Submission from GS1 New Zealand Regarding the New Zealand Business Number Discussion Document

Transcription

1 Submission from Regarding the New Zealand Business Number Discussion Document Authors: Sally King, General Manager Government Dr Peter Stevens, Chief Executive Inc April

2 Table of Contents 1 Who is GS1? Who is? Background and Introduction Key Messages Complete coverage of the NZBN in government is essential Similarly, NZBN coverage for all businesses must be mandatory Implementation is critical to success Current GS1 Members with a pre-existing allocation of a legal entity GLN should have the option of grand-parenting their GLN Our Members require clarity, stability and accountability Authentication and identity verification still needs to be addressed The proposed use of the NZBN for street location creates risk Greater visibility for government interoperability is recommended Specific responses to the Discussion Document questions Companies already have an NZBN. Who else should have one? Should any business be exempt from having one? What information should be kept centrally? Why? What access will government agencies have to your information? What information should be public? Why? Do you agree that businesses can choose to include more information with their NZBN public information? What information should third parties, like banks, be given access to be you? Why? Do you want to be allocated your NZBN automatically, or do you want to apply for it? Should the NZBN attach to a business, or the legal entity that carries on the business? What should happen to the NZBN if a business is sold? Should NZBNs expire? Why/why not? Do you agree that a person who is bankrupt should continue to have an NZBN? Do you think NZBN legislation should permit the use of the NZBN across both the public and private sectors with appropriate protections for your personal information? Are there reasons why NZBN information should not automatically be available to government agencies you deal with? Understanding Global Location Numbers in the GS1 world What Is a Global Location Number? What Is a GLN Used For? Business Benefits of Using GLNs

3 1 Who is GS1? For the last 40 years, GS1 has been dedicated to the design and implementation of global standards for use in the supply chain: 1. Identification standards for the identification of objects, locations, assets 2. Automatic data capture standards for technologies such as bar codes or radio frequency identification (RFID) 3. Data sharing standards supporting supply chain visibility, traceability, electronic cataloguing and authentication processes. GS1 standards provide a framework that allows products, services, and information about them to move efficiently and securely for the benefit of businesses and the improvement of people s lives, everyday, everywhere. GS1 s standards ensure effective exchanges between companies, and act as basic guidelines that facilitate interoperability and provide structure to many industries. GS1 standards bring together companies representing all parts of the supply chain manufacturers, distributors, retailers, hospitals, transporters, customs organisations, software developers, local and international regulatory authorities, and more. GS1 standards are used by huge multinational chains and by small corner shops; by world-famous brands and by individual craftsmen. These companies, who may in fact have diverging business interests, work together under GS1 s auspices to agree upon standards that make the supply chain faster, more efficient, less complex and less costly. Without a neutral, not-for-profit and global organisation like GS1, such very diverse companies would probably not be able to agree on standards. GS1 makes it happen, and consumers and businesses benefit. Originally created by manufacturers and retailers to improve the efficiency of the distribution of food and consumer goods to supermarkets, GS1 standards today are used by millions of companies in dozens of sectors including healthcare, transportation and logistics, aeronautics, defence, chemicals, high tech, and still, of course, the retail supply chain. GS1 has offices in 111 countries. Our work is funded by the contributions of our users. Some of the world s largest corporations participate in our boards and work groups. GS1 is not: A government agency. A commercial solutions provider A software provider A hardware provider A technology company A trade organization 1.1 Who is? GS1 NZ is one of 111 country-based Member Organizations of GS1. We are a not-for-profit standards and services organization, locally governed and owned by more than 5,000 organisations in more than 20 industries including fresh foods, healthcare, produce, packaged foods, beverages, consumer packaged goods, government, retail and transport & logistics. The Board consists of senior executives from: Foodstuffs, Countdown, Fonterra, The Warehouse, ANZCO Foods, NZ Retailers, PepsiCo, Placemakers, Apotex and a nominee from the Ministry of Health. This submission is representative of member views; and we request the opportunity to be heard. 3

4 2 Background and Introduction A shared business language for identification, and information sharing that is standardised, global, open, and non-proprietary, is an important enabler for e-commerce success going forward. The New Zealand Business Number (NZBN) is an excellent first step for government; however, it can only be the beginning of a programme of change. We commend the intent of improving the B2G (Business-to-Government) environment for business, but also see this as a very important step in enabling a very robust platform for e-commerce B2B (Business-to-Business) and B2C (Business-to- Consumer) with a data standard that allows for a globally unique open identifier for all New Zealand businesses. A unique business number (now the New Zealand Business Number NZBN) has been in discussion in government agencies for at least 5 years. Earlier Ministry of Economic Development analysis considered a range of options for the unique number, including GS1 s Global Location Number (GLN), Australian and Canadian Business Numbers, Inland Revenue tax or GST number, and 5 others. The GLN was selected for the New Zealand Business Number by government, as it is a reliably allocated, consistently available, globally unique identifier, recognised as an international standard. In 2011, GS1 and the Companies Office began partnering on delivering the GLN to sit alongside (and eventually replace) the Companies Office Number for all limited liability companies. This was a very significant challenge for a small not for profit organisation - shifting from a register of 5,000 NZ members to 1,100,000 Companies Office entities current and historic. The programme of work was delivered on time and without any major challenges. Importantly, it has also enabled a federated, worldwide NZBN search capability a benefit that was not originally scoped into the project, but provided for by the use of GS1 s GEPIR our Global Electronic Product Identification Register. GEPIR will locate the public and GS1 member data (if appropriate) about all New Zealand businesses. This is illustrated as follows One can search for an NZBN the New Zealand Companies Office site by official registered company name, NZBN or Companies Office number 4

5 Or one can search for a NZBN (or a registered company name, a trading name if a GS1 member, or NZBN number) on the GS1 NZ Global Electronic Product Identity Register (GEPIR) site and the data GS1 holds in New Zealand is replicated in our worldwide Global Electronic Product Identity Register (GEPIR), providing world-wide access and visibility. 5

6 However, the NZBN currently covers only half the NZ businesses. Smaller, non- limited liability businesses have also been advocates for the introduction of a unique number to provide data to government just once. Similarly, intermediaries (i.e., tax agents, accounting and payroll software developers) see that a NZBN would facilitate business-to-business (B2B) e-commerce. The greatest benefits for businesses, in our view, are the B2B impacts rather than the B2G. But such benefits and network effect only happen if all trading entities use the NZBN. GS1 NZ is pleased to endorse the proposal to extend the NZBN. Moreover we note that the NZBN, could, if properly managed across government agencies, support other global data standard initiatives. There are other projects or systems extant or in progress that provide opportunities to leverage the NZBN and other global data standards, including: NAIT (run by OSPRI) and FarmsOnline (run by MPI) both these systems are mandatory for the primary sector, and are vital to NZ s biosecurity and traceability infrastructure. Both systems, it is likely, have relevance in the government s response to the Whey Protein Concentrate contamination (WPC) Incident. Both systems are not appropriate for the emerging need for global interoperability in our view. Customs-MPI s Joint Border Management System has the potential to leverage global data standards (including GS1 s standards for item identification) for expedited risk assessment and cross-border movement of goods. The public healthcare system, via shared services agency Health Benefits Ltd, is rolling out GS1 s data standards to drive transparency and economies in procurement operations (the DHB National Catalogue). The extension of these data standards closer to the point of patient care has quantifiable benefits for patient safety. (The Ministry of Health has done a business case on the benefits of bedside verification of medications). We believe there may be further opportunities for interconnection both in the work we have underway with government, and in the recent RFI/ROIs we have seen, that could leverage further government s investment in the NZBN. 6

7 3 Key Messages 3.1 Complete coverage of the NZBN in government is essential. For the full benefits of the NZBN to be realised it is essential that all government agencies and public sector entities are involved, and ideally all local government or compliance organisations. A partial solution with some government entities using the identifier and others using a different organisation-only account number or identifier will defeat the purpose of an NZBN and create confusion. Such an outcome is counterproductive and will devalue the utility and businesses trust in the NZBN. Given the Result Area is a high profile goal and was established in 2012 the NZ public sector have already had more than 18 months awareness of the programme. GS1 recommend a further window of no more than 3 years for all public sector organisations be allowed for transition to avoid business disengagement. A published deadline for all government entities to be accepting the NZBN to identify, transact, and access government services is recommended. 3.2 Similarly, NZBN coverage for all businesses must be mandatory. Yet another identifier that is not universally applied would be the worst possible outcome for business. A partial solution with some trading entities using the NZBN and other trading entities using a different identifier will defeat the purpose of an NZBN and create confusion and additional costs. Such an outcome is counterproductive and will devalue the utility to government of the NZBN, and it s applicability in B2B e-commerce. We recommend all trading entities have an NZBN, and that it be allocated automatically. Having business identification reliably allocated and consistently available will become a powerful enabler for New Zealand. 3.3 Implementation is critical to success. A poorly executed implementation, as has been seen in several recent large government technology projects, would significantly damage confidence in the NZBN project. The implementation by government, including the transition process, needs to be efficient and simple. Avoiding risk often translates into very drawn out implementation. This must be avoided and the priorities of businesses, rather than the government entities processes, should be given predominance. Government entities not fully compliant should be required to operate interim solutions in order to accept the NZBN as their identifier by the deadline. 3.4 Current GS1 Members with a pre-existing allocation of a legal entity GLN should have the option of grand-parenting their GLN Hundreds of significant NZ businesses (e.g. Foodstuffs, Fonterra, ITM, Placemakers, Health Benefits Ltd etc., etc.) and registered subsidiaries of large multinationals (e.g. Baxter Healthcare Ltd) currently use Global Location Numbers to identify their operations. GS1 recommend the government develop a process to register qualifying GLNs in the NZBN registry. 3.5 Our Members require clarity, stability and accountability. At present the Ministry of Business and Innovation is driving the NZBN on behalf of just 9 government agencies, not all government bodies. This is inadequate. Our members want to see the acceptance of the NZBN mandatory across the public sector. In addition our members were concerned about a change of government and internal public sector changes. They asked for assurance that the decision to have a government assigned 7

8 identifier not be reversed, be properly funded, and have straightforward decision making to ensure compliance, consistency and appropriate controls. We recommend that the ongoing model of governance, accountability, funding and management rights for the NZBN be clarified before the law is passed. Accountability (and the decision rights and funding that underpin accountability) needs to be assigned to one agency; ideally MBIE or, if this is considered outside of MBIE s mandate, to the GCIO. This will ensure that the appropriate level of oversight and decision-making is achieved. Accountability in the matter of privacy, protections and redress for any government misuse of data is a critical part of this responsibility. The monitoring and reporting of government s use of any businesses NZBN data (especially anything not made public), needs to be transparent and an agency identified as accountable. 3.6 Authentication and identity verification still needs to be addressed It is not clear how authentication and verification will be established so that Internet crossparty transactions can be enabled. This must be clarified before any extension of the NZBN is introduced. Whilst this is not really a B2G issue, (and the discussion document rightly signals the need for agencies to ensure their own authentication requirements are met), the B2B opportunity enabled by a NZBN is dependant upon how authentication and identity verification is ensured. A poorly regulated or managed verification or authentication process is a considerable risk. It might be possible for a business to opt in by choosing among trusted third parties such as banks, technology service providers, etc. These third parties could verify certain information about businesses and issue secure credentials to use in online transactions. However, unless there are stringent safeguards, overseen in a robust manner, third party identity verification online could make businesses more vulnerable, and undermine the integrity of the NZBN. This matter is especially pertinent to sole traders businesses, which would risk their business identity and potentially their personal identity. Ideally any validation and authentication process is also recognised in the key markets New Zealand businesses operate within. Although not an area that GS1 operates directly within, we would further recommend the use of global data standards to ensure authentication interoperability. 3.7 The proposed use of the NZBN for street location creates risk By suggesting the extension of a business entity identifier to include street address as part of the data populated to a public website puts at risk the important data structure that the GLN is based upon (unless it is consistent GS1 s global and local practice and supports existing GLN allocations). All information architecture depends upon unique, reliable and authoritative data to ensure ongoing operability and most importantly in the NZ context, interoperability between B2B, B2G, and G2G. Our members have specifically asked a question: Can I use my NZBN for other street or geographic information by adding other alpha-numerical information? We have advised that this is very poor practice. GLNs operate typically on a tree-ed arrangement of data that provides a cascading data infrastructure to remain globally unique, authoritative and reliable (e.g.: a legal entity > a facility > a building > a part of a building). The NZBN is a register of businesses and should not become everything for every purpose. The NZBN identification should only be used for legal entity identification, and not bastardised to create street address identification register. 8

9 3.8 Greater visibility for government interoperability is recommended As indicated by the recent changes in the State Sector and Public Finance Act, the delineations in the New Zealand public sector that have separated individual agencies are not altogether helpful in digital world. We are increasingly seeing the interdependence of actors, not just between businesses and government within New Zealand, but across national boundaries and indeed, with global end consumers. The NZBN is an excellent step for government; however, it must be the beginning of a programme of change. Optimal but unconnected agency systems simply externalise costs (businesses bear this) and the amount of storage and data maintenance required is phenomenal. GS1 note however, that advances in establishing a platform for digital platform for business to government interaction in New Zealand can t be approached efficiently via a policy level alone. Broadly interoperability can be described in 4 levels. Approaching interoperability at the legal level, as the NZBN Discussion Document does, is essential, but insufficient. An indication of the range of interoperability questions to be addressed by a cohesive e-government approach GS1 believe that there are several layers of interoperability, harmonisation and alignment that need addressing including technical, semantic, (including data standards) process and legislative interoperability. It is not clear in the discussion document, or indeed in any of the published information from other government agencies or the Government Chief Information Office if the matter of interoperability is being considered (beyond the specific Result 9 and 10 projects), and if so, how. In our view the Government Chief Information Officer (or an authorised agency) seems a natural owner for matters of interoperability on behalf, and for the wider benefit of, the public service. Trade-offs, (which will be almost inevitably suboptimal for some agencies), are a consequence. As these trade-offs arise, bold calls taken on behalf of the public sector by one designated leader for interoperability must be transparently and decisively taken. 9

10 4 Specific responses to the Discussion Document questions appreciates the opportunity to provide these comments to the Government Discussion Document, Less Admin, More Business. The following are responses to the specific questions posed by the Discussion Document. We have provided some key messages and recommendations above (section 4) that are our members key issues. 4.1 Companies already have an NZBN. Who else should have one? For the benefits to be realised, NZBN coverage for all businesses or those trading in the economy must be mandatory. Yet another identifier that is not universally applied would be the worst possible outcome for business. A partial solution with some trading entities (and government enterprises) using the NZBN and other trading entities using a different identifier will defeat the purpose of an NZBN and create confusion and additional costs. Such an outcome is counterproductive and will devalue the utility to government of the NZBN, and it s applicability in B2B e-commerce. We recommend all businesses, regardless of their structure or tax status, that are trading have an NZBN, and that it be allocated automatically. Having business identification reliably allocated and consistently available is, in our view, will become a powerful enabler for New Zealand. 4.2 Should any business be exempt from having one? No. 4.3 What information should be kept centrally? Why? The information that is held centrally by government could become a critical question over time, depending upon the framework that government determines for data interoperability of its administration, and the privacy settings in place in New Zealand. This issue is well beyond the scope of this one policy proposal, and highlights a limitation of the existing policy and strategic approach to e-government. The current requirement to interact with each agency individually providing the same, or similar data is a huge cost and compliance burden to taxpayers and businesses. It is the government s goal is to ensure business cost effectiveness and effective data management. If so, reducing business-reporting requirements, submitting data to just one authoritative, verified location/agency is sensible. This would imply that ultimately all business data, not just the proposed BIC, business name and general geographic information should be reported once, managed by only one source and aggregated as the law allows for each agency s reporting/monitoring requirements. Where and what NZBN data is kept is less important than who and how government agencies can access it; how it is monitored; the security of the system; and rights of redress for any inappropriate access or use. 4.4 What access will government agencies have to your information? Only access explicitly allowed for by law, regulation or other legislative mechanism. Businesses could, if they so choose, opt in to allow access for agencies for other data as it suits. The monitoring and reporting of government s use of any businesses NZBN data (especially anything not made public), needs to be transparent the businesses concerned. 10

11 Accountability in the matter of privacy, protections and redress for any government misuse of data is a critical. One agency should be identified as accountable for the appropriate use of the NZBN data. 4.5 What information should be public? Why? GS1 favour an opt out, rather than an opt in model of data provision, of the following elements: NZBN Trading Name Electronic address (e.g. website, generic address) Business Industry Classification (BIC) and a generalised region data but these are only valid for B2G and G2G reporting. If the business code is to be required, then to add value to businesses, their suppliers and potential business customers (i.e., as part of the public facing online directory), the codes would need review 1.. Unless there are specific, validated reasons, which justify withholding a trading name, the trading name of the NZBN holder should be captured and an e-service address should be publically available. There is a difference in the B2G needs and the B2B and B2C needs possible within the NZBN. In many cases, B2B will be incentivised to provide a wide range of data to enable e-commerce business and consumer interactions, etc. A trading name and e-service detail simplifies this process further: businesses will have secondary points of verification and avoid user error. Electronic addresses for maximum benefit need to be accessible via an API to allow for automatic checking. Importantly, transparency regarding a NZBN for end consumers, who may choose to look up the online directory and check the legitimacy of a trading entity, is not enhanced by the proposed data set. The NZBN is officially recognised by government, which, for some consumers, (particularly those from other cultures), could be misconstrued as an official endorsement. A trading name and an address for e-service, whilst not a perfect solution, contributes to consumer confidence and trust. 4.6 Do you agree that businesses can choose to include more information with their NZBN public information? Yes. The data being used for e-commerce needs to be held in a standard format so that interoperability is achieved. 4.7 What information should third parties, like banks, be given access to be you? Why? Third parties should have access only to the publically available information. All other information should be at the discretion of the business concerned. 4.8 Do you want to be allocated your NZBN automatically, or do you want to apply for it? Automatic allocation. Any opt-in arrangement will not ensure complete coverage. Yet another identifier that is not universally applied would be the worst possible outcome for business. A lack of complete coverage defeats the purpose of an NZBN and creates confusion and additional costs. Such an outcome is counterproductive and will devalue the utility to government of the NZBN. More importantly, it will defeat the adoption and applicability of an NZBN n B2B e-commerce. 1 As a small example, Business Consultant Service (M696205), Management Services Consultant (M696297), Management Consultancy Service (M696245), are all listed separately as BIC codes. This is not terribly useful for searching the online data. 11

12 4.9 Should the NZBN attach to a business, or the legal entity that carries on the business? We agree that the NZBN attach to the legal entity that undertakes the business What should happen to the NZBN if a business is sold? In light of 5.10 above, as the legal entity (i.e. the sole trader or other non-registered entity) can not transfer on the sale of the business, then the NZBN should stay with the sole trader. However, as a separate legal entity, a registered company s NZBN should transfer with its sale Should NZBNs expire? Why/why not? In light of 5.10 above, for simplicity and certainty, NZBN should remain as long as the entity exists. Cancellations, suspensions and expiry, if any, should follow as closely as possible the current model of the Companies Office, for consistency Do you agree that a person who is bankrupt should continue to have an NZBN? We agree that a person who is bankrupt should continue to have a NZBN, and agree that a link should be made to the insolvency register Do you think NZBN legislation should permit the use of the NZBN across both the public and private sectors with appropriate protections for your personal information? With appropriate protections for personal information, we recommend that the NZBN legislation should permit the use of the NZBN in both public and private sectors for business purposes Are there reasons why NZBN information should not automatically be available to government agencies you deal with? No. However, government agencies should be able to access only NZBN data explicitly allowed for by law, regulation or other legislative mechanism. The comments we have made to the specific questions must be read in context and alongside the broader messages in section 4. 12

13 5 Understanding Global Location Numbers in the GS1 world The New Zealand government has selected a very widely adopted GS1 global standard, the Global Location Number (GLN) for the NZBN. Below we provide some background context for the GLN and how the GLN is used in commerce worldwide. 5.1 What Is a Global Location Number? The Global Location Number (GLN) is used to identify physical locations or legal entities. This unique identifier is comprised of a GS1 Company Prefix, Location Reference, and Check Digit. 5.2 What Is a GLN Used For? GLNs are used to identify parties to business transactions; functional groups within a company; or real, physical places that might ship, receive, process, or hold inventories. Examples include: LEGAL ENTITIES: Whole companies; subsidiaries or divisions within a company; corporation, etc. FUNCTIONAL ENTITIES: Specific department within a legal entity, such as an accounting department, purchasing department or hospital pharmacy, etc. PHYSICAL LOCATIONS: Manufacturing facility, distribution centre, warehouse, dock door, hospital wing, bin location, retail store, etc. The GLN will uniquely identify any location or legal entity, thus ensuring that it is always identified correctly anywhere in the world. Some companies choose to allocate one GLN for their whole business, while others allocate an individual GLN for every location they need to identify. This could be a warehouse goods-in door or a hospital bed location in a ward. The GLN allows complete flexibility for whatever level of location identification is required. As a GS1 Identification Key, the GLN will always be unique, thereby allowing trading parties to exchange GLN data for location identification with no danger of number duplication. A GLN can be assigned anywhere in the world and can be used throughout the world. The GLN is a required component of the Global Data Synchronization Network (GDSN ) and various types of e-commerce transactions. This global identification system of GS1 ensures that the GLN placed in a barcode or Electronic Product Code TM (EPC ) is the same information contained in the corresponding electronic documents processed between trading partners. 5.3 Business Benefits of Using GLNs There are a number of benefits of using the GLN to identify parties, functional groups, and physical locations: The structure of the GLN and its assignment rules are administered by GS1, a not-forprofit standards organisation that is supported by implementation guidance, business examples, and maintenance. The GLN can be used throughout world with no need for trading partner(s) to assign proprietary numbers to ensure uniqueness. Use of the GLN saves time and money as the number can be moved quickly and confidently through the supply chain. 13

14 Numbers may be assigned to any location to meet the needs/requirements of all businesses anywhere in the world from loading docks to all buildings on government bases to circuit boards in a router. A GLN may be assigned to generic departments at the same location as well as to unstaffed operation points (automated teller machines, vending machines, etc.) The use of GLNs provides companies with a method of identifying locations both within and outside their organisation that is: SIMPLE: An easily defined data structure with integrity checking that facilitates processing and transmission of data UNIQUE: GLNs are unique worldwide MULTISECTORAL: The characteristic of the GLN allows any location to be identified for any company regardless of its activity anywhere in the world GLNs can be encoded in GS1-128 barcodes and/or EPC-enabled Radio Frequency Identification (RFID) tags and physically marked onto: Trade items (products), to identify the parties involved in the transaction (e.g., buyer and supplier) Logistics units, to identify the parties involved in the transaction (e.g., consignor/shipper and consignee) Physical locations (e.g., place of delivery, place of departure, point of storage) GLNs provide a globally unique answer to the Where? portion of EPC Information Services (EPCIS)-read events that are used as the basis for global visibility and traceability in the supply chain. 14