[osdcmy] Fwd: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers

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[osdcmy] Fwd: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers

Raja Iskandar Shah
Salam hormat

Berikut apa yg saya dapat utarakan berkaitan Computing Professional Act yang akan melibatkan Koperasi.

Ini adalah perkara-perkara khusus bagi Koperasi yang berfungsi sebagai 'a member based organisation'.

Kalau ada yg lain, masih boleh dikemukakan terus kepada Mosti sebelum 15 Jan 2012.



---------- Forwarded message ----------
From: Raja Iskandar Shah <[hidden email]>
Date: Mon, Jan 9, 2012 at 1:04 PM
Subject: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers
To: [hidden email]


Salam hormat

As a representative of the Koperasi Sumber Terbuka Selangor Berhad (Dalam Penubuhan), we would like to seek further clarification on the following matters contained in the draft of the Computing Professionals Act 2011 (as downloaded today from http://www.mosti.gov.my/mosti/index.php?option=com_content&task=view&id=3677&Itemid=5 )

  1. Critical National Information Infrastructure (CNII)
    1. References: Para 2.(2), 3, 34
    2. Commentary: Would the scope of CNII, also include govt funded / sponsored community programs ? We have members who are actively involved in the use of OSS, for enhancing computer literacy for the underprivilieged (such as Tamil Schools). The tutors are part-time volunteers. If the Act is passed, would such volunteer groups be (1) denied to do such community work at public sector institutions (such as schools, colleges, universities) ?, and (2) also denied against seeking funding for community work from any govt agencies (computer literacy for single mothers) ? Para 34 would imply that CNII are entities, such as whole agencies, rather than projects / programs.
    3. Recommendation: Clarity on the extent of CNII is required where it involves community service programs.
  2. Computing Services by Subject Matter Experts (eg accountants, educators, econometricians, statisticians)
    1. References: Para 2.(2)
    2. Commentary: The definition of computing services includes "use and manage of information technology" which is too broad a scope, as it would also encompass subject matter experts, and other cross-domain specialists, particularly for expert systems (eg economist intelligence system, or even google analytics). Other than proprietary databases who provide commercial training, there are many more peer-based systems which do not have any formal training programs (such as World Bank's Open Data Initiative, the US Government Open Government Initiative).
    3. Recommendation: that the definition excludes "use and manage"
  3. Computing Services by Community on Govt OSS Projects / Products
    1. References: Para 2.(2), 34
    2. Commentary: Para 34 explicitly prevents govt agencies from engaging the OSS community to provide fixes / patches to software that are implemented in CNII projects / programs. This would even extend to automated software fixes subscriptions from software vendors (such as Oracle)
    3. Recommendation: Further clarification is required. 
  4. Computing Services Provider: Change of shareholders
    1. References: Para 15.(3)
    2. Commentary: Clarification is sought whether the Act would allow for Cooperatives (registered under Suruhanjaya Koperasi Malaysia) to provide computing services. Also as Cooperatives are public entities (Berhad), where members of the public can become shareholders at any point of time, it would not be feasible to comply to 15.(3)
    3. Recommendation: That the requirement for the notice of change of shareholder, be exempted for public companies, that the register of shareholders is submitted only on an annual basis.

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Re: [osdcmy] Fwd: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers

Abu Mansur

Ok jazakallah :-)

On Jan 9, 2012 1:18 PM, "Raja Iskandar Shah" <[hidden email]> wrote:
Salam hormat

Berikut apa yg saya dapat utarakan berkaitan Computing Professional Act yang akan melibatkan Koperasi.

Ini adalah perkara-perkara khusus bagi Koperasi yang berfungsi sebagai 'a member based organisation'.

Kalau ada yg lain, masih boleh dikemukakan terus kepada Mosti sebelum 15 Jan 2012.



---------- Forwarded message ----------
From: Raja Iskandar Shah <[hidden email]>
Date: Mon, Jan 9, 2012 at 1:04 PM
Subject: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers
To: [hidden email]


Salam hormat

As a representative of the Koperasi Sumber Terbuka Selangor Berhad (Dalam Penubuhan), we would like to seek further clarification on the following matters contained in the draft of the Computing Professionals Act 2011 (as downloaded today from http://www.mosti.gov.my/mosti/index.php?option=com_content&task=view&id=3677&Itemid=5 )

  1. Critical National Information Infrastructure (CNII)
    1. References: Para 2.(2), 3, 34
    2. Commentary: Would the scope of CNII, also include govt funded / sponsored community programs ? We have members who are actively involved in the use of OSS, for enhancing computer literacy for the underprivilieged (such as Tamil Schools). The tutors are part-time volunteers. If the Act is passed, would such volunteer groups be (1) denied to do such community work at public sector institutions (such as schools, colleges, universities) ?, and (2) also denied against seeking funding for community work from any govt agencies (computer literacy for single mothers) ? Para 34 would imply that CNII are entities, such as whole agencies, rather than projects / programs.
    3. Recommendation: Clarity on the extent of CNII is required where it involves community service programs.
  2. Computing Services by Subject Matter Experts (eg accountants, educators, econometricians, statisticians)
    1. References: Para 2.(2)
    2. Commentary: The definition of computing services includes "use and manage of information technology" which is too broad a scope, as it would also encompass subject matter experts, and other cross-domain specialists, particularly for expert systems (eg economist intelligence system, or even google analytics). Other than proprietary databases who provide commercial training, there are many more peer-based systems which do not have any formal training programs (such as World Bank's Open Data Initiative, the US Government Open Government Initiative).
    3. Recommendation: that the definition excludes "use and manage"
  3. Computing Services by Community on Govt OSS Projects / Products
    1. References: Para 2.(2), 34
    2. Commentary: Para 34 explicitly prevents govt agencies from engaging the OSS community to provide fixes / patches to software that are implemented in CNII projects / programs. This would even extend to automated software fixes subscriptions from software vendors (such as Oracle)
    3. Recommendation: Further clarification is required. 
  4. Computing Services Provider: Change of shareholders
    1. References: Para 15.(3)
    2. Commentary: Clarification is sought whether the Act would allow for Cooperatives (registered under Suruhanjaya Koperasi Malaysia) to provide computing services. Also as Cooperatives are public entities (Berhad), where members of the public can become shareholders at any point of time, it would not be feasible to comply to 15.(3)
    3. Recommendation: That the requirement for the notice of change of shareholder, be exempted for public companies, that the register of shareholders is submitted only on an annual basis.

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Re: [osdcmy] Fwd: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers

Mohamad Imran
+1

Ku tak tau apa lagi mahu tambah.

2012/1/9 Abu Mansur <[hidden email]>

Ok jazakallah :-)

On Jan 9, 2012 1:18 PM, "Raja Iskandar Shah" <[hidden email]> wrote:
Salam hormat

Berikut apa yg saya dapat utarakan berkaitan Computing Professional Act yang akan melibatkan Koperasi.

Ini adalah perkara-perkara khusus bagi Koperasi yang berfungsi sebagai 'a member based organisation'.

Kalau ada yg lain, masih boleh dikemukakan terus kepada Mosti sebelum 15 Jan 2012.



---------- Forwarded message ----------
From: Raja Iskandar Shah <[hidden email]>
Date: Mon, Jan 9, 2012 at 1:04 PM
Subject: Comment on Draft BCPM: Further Clarification is Required on Computing Services Providers
To: [hidden email]


Salam hormat

As a representative of the Koperasi Sumber Terbuka Selangor Berhad (Dalam Penubuhan), we would like to seek further clarification on the following matters contained in the draft of the Computing Professionals Act 2011 (as downloaded today from http://www.mosti.gov.my/mosti/index.php?option=com_content&task=view&id=3677&Itemid=5 )

  1. Critical National Information Infrastructure (CNII)
    1. References: Para 2.(2), 3, 34
    2. Commentary: Would the scope of CNII, also include govt funded / sponsored community programs ? We have members who are actively involved in the use of OSS, for enhancing computer literacy for the underprivilieged (such as Tamil Schools). The tutors are part-time volunteers. If the Act is passed, would such volunteer groups be (1) denied to do such community work at public sector institutions (such as schools, colleges, universities) ?, and (2) also denied against seeking funding for community work from any govt agencies (computer literacy for single mothers) ? Para 34 would imply that CNII are entities, such as whole agencies, rather than projects / programs.
    3. Recommendation: Clarity on the extent of CNII is required where it involves community service programs.
  2. Computing Services by Subject Matter Experts (eg accountants, educators, econometricians, statisticians)
    1. References: Para 2.(2)
    2. Commentary: The definition of computing services includes "use and manage of information technology" which is too broad a scope, as it would also encompass subject matter experts, and other cross-domain specialists, particularly for expert systems (eg economist intelligence system, or even google analytics). Other than proprietary databases who provide commercial training, there are many more peer-based systems which do not have any formal training programs (such as World Bank's Open Data Initiative, the US Government Open Government Initiative).
    3. Recommendation: that the definition excludes "use and manage"
  3. Computing Services by Community on Govt OSS Projects / Products
    1. References: Para 2.(2), 34
    2. Commentary: Para 34 explicitly prevents govt agencies from engaging the OSS community to provide fixes / patches to software that are implemented in CNII projects / programs. This would even extend to automated software fixes subscriptions from software vendors (such as Oracle)
    3. Recommendation: Further clarification is required. 
  4. Computing Services Provider: Change of shareholders
    1. References: Para 15.(3)
    2. Commentary: Clarification is sought whether the Act would allow for Cooperatives (registered under Suruhanjaya Koperasi Malaysia) to provide computing services. Also as Cooperatives are public entities (Berhad), where members of the public can become shareholders at any point of time, it would not be feasible to comply to 15.(3)
    3. Recommendation: That the requirement for the notice of change of shareholder, be exempted for public companies, that the register of shareholders is submitted only on an annual basis.

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