bcgov
Requirements: Changes/Corrections to Significant Individuals (post-filing)
We need to understand the business flow around how changes/corrections can be made to SI filings. Note: In all cases BC Registries must retain historical data - i.e. we update a record but still are aware of how the record appeared prior to the change/correction
1. What can be changed? Everything? • The following can changed or be corrected: - Name, - Address, - Citizenship, - Tax residency, - SIN/ITN/TTN, - The description of how an individual is a SI. • The following cannot be changed, but can be corrected: - DOB, - Date the person became or ceased to be a SI. NOTE: • If full name field is being edited on a change filing, the person filing should be able to indicate: “Name updated as a result of legal name change, marriage, or divorce.” • If a name has a spelling mistake, then a correction filing can be used to correct the spelling. • Ceased SI information cannot be edited on an SI change filing. • Any change to ceased SI information would be a correction as there is no legislative requirement to update the information of a ceased SI. • An individual listed as a ceased SI, could become an active SI again before company has deleted them from the RTR, will need a way for ceased SI to again be listed as an active SI with same editable fields as an active SI. • Note about deletion of ceased SIs: Allow a company to delete from the TR a ceased SI. If company tries to delete SI from RTR within 6 years from cessation date, messaging should be provided to indicate that perhaps this information should still be present on the company transparency register according to section 119.4. However, the Registry cannot prevent deletion of the ceased SI in this scenario, and SI delete option should be available for the company to select. Note: we have requested policy amend legislation to allow us to delete a person on behalf of the company after 6 years to reduce effort. This interaction for deleting after 6 years isn't needed for MVP.
2. What data prepopulates in a change/correction filing? According to policy's feedback this is a business decision that the Registrar must make. Nothing in the legislation stops from allowing all fields to populate for changes/corrections. Note that the date a person became or ceased to be a SI is still not publicly available and will not be until legislative changes are made post implementation.
3. Who can file a change? Anyone authorized to make changes on behalf of the company can make changes.
4. Who can file a correction? Corrections are a client only filing. Staff will not complete transparency register filings, changes or corrections due to the high volume of personally identifiable information. As per policy's feedback this is a business decision that the Registrar must make. Nothing in the legislation stops the Registrar from allowing their staff to view/make changes. Section 414 of BCA titled “Correction of registers applies.” This section indicates that the registrar may correct an error or omission in this register if the registrar is satisfied that the error or omission exists and is satisfied as to the true facts that ought to have been incorporated into the register.
5. Can we assume there are no fees for any changes? Yes, no fees will be applied. The fee issue paper identified we would review after go-live.
See UI Design ticket #19229
@steveburtch with the recent discussions on protecting information it seems like we would show the details available in the public search when a transaction was launched but any updates to fields other than those displaying would require re-entry. The questions above still apply though and I think we'd seen a circulated chart from @Apt766525 outlining those fields. @Apt766525 can you update the ticket with your findings on "What can be changed" and "Are there any fees for findings?". Ideally, if you have the requirements stored on the Google Drive in the requirements folder you could provide a link in this ticket?
@mstanton1 yes, this will need to be spelled out asap. Let's brief @Apt766525 this morning at our Review Tickets meeting.
Removing "On Hold". Based upon our discussion this morning requirements for items #1 and #3 can still be addressed now.
@mstanton1 @Apt766525 It isn't clear what the requirements are - there's no documentation of the the last comment above here. Can someone update the details section with the requirements?
@forgeuxGH5 @mstanton1 Its still under progress. Waiting for some input and confirmation on the requirements. Once received will update the details section and notify.
@mstanton1 @forgeuxGH5 Have updated the details section with the requirements.
@forgeuxGH5 @mstanton1 Change is nothing but the edit mode, anyone authorized to make changes/edit on behalf of the company can make changes. Whereas corrections are a client only filing. But nothing in the legislation stops the Registrar from allowing their staff to view/make changes/correction. As per policy's feedback its the Registrar's decision. DOB and effective date cannot be changed/edited but can be corrected.
@mstanton1 @Apt766525 we need to know exactly which fields can be changed by the business in this form. It's not clear if corrections are made in this form or other filing/form.
@forgeuxGH5 @mstanton1 Here's the list of fields that can be changed: https://docs.google.com/spreadsheets/d/1y4MNXpp5rqbH8lw0oe_sBHbtHIVCetFd/edit#gid=618906945
@Apt766525 can you seek clarity from policy on one last item (added as #6 above) please?
Decision from Design today - no requirement to re-enter all data. However, there is a requirement to ensure that private data that could cause harm (SI address and SIN) does not display when change is launched. Could be accomplished by masking.
@mstanton1 @forgeuxGH5 In regards with the #6 in the above details section, changes can be made to an SI’s information and cease them in the same filing. While the legislation requires that companies update the information with the Registrar within 15 days of having received new information, we know that companies are not always on the ball with updates.
@Apt766525 can you set up a time with @J-Baese to go over these requirements?
~~@mstanton1 I have the design ticket linked to this ticket - we should make sure that is linked to the dev tickets~~ comment should have been in another ticket
@forgeuxGH5 both this requirements ticket and the design ticket are linked to the epic. All dev tickets from pre-grooming are also be linked to the Change Significant Individuals Epic (#19898). We'd been including links to designs within each dev ticket but could revisit if needed.
~~@mstanton1 either way - there's info in the design ticket that the devs need to use so as long as they know to get it from there but I don't see it linked to any dev tickets right now.~~
Let's continue as we've been doing for now and put the Figma links in each dev ticket where applicable. Dev's can also easily locate this from the Epic on the side. Thanks
