What do investigators, government, procurement & tax officers want from a global beneficial ownership register?
Grand corruption is a networked problem. To fight it we need a networked solution, and nowhere is this more true than who controls and benefits from companies. For the past year, a group of organisations have been working together to create a Global Beneficial Ownership Register. The Global Beneficial Ownership Register will tackle this, by collecting and linking together beneficial ownership datasets and self-disclosed corporate data. By doing this, it will enable investigators and corruption fighters see the connections between ownership of companies and trusts the world over, and allow governments and business to more easily see who they are really doing business with.
The creation of such a register cannot and should not be done in isolation and therefore, at the 4th International Open Data Conference in Madrid, Spain — I helped organise a workshop to map & design user needs.
We used human-centred design techniques to explore the need for global beneficial ownership data, used people in the room to reflect on their workflows and needs and sketch out what a platform could like if it had to be useful for them. In this post, you’ll see what we learned from the workshop.
Who benefits from access to beneficial ownership data?
There has been a global movement of civil society and businesses who have been working together to push governments for greater transparency and it has achieved some success. The UK has already started collecting and publishing beneficial ownership data. Norway, South Africa, Nigeria, Denmark, Afghanistan, France are amongst others have pledged to do the same. But does control mean the same thing in different jurisdictions? This was the question looming in our head so we put it to the crowd. As you can see, we got some interesting answers on the definition of control but we were surprised that it was more difficult to get people who work in the space of accountability to pin down how they would define control.
The mapping of various stakeholders who benefit from open access to beneficial ownership data was a lot more successful. 27 post-its covered a range of professionals from auditors to academics. The full list was as follows: Business intelligence, politicians, governments, tax officers, average citizens, compliance, anti-money laundering, banks, accountability NGOs, journalists, regulators, academics, tax authorities, corporate formation agents, activists, auditors, due diligence, lawyers, accountants, investors, corporate governance, donors, public procurements, wikileaks, customers and shareholders.
The participants in the room ranged from representing different government divisions from Canada to France, as well as civil society and journalists specialising in tax, extractives and banking. When asked why they wanted to attend the workshop, the links Beneficial ownership has to contract fraud, aid corruption, tax justice and extractive exploitation came up high up on the agenda.
After this, we divided into three groups with people who either are or work with the following professionals: (1) NGOs and investigative journalists (2) Government and procurement officers (3) Tax officers.
Personas & Workflows
Who would use the register? What does a typical work day for them look like?
Adopting personas to map user needs and workflows is a popular technique to allow people to step outside of their own preconceived notions and explore the world from another viewpoint. While this is a useful exercise in building empathy and a better understanding of other people’s life, from running these workshops before, I’ve had the experience that sometimes we tend to make even larger assumptions when we do this. If you are an accountant in Lagos, you may be able to imagine the day to day work-life of a lawyer and tax officer in the region but it might be difficult to imagine that of a investigative journalist in New York. Not only is the professional context important for nailing down procedure, but so is the geo-context.
We were very aware of this when designing the workshop so we asked people to stay in groups that relate to their work. This meant that they were simply thinking about their own profession, and sketching out what life was for themselves and their colleagues. You can see the rich insights from the groups below.
Government / Procurement Officers
Personas: Jean Michelle (Procurement Officer, France), Jessica (Procurement Officer, Canada) and Brad Cusa (Procurement Officer, USA), Pedro (Procurement Officer, Spain).
France: Jean Michelle
54, Procurement officer, long serving government employee.
Jean Michelle has access to the National contractor database which has Corporate IDs and an entity register. Though it is under fee for re-use at the moment and is scheduled to be opened up later. This doesn’t concern Jean Michelle. He already has access to all public and private contractors but struggles with the quality of the data.
When he is conducting due dilligence on a contractor, he looks at factors such as capacity (can the contractor undertake this project efficiently?), and financial background (is there a history of bankruptcy and blacklisting?). At the moment he will not have access to or ask for beneficial ownership data. If he had to establish links between companies and people, he will ask for resumes of collaborators and see who sits on the board.
What are his needs? He needs support in identifying data sources for beneficial ownership data and believes this data should at least be available to public servants. He would also like to see a public Trust register and company register.
Procurement Officer, Government of Canada
Procurement officer will screen government database of official providers, takes requirements of the bid and loads it onto a portal. Screening is basic and she will take resumes into account. Jessica believe having a beneficial ownership register will be useful to validate companies, especially those with lowest bids.
She needs access to beneficial ownership data to get access to basic information, as well as verification and corporate structures.
Procurement Officer, Spain Government
Pedro works at municipal level is interested in how citizens could participate in the process. How could they be sure that the company awarded was the right one? Could a global beneficial ownership register have a ‘red flag companies’ feature or have a white listing approach?
For Pedro, it seems very clear that operational baselines are very manual and that in time workflows should be automated.
Federal Government Procurement Officer, US Government
Brad operates in a sophisticated but fragmented awards environment that is federally mandated. He has worked in this role for 9 years. He has a big workload and has to deal with a complex system highly reliant on paper-based procedures and different databases. Even though there is a lack of innovation culture, he wants to use the global beneficial ownership register as a quick check on the honesty of existing disclosures in Integrated Awards Environment.
Investigative journalists & NGOs
Personas: Roberto Pernieri (NGO), Unnamed Investigative Journalist.
Roberto has a keen eye for measuring the quality of data as he is used to working with multiple sources of data (e.g. whistleblowers, regulatory data and news stories). when he is using it to investigate companies and corruption. He likes to write reports and investigative pieces that make people ask questions about systemic corruption. Advocating for more public data from government s a key part of his remit. He mostly works on paper but is increasingly using data to inform and distribute his work.
The mission of this investigative journalist is to uncover corrupt networks connecting politicians and businesses, sometimes with a link to contracting. They have a short timeframe to turn around the investigations and need information on the evaluation of the company, ownership shares, fields of business activity, and size amongst others. They also need the ability to filter the data as they wish to test hypothesis and find connections between entities.
Persona: Female Tax Officer (Tanzania).
The tax officer for Tanzania might have up to date information about local companies but wants to know more about global companies active in Tanzania. As she works in a low capacity environment, she often has to lobby other governments departments for access to data. She feels passionately about tax justice and needs a strong legal framework to support her work. She wants to build trust and awareness in the general public about tax issues and needs to access global beneficial ownership data to do this quickly and efficiently.
What would these users need from the platform? Would this be different based on their job roles and their geo-context?
Once we had explored user needs and identified different points in the workflow of the user groups, we moved on to sketch what an ideal platform would like for them. We were curious to see if there were any differences or similarities in the approaches.
Almost every wireframe (20 pages) showed that the platform must have:
- the ability to search with different keywords
- a strong filtering function
- visualisation of the networks (tree diagrams, neo4j powered, network diagrams, tables & more)
- provenance (no surprises there!)
- explanation of the type of type of control
- historical records
- capturing/showing other ‘optional’ relevant datasets (project by project reporting, tax registers, aid information etc)
There were differences in what search bars to prioritise and this was because each user group would have a different ‘lead’. An investigative journalist might know the names of people involved in a corruption or money laundering ring so may be looking at what companies connect the people together. The procurement group preferred company name first because in that role, the ‘lead’ is the company that is applying for the contract.
In conversations about transparency, skeptics often said that designing a global beneficial ownership would be too complex and that it would not be able to aid the work of professionals who investigate companies.
The output from this workshop could not tell a more different story.
If in the space of two and a half hours, a group of 20 professionals from different parts of the world and work spectrum can come together and rapid prototype practical solutions — there is no doubt that it is something that can be done. Alongside OpenCorporates, the world’s largest open database of company information, the steering group for the Global Beneficial Ownership Register includes transparency NGOs (Transparency International and B Team), web standards and accessibility advocates (Web Foundation), investigative reporting watchdog (Global Witness), open contracting pioneers (Open Contracting Partnership) and poverty and human rights advocacy group (ONE Campaign).
We will be spending the next few weeks analysing the feedback and ideas that came from the workshop. Additionally, B Team is also convening a Business Advisory Group so we can make sure the platform works for businesses who want to self-disclose beneficial ownership data.
This workshop has given us a lot to think about but we know there is a lot more ground to cover. To ensure we have diverse opinions from around the world, we will be doing an online version of the workshop. If you would like to stay in the loop for that, sign up to our newsletter.
Thanks to all participants from giving us their honest ideas and feedback as well as Gavin and Kristen for writing up notes during the workshop.