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A public consultation exercise on the proposal for a unique identification number for establishments in Singapore, also known as Unique Establishment Identifier (UEI), was held from 3
December 2005 to 13 January 2006.
Establishments that may be issued with a UEI include sole proprietorships, partnerships, limited liability partnerships, companies, firms, or any bodies of persons (such as representative offices, charities, clubs, associations, societies, non-profit organisations etc) registered or licensed by a public agency in Singapore.
2. Having a UEI for establishments in Singapore will make it simpler, faster and easier for the establishments to interact with government agencies. Basic non-confidential information on establishments can also be shared more effectively across public sector agencies to enable the delivery of efficient and customised services.
The consultation paper on Unique Establishment Identifier (UEI) may
be downloaded here.
3. A total of 67 feedback were received. 4 were from individuals while 63 were from organisations. We would like to thank all who have given us their feedback.
4. A summary of the key comments received, together with our responses, is shown in this table. The comments pertained to the following key areas:
- Usefulness of UEI
- Impact of UEI
- Business and privacy concerns if UEI were made publicly available
- Establishments to be issued with UEI
- Identification of sub-entities within an establishment
- Use of UEI for interactions with customers
- Changes to be made and costs to adopt UEI
- Measures to ease the transition of establishments to use UEI
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53 respondents felt that a UEI would be useful, 7 respondents opined that a UEI would be of little or no use to them, while 8 respondents were neutral to having a UEI.
The key benefits of having a UEI, as cited by respondents, included the following:
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Increase convenience and efficiency (e.g.
through time savings) by reducing the number of identifiers
that establishments have to remember and use when interacting
with public agencies.
- Facilitate and speed up interaction and verification of establishments by public agencies (e.g. reduce time taken to verify existence of company).
- Easier authentication for establishments when transacting online with the Government.
- Facilitate data sharing, increase transparency, streamline administration and operations, and improve decision making among public agencies e.g. reduce the need for establishments to repeatedly provide the same information to different agencies,
- Make it easier for businesses to conduct their operations.
Respondents who felt that UEI would be of no use or little use to them gave the following reasons:
- They were already issued with ACRA numbers which they used for the majority of their transactions with public agencies. Hence they did not see a need for another identifier to be issued to them. Some respondents suggested to adopt the ACRA number as the UEI
- A UEI alone would not reduce administrative burden. More importantly, there was a need to for public agencies to reduce bureaucracy and improve service delivery to establishments.
- They currently used internal customer reference numbers to identify their customers, thus there was no need for a UEI to facilitate their interactions with their customers.
MOF’s response:
- Some establishments such as societies, representative offices, management corporations, trade unions, professional firms are not issued with ACRA numbers today. Hence, by issuing UEI to these non-ACRA registered establishments, they will be able to enjoy the convenience that the ACRA number has brought to the ACRA-registered establishments e.g. companies and businesses today.
To minimise the cost and impact of implementing a UEI, the proposal is to use the ACRA number as the UEI for companies and businesses registered with ACRA. Hence, only non-ACRA registered establishments (e.g. societies, embassies, representative offices, trade unions, schools etc), which do not have an ACRA number, would need to be issued with a UEI.
- While UEI will facilitate information sharing among public agencies, we agree that a UEI alone will not be sufficient to enhance administrative procedures and operations within the government. There are ongoing parallel efforts by the government to continue to work on cutting bureaucracy and improve services to citizens and businesses.
- The primary purpose of the UEI is for public sector agencies to use in interacting with establishments. Private/social sector establishments may continue to use their own identification number to interact with their own customers, or switch to using UEI to interact with their customers if they think that the UEI is more expedient and convenient. In the same vein, they may use the UEI in interaction with other private sector establishments.
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Some respondents said that costs would be incurred in the short run because:
- Systems and customer databases have to be changed and upgraded
- Official stationery and documents have to be reprinted.
- Establishments have to invest time and efforts to familiarise themselves with the UEI process.
- The risk of data confidentiality, privacy and security being compromised would need to be addressed.
However, most respondents said that UEI would be beneficial in the long run to public agencies and establishments through the following ways:
- Increase coordination, efficiency and effectiveness among public agencies by minimising duplication of databases, facilitating information sharing and analysis and improving service delivery.
- Time and cost savings would be brought to establishments as interactions with public agencies would be made simpler, easier and faster.
- Better risk management and less confusion through easier identification, verification and authentication of customers which are establishments.
MOF’s response: While conversion to the UEI may incur a one-time
cost, there will be longer term continuing
benefits in using the UEI both in interactions
with government agencies as well as private
and people sector organisations. MOF will design
and execute the conversion from existing identifiers
to the UEI in such a way as to keep the cost
and inconvenience to companies and other establishments
as low as possible.
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Most respondents did not foresee business or privacy concerns if the UEI is made available publicly, as long as security measures are in place to protect confidential or sensitive information, and the consent of establishment is sought before any confidential information is disclosed. It was also suggested that an authentication system (e.g. password) should be used in conjunction with UEI to control access to confidential information.
MOF’s response: Measures will be put in place to ensure that confidential
and sensitive information is protected.
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Majority of respondents said that the proposed list of establishments to be issued with UEI in the consultation paper was sufficiently comprehensive. Establishments that need to transact commercially in Singapore ought to be issued with a UEI. There were suggestions to include banks, health-related organisations as well as groups of individuals such as families and schools.
MOF’s response: ACRA-registered establishments (which include banks)
are among the proposed list of establishments to be issued with UEI.
Health-related organisations that are registered with ACRA will also
be issued with UEI. Public agencies including schools are also among
the proposed establishments to be issued with UEIs. Public Sector agencies
will continue to use NRIC/FIN numbers in their transaction with individuals.
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21 among the 67 respondents said that there was a need for sub-entities such as branches and departments within an establishment to be issued with UEIs if these sub-entities transacted directly with public agencies. There was a suggestion for the sub-entity identifier to be appended to the establishment identifier of the parent establishment, so that the relationship of the sub-entity to its parent establishment was easily visible.
MOF’s response: The UEI is meant to identify an establishment. To
identify sub-entities (e.g. branches and divisions) within an establishment,
MOF will consider issuing separate branch and division identifiers
(likely to be 3 digits) to establishments where this is required by
the public sector agencies or on request of the private sector establishment.
The branch and division identifiers can be used together with the
UEI of the parent establishment to identify
the branches or divisions. When transacting online with public agencies,
the branch or division
of an establishment may identify itself by
quoting both its parent establishment’s UEI and its branch or division
identifier.
Private sector establishments can choose to use the UEI with the branch and division identifiers in their interaction with their customers and/or other private sector establishments.
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44 respondents said that they would likely use UEI to interact with their own customers as it would bring convenience and increase efficiency and accuracy in identifying customers.
Among the 12 respondents who said that they would not use UEI for interactions with customers, the key reasons cited included:
- They already had their own internal identification system to identify their customers and preferred to retain it for the time being.
- They had few customers at the moment. When their customer base expanded in future, they may use UEI for customer interactions.
- Preference to identify customers by name.
MOF’s response: The primary purpose of the UEI is for public sector
agencies to use in their interactions with establishments. Private/social
sector establishments can choose to continue using their own identification
number to interact with their own customers, or switch to using UEI
to interact with their customer if they think that the UEI is more
expedient and convenient. In the same vein, they may use the UEI in
interaction with other private sector establishments.
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With regard to the changes and costs required to adopt UEI, the respondents’ comments varied, depending on the type of identifiers (e.g. ACRA or CR numbers) which they currently used, as well as the nature of their interactions (e.g. whether they used manual or electronic means) with public agencies and customers. Changes required generally included reprinting of official stationery and documents, and upgrading of IT systems and customer databases.
Establishments which primarily conduct interactions manually would generally incur lower costs, in the range of $40 - $2000 to reprint official stationery and documents so as to replace the current identifier with the UEI. Establishments which use non-ACRA numbers or which function as intermediaries that transact with public sector agencies on behalf of their customers would need to make more significant system changes (in the range of tens of thousands to 2 million dollars).
MOF’s response: While conversion to the UEI may incur a one-time cost,
there will be longer term continuing benefits in using the UEI both
in interactions with government agencies as well as private and people
sector organisations. MOF will design and execute the conversion from
existing identifiers to the UEI in such a way as to keep the cost and
inconvenience to companies and other establishments as low as possible.
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Suggestions on measures, other than the provision of conversion tools, that the Government could implement to ease the transition of establishments to use the UEI included the following:
- Give sufficient time for conversion from existing identifiers to UEI. Suggested conversion time ranged from 6 months to 5 years.
- Conduct pilot/trial tests before large scale implementation.
- Create public awareness and educate the general public on the use, benefits, and implementation of UEI through training courses and seminars.
- Set up counters, one-stop helpdesk and hotline, and publish FAQs to provide assistance and answer queries during implementation phase.
- Offer a list of qualified IT consultancy companies that can help establishments with UEI implementation.
- Offer incentives (e.g. financial assistance, grants and subsidies) for conversion, especially to the smaller establishments.
- Provide a reference database or e-service that converts between existing identifiers and the UEI.
- Exercise tolerance in event of non-compliance by establishments due to miscomprehension.
MOF’s response: MOF will consider these suggestions if and when we
implement the UEI.
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