Representa implementation guide

1. What is the Implementation Guide?

The Implementation Guide for the Representa project is a document for users of the service, intended to facilitate the implementation and commissioning , within your organization, of the electronic registry of powers of attorney in compliance with the provisions of Law 39/2015, of October 1, on the common administrative procedure of public administrations and Royal Decree 203/2021, of March 30, which approves the regulation of action and operation of the public sector by electronic means.

This Guide makes a series of recommendations for each of the following actions:

• What is an electronic power of attorney register?
• The discharge from the service.
• Parameterize Representa.
• Aspects related to files, procedures and forms.
• Integrations.
• Staff training.
• Regulation.
• Service operation.
• Diffusion.

It is drawn up based on practical experiences of various Catalan public administrations, and contains technical, organizational and procedural issues. You also have access to the Support portal for more information on other service issues.

2. What is an electronic power of attorney register?

The Electronic Registry of Powers of Attorney, created by Law 39/2015, of 1 October (art.6), allows the registration of the representations that citizens, professionals and companies grant to third parties to act on their behalf before Public Administrations. The Representa is an electronic registry of powers of attorney common to all entities using the service (more information: What is Representa and what does it do? ).

The Representa is only one of the different valid ways in law to prove that a person is a representative of another (art.5 Law 39/2015, of October 1) (more information: What is and what does the Representa do? section “Is registration mandatory in order to prove representation?”).

The Representa service presents two environments, in addition to the possibility of integration via webservice:

• Public employee portal: through the EACAT for:
  • Manage representations on behalf of citizens (registrations, cancellations and acceptances).
  • Consult representations in an administrative procedure.
• Citizens' portal: through a personalized URL for each entity, for the management of representations by citizens and companies. In relation to subjects obliged to interact electronically with the administration, they must use this channel. (More information: How is a representation created? section “Do companies have to manage representations electronically”?.

What is not the Representa?

• It is not a register of authorized civil servants. (More information: What is Representa and what does it do? section “Is it necessary to register the representation of an authorized civil servant in Representa?”).
• It is not an administrative record. (More information: What is Representa and what does it do? section “Is the Representa service an administrative record?”).
• It is not a register of associations. (More information: What is Representa and what does it do? section “Does Representa allow the incorporation of representations collected in registers of municipal associations?”).

Informative tips for the tool:

• • Decalogue of the Representa: 10 ideas to get to know the service
  • Representations and capacities. (More information: What is a representation? section “Types of powers of attorney”).
  • What states do representations have? (More information: What is a representation? section “What are the possible states of a representation”).
  • Is it integrated with Apodera, the Commercial and Property Registry? (More information: What is Representa and what does it do? section “Is it integrated with Apodera, the Commercial and Property Registry?”).

3. Steps to register for the service

See Let's get started with Representa section “How can I request the Representa service?” to register.

To fill out the registration form, decide :

• • 1. Which catalog will you use :
       • Own catalog: you will have to parameterize it according to section 3 . How to parameterize REPRESENTA .
       • Generic catalog of Representa that is offered by default from the service. (More information: How can I manage the catalog of procedures? section “Catalog of procedures”).
    2. The method of using the service :
       • Direct users.
       • Integration with own systems , as indicated in section 5. Integrations .

Please note that submitting the form via EACAT implies:

• • 1. Acceptance of the Consortium's General Conditions for the provision of services AOC (in most cases it will already be approved for the use of other services) and of the Specific Conditions of the service Representa .
    2. The approval of the Co-responsibility Agreement for the processing of personal data. More information: We begin with the Representa section “Co-responsibility Agreement”.

It is recommended that the competent body of your country approves the creation of the Register of Qualified Officials and, if applicable, the corresponding regulation: the people who will act as managers of the service and carry out processing handled from REPRESENTA must have this role (as indicated in section 3. How to configure REPRESENTA ).

You can use the EACAT Skilled Officials Registration module , available to all users in the “ my entity ” section (no need to request registration). There is also the possibility of integration .

In the future, REPRESENTA will be integrated with the RFH and processing will only be allowed for users who are verified to be registered with the RFH.

4. How to configure Representa

Once you have been notified that the registration has been completed correctly, and before starting to use the service, configure Representa (more information: Let's start with Representa in the “First steps with Representa” section).

You will need to provide the following information necessary for it to function:

1. 1. 1. Entity data : configure your entity data, which allows the service documentation to be automatically filled in. This task can be performed by the service administrator, who encompasses all the functionalities. (More information: Let's start with the Representa section “Entity data configuration”).
      2. Procedure data : if you opt for the generic catalogue offered by the service, no action is required ; however, if you opt for your own procedure catalogue, you must personalise it and upload it to the service (you can upload the entire catalogue and then partially modify procedures and/or families). (More information: How can I manage the procedure catalogue? section “Add families and procedures to the procedure catalogue via file”).
         It is currently possible to have your own catalogue, the trend for the service will be the use of a single catalogue.
         This task can be performed by:
         • • Service Administrator: includes all roles
           • Entity administrator: allows you to manage your own catalog.
      3. User roles: the EACAT user manager of your entity must assign the roles to the users of the service (validator, manager, consultant, entity administrator and service administrator). (More information: Let's start with Representa in the “First steps with Representa” section).
         It is advisable to provide the role with broader functionalities than is needed and that the people who will carry out the processing attended to (it is not necessary for authentic copies, which can be with an organ seal), must have the relevant authorization.
      4. Seu-e: incorporate the link to the citizenship portal, which is provided to you at the time of registration, into your electronic headquarters, to promote and disseminate the electronic management of representations. Consult the list of entities registered with the service, and the data relating to the protection of personal data. (More information: Let's start with the Representa section “Entities registered with Representa”).

5. Aspects related to files, procedures and forms

The implementation of Representa may involve the modification of the flows of files, procedures and forms to include the consultation of representations that may be registered with the service. For this reason:

• • • Identify the affected procedures , those that are likely to be formulated by a person representing a third party.
    • Analyze the variables and requirements to be incorporated into the files, procedures and/or forms and templates associated with the files and procedures. It is important to define the new needs and variables to be incorporated. In this sense, we recommend that you analyze whether or not registration in Representa is necessary (More information: What are the implications of registration in Representa? Warning model when promoting registration ).
    • If necessary, implement the appropriate modifications to the applications, forms and templates, consisting of including the fields related to the representations, to facilitate the settlement numbers, etc.

This process may result in the need to establish specific forms to grant representations and powers of attorney (you have at your disposal the models offered by default by the service in How do you create a representation? section “ Obtain document templates ”).

6. Integrations

If you opt for integration, evaluate the integration of Representa functionalities into your case manager and other electronic administration services where representation is relevant. This involves analyzing the requirements for the integration and, depending on the result of this analysis, implementing it. It is important that you read the integration documentation and analyze the different consumption modalities provided (REPRESENT_VALIDATION / REPRESENT_QUERY / REPRESENT_MODIFICATION / REPRESENT_UPGRADE).

You must determine which consumption methods you will use (management of registrations and/or consultation of representations in the database) and provide the relevant information to AOC , as it will be used automatically from the service.

The next step is to start the technical integration tasks.

If in the application you asked us to use the service via EACAT but at some point, you decide to consume it through integration, in any of its consumption modalities, you only have to request it through the usual channels .

You can find more information about support for integrators on the service's website.

7. Testing and staff training

It is recommended that , after carrying out the previous actions, you test the correct operation of the service before putting it into operation.

You can test the functionalities through a pilot , selecting groups likely to be frequent users of the service or a procedure (or family of procedures) that can generate a high volume of registrations and subsequent actions by proxies or representatives.

It is also advisable to develop and execute a Training Plan for the organization's personnel who will use the service. To do this:

• • • Determine the groups to form .
    • Review the materials on the Representa Support Portal .
    • Take the Representa virtual course
    • Sign up for AOC training (if you consider it appropriate)
    • Develop your own training materials (if applicable), both regarding the operation of the service and practical aspects (more information, in section 9. Service operations ).
    • Determine the training schedule (if applicable), without prejudice to other sessions that may be organized.

8. Regulation

If you have a general provision that develops the provisions of Law 39/2015, of October 1 (for example, a General Ordinance on electronic administration), analyze whether it is necessary to modify it, or not, to include issues related to the electronic registration of powers of attorney.

If you do not have one, assess whether some aspects of the electronic registration of powers of attorney may be subject to specific regulation.

If you are a user of Representa, take into account the technical aspects of the service that may be related to this regulation (for example, the necessary acceptance of representation) and evaluate the adaptation.

Decree 76/2020, of August 4, on Digital Administration , regarding the Administration of the Generalitat of Catalonia, or the Standard Electronic Administration Ordinance prepared by LOCALRET, for local entities, are 2 examples of provisions that develop the provisions relating to the electronic registration of powers of attorney in the respective areas.

9. What should I keep in mind when using the service?

• • • Registration/cancellation/acceptance management:
      • Tasks to be faced by the OAMR with the role of Manager (which also includes the functions of the consultant).
      • The OAMR must mandatorily assist citizens and other non-obligated subjects in the management of registrations, terminations and acceptances through the public employee portal or the entity's personalized portal, therefore, the assigned personnel must have the necessary roles and the relevant training both on the tool itself and on the procedure to be followed.
      • OAMRs should also be able to make authentic copies of paper documents, even in the case of subjects obliged to the electronic relationship. More information: How is a representation that requires review of the documentation validated? section “Documentation to attach to a representation”.
      • Registrations must always be accepted or validated, therefore, a registration is never registered directly.
        • Acceptance: by the representative. More information: How are representations managed in “Pending acceptance”? section “How to manage a request for acceptance by a representative?”.
        • Validation: by the validator (when there is attached documentation to validate). More information: How do you validate a representation that requires documentation review?? section “Which representations need to be validated”?.
      • Assisted processing is a mechanism to assist interested parties that can also be used to request ex officio representations.
      • The representative certificate is a mechanism for accrediting the representation, therefore, registration of the representation in the Representa is not necessary.
    • Validation of representations with attached documentation to be validated:
      • Those representations that are in Pending Validation status must be reviewed and validated or denied by the Validador role (which also contains the functions of the Consultant role)
      • The validator role must be assigned to people with a legal profile who can analyze the supporting documentation and issue the validation report. More information: How do you validate a representation that requires a review of the documentation? section “Which representations must be validated?”.
      • Given that Representa is a collaborative registry, the validation report issued by a user entity is used by the rest of the users of the service. More information: How is a representation that requires documentation review validated? section “Who validates representations made when they require validation?”.
    • Consultation of representations:
      • It is the verification of whether there is a valid representation between two people (natural and/or legal entities) to carry out a specific procedure on a specific date.
      • The query can be performed automatically via integration or manually, from the consulting user.
      • It allows you to obtain evidence in xml of the existence of this representation, and shortly, evidence in pdf, which the entity must download and save in the corresponding administrative file. More information: How can I make representations inquiries?

When you launch the service, you can advertise it on your website, newsletters, organize dissemination days, etc., for example, to groups of large users and within procedures likely to generate registrations (the same assumptions as the pilot in section 7. Testing and staff training ).

It is also recommended that you enable assistance points, spaces set up to help interested parties when they want to register for performances.

In case it is of any help, the AOC support portal has a support section for citizens and it is recommended that it be disseminated among citizens.

For more information about Representa, please see the service's support portal .