Alignment of BODS with Principles for Effective Disclosure

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BODS should be able to show how it supports data publishers to implement the OpenOwnership Principles for Effective Disclosure.

Achieving this involves a number of steps:

• [ ] (1) Review of the principle indicators to identify any changes required to BODS in order that it fully supports implementation of the principles.
• [ ] (2) Creating a page in the BODS documentation that will detail alignment between the principles and BODS.
• [ ] (3) (Optionally) Providing more detailed worked examples to show how BODS is aligned with, and supports detailed implementation of, each of the principles

A draft of text for (2), showing the relevance of BODS to each of the principles is given below.

In some cases, mapping is also possible at the indicator level (e.g. C-EX-PS "Any grounds for beneficial owners (natural persons) to be exempt from public disclosure requirements are clearly defined" has a direct mapping to used of the UnspecifiedReason codelist

Example of Principles <-> BODS mapping

Written as though BODS 1.0 implements all relevant features (still tbc.)

A public register BODS 1.0 encourages open licensing of data, and provides space to include license meta-data with each disclosure.

Robust Definitions BODS 1.0 can be used to describe all forms of ownership and control.

Comprehensive coverage BODS 1.0 supports description of a wide range of entities and owners, including State Owned Enterprises, and legal arrangements.

Low thresholds BODS 1.0 can be used to describe the exact interests held, or to provide a range where exact figures are not known.

Ownership chains BODS 1.0 statements can be chained together to provide the full picture of ownership and control, and the statement-centric model allows data from multiple sources to be integrated to reveal networks or ownership and control.

Clear identification BODS 1.0 provides a clear privacy-sensitive approach to identifying companies, arrangements and individuals, adopting a decentralised best-efforts approach to find matches between different disclosures and sources.

Accurate and complete BODS 1.0 includes features to support data verification, and to record the provenance of disclosures.

Timely and updated BODS 1.0 statements are timestamped, and the standard provides clear guidance on approaches to data updates.

Historic records BODS 1.0 statements are immutable, supporting a ledger-like approach to track the history of ownership and control, supporting investigations and audit.

Sanctions and Enforcement BODS 1.0 captures details of non-disclosure, for documenting missing data, and for recording enforcement actions.