Processes copy

ABSTRACT

By its nature, Alternative Data sits outside current regulatory frameworks, with evolving legal and operational standards. There are two levels of risk associated with Alternative Data:

Participant Risk - Regulatory or reputational risks associated with individual participants, and
Industry Risk - Risk of regulatory strictures imposed on the collection, distribution or utilization of alternative data for all participants.

A key goal in articulating standards is to reduce both levels of risk for originators, intermediaries, and consumers by definiung best practices and industry standards to facilitate the collection, cleansing, quality-control, consumption, packaging, and distribution of Alternative Data, without detracting from the attributes of each dataset.

PARTICIPATION

The mission of the Investment Data Standards Consortium (IDSC) is to create and maintain compliance, process, and product standards for financial data providers and investment managers to increase trust and lower the burden of exploration and onboarding.

The IDSC process document describes the organizational structure of the IDSC and the processes related to the responsibilities and functions they exercise to enable IDSC to accomplish its mission. This document does not describe the internal workings of the Team or IDSC's public communication mechanisms.

For more information about the IDSC mission and history of IDSC, please refer to <ABOUT US>.

1. INTRODUCTION

Most IDSC work revolves around the standardization of financial data. To accomplish this work, IDSC follows processes that promote the development of high-quality standards based on the consensus of the Membership, Team, and public. The objective of such processes promote fairness, responsiveness, and progress: all facets of the IDSC mission. This document describes the processes IDSC follows in pursuit of its mission.

Here is a general overview of how IDSC establishes or revises a Recommendation.

1 Industry participants generate interest in a particular topic (e.g., PII). For instance, Members express interest in the form of Member Topics, and the Team monitors work inside and outside of IDSC for signs of support and interest. Also, IDSC is likely to organize a Workshop to bring people together to discuss topics that interest the IDSC community.

2 When there is enough interest in a Topic (e.g., after a successful Workshop and/or discussion), the Director announces the development of a IDSC Proposal by one or more new Working or Interest Groups, depending on the breadth of the topic of Member Topic. Each Working Group submits a Charter for Members to review. When there is support within IDSC for investing resources in the topic of interest, the Director approves the group(s) and they begin their work.

3 There are three types of Working Group participants: Member representatives, Invited Experts, and Team representatives. Team representatives both contribute to the technical work and help ensure the group's proper integration with the rest of IDSC.

4 Working Groups generally create guidelines that undergo cycles of revision and review as they advance to IDSC Recommendation status. The IDSC process includes significant review by the Members, public, and Technical Architecture Group (TAG), and requirements that the Working Group be able to show implementation and interoperability experience. At the end of the process, the Advisory Committee reviews the mature report, and if there is support, IDSC publishes it as a Recommendation.

The Process Document promotes the goals of quality and fairness in technical decisions by encouraging consensus, requiring reviews (by both Members and public) as part of the report development process, and through an appeal process for the Advisory Committee.

4. DISSEMINATION POLICIES

The Team is responsible for managing communication within IDSC and with the general public. Members should solicit review by the Team prior to issuing press releases about their work within IDSC.

The Team makes every effort to ensure the persistence and availability of the following public information:

• IDSC reports whose publication has been approved by the Director. Per the Membership Agreement, IDSC reports are available free of charge to the general public.

• A mission statement that explains the purpose and mission of IDSC, the key benefits for Members, and the organizational structure of IDSC.

• Legal documents, including the <Membership Agreement> and documentation of any legal commitments IDSC has with other entities.

• This Process Document.

• Public results of IDSC activities and Workshops.

To keep the Members abreast of IDSC meetings, Workshops, and review deadlines, the Team provides them with a regular (e.g., weekly) news service and maintains a calendar of official IDSC events. Members are encouraged to send schedule and event information to the Team for inclusion on this calendar.

4.1 Confidentiality Levels

There are three principal levels of access to IDSC information (on the IDSC web site, in IDSC meetings, etc.): public, Member-only, and Team-only.

While much information made available by IDSC is public, "Member-only" information is available to authorized parties only, including representatives of Member organizations, Invited Experts, the Advisory Board, the TAG, and the Team. For example, the charter of some Working Groups may specify a Member-only confidentiality level for group proceedings.

"Team-only" information is available to the Team and other authorized parties. Those authorized to access Member-only and Team-only information:

• must treat the information as confidential within IDSC,

• must use reasonable efforts to maintain the proper level confidentiality, and

• must not release this information to the general public or press.

The Team must provide mechanisms to protect the confidentiality of Member-only information and ensure that authorized parties have proper access to this information. Documents should clearly indicate whether they require Member-only confidentiality. Individuals uncertain of the confidentiality level of a piece of information should contact the Team.

Advisory Committee representatives may authorize Member-only access to Member representatives and other individuals employed by the Member who are considered appropriate recipients. For instance, it is the responsibility of the Advisory Committee representative and other employees and official representatives of the organization to ensure that Member-only news announcements are distributed for internal use only within their organization. Information about Member mailing lists is available in the <Member Orientation>.

4.1.1 Changing Confidentiality Level

As a benefit of membership, IDSC provides some Team-only and Member-only channels for certain types of communication. For example, Advisory Committee representatives can send reviews to a Team-only channel. However, for IDSC processes with a significant public component, such as the report development process, it is also important for information that affects decision-making to be publicly available. The Team may need to communicate Team-only information to a Working Group or the public. Similarly, a Working Group whose proceedings are Member-only must make public information pertinent to the technical report development process.

This document indicates which information must be available to Members or the public, even though that information was initially communicated on Team-only or Member-only channels.

Only the Team and parties authorized by the Team change the level of confidentiality of this information. When doing so:

1 The Team must use a version of the information that was expressly provided by the author for the new confidentiality level. In Calls for Review and other similar messages, the Team should remind recipients to provide such alternatives.

2 The Team must not attribute the version for the new confidentiality level to the author without the author's consent.

3 If the author has not conveyed to the Team a version that is suitable for another confidentiality level, the Team may make available a version that reasonably communicates what is required, while respecting the original level of confidentiality, and without attribution to the original author.

7. ADVISORY COMMITTEE

Reviews, Appeals, and Votes

This section describes how the Advisory Committee reviews proposals from the Director and how Advisory Committee representatives appeal IDSC decisions and decisions by the Director. A IDSC decision is one where the Director (or the Director's delegate) has exercised the role of assessing.

7.1 Advisory Committee Reviews

The Advisory Committee reviews:

• new and modified Working and Interest Groups,

• Proposed Recommendations, Proposed Edited Recommendations, Proposal to Rescind a Recommendation, and

• Proposed changes to the IDSC process.

7.1.1 Start of a Review Period

Each Advisory Committee review period begins with a Call for Review from the Team to the Advisory Committee. The review form describes the proposal, raises attention to deadlines, estimates when the decision will be available, and includes other practical information. Each Member organization may send one review, which must be returned by its Advisory Committee representative.

The Team must provide two channels for Advisory Committee review comments:

1 an archived Team-only channel;

2 an archived Member-only channel.

The Call for Review must specify which channel is the default for review comments on that Call.

Reviewers may send information to either or both channels. They may also share their reviews with other Members on the Advisory Committee discussion list.

A Member organization may modify its review during a review period (e.g., in light of comments from other Members).

7.1.2 After the Review Period

After the review period, the Director must announce to the Advisory Committee the level of support for the proposal. The Director must also indicate whether there were any Formal Objections. This IDSC decision is generally one of the following:

1 The proposal is approved, possibly with minor changes integrated.

2 The proposal is approved, possibly with substantive changes integrated. In this case the Director's announcement must include rationale for the decision to advance the document despite the proposal for a substantive change.

3 The proposal is returned for additional work, with a request to the initiator to formally address certain issues.

4 The proposal is rejected.

This document does not specify time intervals between the end of an Advisory Committee review period and the IDSC decision. This is to ensure that the Members and Team have sufficient time to consider comments gathered during the review. The Advisory Committee should not expect an announcement sooner than two weeks after the end of a Proposed Recommendation review period. If, after three weeks, the Director has not announced the outcome, the Director should provide the Advisory Committee with an update.

7.2 Appeal by Advisory Committee Representatives

Advisory Committee representatives may appeal certain decisions, though appeals are only expected to occur in extraordinary circumstances.

When Advisory Committee review immediately precedes a decision, Advisory Committee representatives may only appeal when there is dissent. In all cases, an appeal must be initiated within three weeks of the decision.

An Advisory Committee representative initiates an appeal by sending a request to the Team. The Team must announce the appeal process to the Advisory Committee and provide an address for comments from Advisory Committee representatives. The archive of these comments must be Member-visible. If, within one week of the Team's announcement, 5% or more of the Advisory Committee support the appeal request, the Team must organize an appeal vote asking the Advisory Committee to approve or reject the decision. Voting procedure to be determined

7.3 Advisory Committee Votes

The Advisory Committee votes in elections for seats on the TAG or Advisory Board, and in the event of a formal appeal of a IDSC decision. Whenever the Advisory Committee votes, each Member has one vote. In the case of Advisory Board and TAG elections, "one vote" means "one vote per available seat".

8. LIAISONS

IDSC uses the term "liaison" to refer to coordination of activities with a variety of organizations, through a number of mechanisms ranging from very informal (e.g., an individual from another organization participates in a Working Group, or just follows its work) to mutual membership, to even more formal agreements. Liaisons are not meant to substitute for IDSC membership.

All liaisons must be coordinated by the Team due to requirements for public communication; patent, copyright, and other IPR policies; confidentiality agreements; and mutual membership agreements.

The IDSC Director may negotiate and sign a Memorandum of Understanding (MoU) with another organization. Before signing the MoU, the Team must inform the Advisory Committee of the intent to sign and make the MoU available for Advisory Committee review; the Advisory Committee may appeal. Once approved, a Memorandum of Understanding should be made public.

9. MEMBER SUBMISSION PROCESS

The Member Submission process allows Members to propose recommendations or other ideas for consideration by the Team. After review, the Team may publish the material at the IDSC Web site. The formal process affords Members a record of their contribution and gives them a mechanism for disclosing the details of the transaction with the Team (including IPR claims). The Team also publishes review comments on the Submitted materials for IDSC Members, the public, and the media.

A Member Submission consists of:

• One or more documents developed outside of the IDSC process, and

• Information about the documents, provided by the Submitter.

One or more Members (called the "Submitter(s)") may participate in a Member Submission. Only IDSC Members may be listed as Submitter(s).

The Submission process consists of the following steps:

1 One of the Submitter(s) sends a request to the Team to acknowledge the Submission request. The Team and Submitter(s) communicate to ensure that the Member Submission is complete.

2 After Team review, the Director must either acknowledge or reject the Submission request.

◦ If acknowledged, the Team must publish the Member Submission at the public IDSC Web site, in addition to Team comments about the Member Submission.

◦ If rejected, the Submitter(s) may appeal to either the TAG or the Advisory Board.

Note: To avoid confusion about the Member Submission process, please note that:

• Documents in a Member Submission are developed outside of W3C. These documents are not part of the technical report development process. Members wishing to have documents developed outside of IDSC published by IDSC must follow the Member Submission process.

• The Submission process is not a means by which Members ask for "ratification" of these documents as IDSC Recommendations.

• There is no requirement or guarantee that recommendations which is part of an acknowledged Submission request will receive further consideration by IDSC (e.g., by a IDSC Working Group).

Publication of a Member Submission by IDSC does not imply endorsement by IDSC, including the IDSC Team or Members. The acknowledgment of a Submission request does not imply that any action will be taken by IDSC. It merely records publicly that the Submission request has been made by the Submitter. A Member Submission published by IDSC must not be referred to as "work in progress" of the IDSC.

10.1 Submitter Rights and Obligations

When more than one Member jointly participates in a Submission request, only one Member formally sends in the request. That Member must copy each of the Advisory Committee representatives of the other participating Members, and each of those Advisory Committee representatives must confirm (by email to the Team) their participation in the Submission request.

At any time prior to acknowledgment, any Submitter may withdraw support for a Submission request. A Submission request is "withdrawn" when no Submitter(s) support it. The Team must not make statements about withdrawn Submission requests.

Prior to acknowledgment, the Submitter(s) must not, under any circumstances, refer to a document as "submitted to the Investment Data Standards Consortium" or "under consideration by IDSC" or any similar phrase either in public or Member communication. The Submitter(s) must not imply in public or Member communication that IDSC is working (with the Submitter(s)) on the material in the Member Submission. The Submitter(s) may publish the documents in the Member Submission prior to acknowledgment (without reference to the Submission request).

After acknowledgment, the Submitter(s) must not, under any circumstances, imply IDSC investment in the Member Submission until, and unless, the material has been adopted as a deliverable of a IDSC Working Group

10.1.1 Scope of Member Submissions

When a technology overlaps in scope with the work of a chartered Working Group, Members should participate in the Working Group and contribute the technology to the group's process rather than seek publication through the Member Submission process. The Working Group may incorporate the contributed technology into its deliverables. If the Working Group does not incorporate the technology, it should not publish the contributed documents as Working Group Notes since Working Group Notes represent group output, not input to the group.

On the other hand, while IDSC is in the early stages of developing a charter, Members should use the Submission process to build consensus around concrete proposals for new work.

Members should not submit materials covering topics well outside the scope of IDSC’s mission.

10.1.2 Information Required in a Submission Request

The Submitter(s) and any other authors of the submitted material must agree that, if the request is acknowledged, the documents in the Member Submission will be subject to the IDSC Document License and will include a reference to it. The Submitter(s) may hold the copyright for the documents in a Member Submission.

The Submitter(s) must include the following information:

• The list of all submitting Members.

• Position statements from all submitting Members (gathered by the Submitter). All position statements must appear in a separate document.

• Complete electronic copies of any documents submitted for consideration (e.g., a technical specification, a position paper, etc.) Submitters may hold the copyright for the material contained in these documents, but when published by IDSC, these documents must be subject to the provisions of the IDSC Document License.

The request must also answer the following questions.

• What proprietary technology is required to implement the areas addressed by the request, and what terms are associated with its use? Again, many answers are possible, but the specific answer will affect the Team's decision.

• What resources, if any, does the Submitter intend to make available if the IDSC acknowledges the Submission request and takes action on it?

• What action would the Submitter like IDSC to take if the Submission request is acknowledged?

• What mechanisms are there to make changes to the specification being submitted? This includes, but is not limited to, stating where change control will reside if the request is acknowledged.

10.2 Team Rights and Obligations

Although they are not technical reports, the documents in a Member Submission must fulfill the requirements established by the Team. The Team sends a validation notice to the Submitter(s) once the Team has reviewed a Submission request and judged it complete and correct.

Prior to a decision, the request is Team-only, and the Team must hold it in the strictest confidentiality. In particular, the Team must not comment to the media about the Submission request.

10.3 Acknowledgment of a Submission Request

The Director acknowledges a Submission request by sending an announcement to the Advisory Committee. This announcement may be made at any time. The Team must keep the Submitter(s) informed of when an announcement is likely to be made.

Once a Submission request has been acknowledged, the Team must:

• Publish the Member Submission.

• Publish Team comments about the Submission request.

If the Submitter(s) wishes to modify a document published as the result of acknowledgment, the Submitter(s) must start the Submission process from the beginning, even just to correct editorial changes.

10.4 Rejection of a Submission Request

The Director may reject a Submission request for a variety of reasons. In case of a rejection, the Team must inform the Advisory Committee representative(s) of the Submitter(s). If requested by the Submitter(s), the Team must provide rationale to the Submitter(s) about the rejection. Other than to the Submitter(s), the Team must not make statements about why a Submission request was rejected.

The Advisory Committee representative(s) of the Submitters(s) may appeal the rejection to the TAG if the reasons are related to Web architecture, or to the Advisory Board if the request is rejected for other reasons. In this case the Team should make available its rationale for the rejection to the appropriate body. The Team will establish a process for such appeals that ensures the appropriate level of confidentiality.

11 Process Evolution

The IDSC Process Document undergoes similar consensus-building processes as technical reports, with the Advisory Board acting as the sponsoring Working Group.

The Advisory Board initiates review of a Process Document as follows:

1 The Team sends a Call for Review to the Advisory Committee and other IDSC groups.

2 After comments have been formally addressed and the document possibly modified, the Team seeks endorsement from the Members by initiating an Advisory Committee review of a Proposed Process Document. The review period must last at least four weeks.

3 After the Advisory Committee review, if there is consensus, the Team enacts the new process officially by announcing the IDSC decision to the Advisory Committee. If there was dissent, Advisory Committee representatives may appeal the decision.

IDSC may also modify a Process Document by following the processes for modifying a Recommendation.

Reviews of the Process Document are not public reviews.

11 PROCESS EVOLUTION