Building an auditable record of beneficial ownership
Feature two: reliable identifiers for people and entities
"What other companies did a particular beneficial owner act as a director of at that time?"
This question is very difficult to answer if individuals are not identified in a common and unambiguous way within declarations from all companies. A name is not enough to guarantee that a person or entity can be correctly identified. A unique reference such as an ID card number, an internal database key, or a company registration number (along with information about the issuing authority) can help identify the individual or entity in the real world.
These identifiers have a further function: they allow information about an individual or an entity to be brought together when it is disclosed at different points in time, or by different agents. Of course, considerations of data protection and privacy require that minimal personal information about individuals is made public, while still ensuring that the data is usable. This might mean that minimal descriptive fields relating to an individual are published; for example, just a name and a birth month and year. However, non-identifying internal references or identifiers can also be published so that an individual’s connections with multiple entities is made transparent.
BODS allows different types of identifiers to be published for people (and for entities). So, for example, a non-identifying internal reference number FFT-826-HKE908 could be published for a particular beneficial owner. Finding out what other companies they are a director of would then simply involve searching records of directors for the same “FFT-826-HKE908” reference.
Recommendation
- Good-quality unique identifiers should be provided for people and entities so that changes in beneficial ownership can be connected to the correct records.