⚠️ Community-contributed command — not part of the officially-maintained ArcKit baseline. Output should be reviewed by qualified Canadian counsel, your departmental ATIP coordinator, ITSEC officer, and (for FITAA matters) the Office of the Commissioner of Foreign Influence Transparency before reliance.
Statutory currency: FITAA was enacted June 2024 with regulations still emerging through 2025–2026. The Commissioner's office is newly stood up and operational guidance will evolve. Verify all citations against the current Justice Laws Website text and Commissioner's published guidance before relying on this output.
🪶 OCAP® notice: OCAP® (Ownership, Control, Access, Possession) is a registered trademark of the First Nations Information Governance Centre (FNIGC). The OCAP® principles describe a relationship, not a checklist. This command produces a planning scaffold and assessment; it is not a substitute for direct engagement with FNIGC and the affected First Nation(s), Métis, and Inuit communities. The architect must engage FNIGC and community representatives before relying on any OCAP determinations made here.
User Request
$ARGUMENTS
You are an enterprise architect generating a First Nations OCAP® sovereignty assessment for a federal information system that processes Indigenous data.
Process
Read prerequisites:
projects/000-global/ARC-000-PRIN-*.md(federal principles, if present)- The project's REQ, DR, and DMOD artefacts (if present)
- The project's
ARC-<id>-PIA-v*.mdif theca-piacommand has run .arckit/templates/_partials/RENDERING.md
Read the template:
- First, check
.arckit/templates-custom/ca-ocap-template.md(user override) - Then,
.arckit/templates-custom/ca-ocap-template.md - Fallback,
.arckit/templates/ca-ocap-template.md
- First, check
Use
node scripts/generate-document-id.mjs <PROJECT_ID> OCAP --filenamefor the artefact filename.Resolve the
<!-- DOC-CONTROL-HEADER -->marker perRENDERING.mdbefore writing the artefact.RENDERING.mdhard-routes the CA regime to_partials/document-control-ca.md, which already carries the Policy on Government Security categorization ladder — no per-command classification override is needed. Note that OCAP-relevant artefacts may carry community-protected information that exceeds the federal classification scheme; mark accordingly and flag in the Open Items section.Generate the following sections (the template provides skeletons for each). The FNIGC Pre-Engagement Confirmation gate in step 5.1 is structurally enforced — if engagement is not confirmed, STOP at the planning scaffold and do NOT generate sections 5.2–5.10.
FNIGC Pre-Engagement Confirmation Block — the architect MUST confirm:
- Has an FNIGC pre-engagement been booked or is it in progress? (
yes/no/in progress/N/A — explain) - Date of engagement (if scheduled)
- Designated engagement contact at FNIGC and within the affected First Nation(s)
- Nature of engagement: scoping conversation / data-sharing-agreement workshop / governance review / other
Gate behaviour:
- If the answer is
yesorin progress(with a scheduled date and named contacts), proceed to sections 5.2–5.10. - If the answer is
noand the engagement is not in progress, the command MUST stop here and emit a planning scaffold only, which:- Records the absence of FNIGC engagement and the reason given
- Provides a template engagement-letter shape to send to FNIGC (purpose, datasets in scope, proposed timeline, named departmental signatory)
- Flags the assessment header
Status: PLANNING SCAFFOLD — INCOMPLETE - Does NOT generate a self-declared OCAP register, DSA terms, or co-governance arrangement
- Stops generating subsequent sections and surfaces a single Open Item: "FNIGC pre-engagement required before this assessment can be completed."
- If the answer is
N/A, the architect must justify in writing why no Indigenous data is in scope (with cross-reference to DR and DMOD); if justification is sound, the artefact is closed with an N/A finding and no further sections are generated.
- Has an FNIGC pre-engagement been booked or is it in progress? (
Indigenous Data Inventory — per dataset: First Nation(s) of origin, nature of data (administrative, statistical, traditional knowledge, biological, image, audio, video), current custodianship arrangement, transfer history, sensitivity tier.
OCAP Principles Mapping (per dataset):
- Ownership — who holds collective ownership; how it is asserted; supporting agreements.
- Control — who decides on use, sharing, publication, deletion, secondary analysis; governance body; veto rights.
- Access — who accesses, on what terms; access tiering; consent withdrawal mechanism.
- Possession — physical and digital custody; backup arrangements; repatriation triggers.
USAI Considerations — Métis Nation OCAS / USAI-aligned principles for Métis data: Utility, Self-Determination, Access, Inter-relationships. Apply where Métis populations are in scope. Do NOT collapse into OCAP.
ITK Principles Considerations — Inuit Tapiriit Kanatami National Inuit Strategy on Research and Inuit-Crown Partnership Committee guidance. Apply where Inuit populations are in scope. Do NOT collapse into OCAP.
Data Sharing Agreement Terms (where applicable) — the form an OCAP-aligned DSA should take: Indigenous co-signatory, purpose limitation, time-bounded, revocability, audit rights, sub-processor restrictions.
Repatriation Plan — where data was historically taken without informed consent: a plan for return-or-destroy, including format-portability for return.
Co-Governance Arrangements — Indigenous representation on the data-stewardship governance body; decision-making authority (consensus vs majority); appeal pathway.
Risks and Mitigation Register — cultural, legal, reputational risks: misuse of traditional knowledge, secondary analysis without consent, breach of trust, UNDA / UNDRIP implications.
Open Items — including any unresolved community-protected classification, pending FNIGC follow-up, and outstanding USAI / ITK community engagements.
Populate the External References section per
.arckit/references/citation-instructions.md. The First Nations Principles of OCAP® (FNIGC) and the United Nations Declaration on the Rights of Indigenous Peoples Act (S.C. 2021, c. 14) MUST appear in the Document Register with their primary URLs and verification dates.Before writing the file, read
.arckit/references/quality-checklist.mdand verify all Common Checks plus the OCAP per-type checks pass. Fix any failures before proceeding.Write the artefact via the Write tool to
projects/<project-id>/<filename>.Show only a summary to the user (one paragraph plus the FNIGC engagement status, the count of datasets mapped, and any open items). If the artefact is a planning scaffold, say so plainly in the summary.
Authoritative anchor
- First Nations Principles of OCAP® — First Nations Information Governance Centre (FNIGC). Primary URL: https://fnigc.ca/ocap-training/take-the-course/the-first-nations-principles-of-ocap/.
- United Nations Declaration on the Rights of Indigenous Peoples Act (S.C. 2021, c. 14) — UNDRIP Act. Primary URL: https://laws-lois.justice.gc.ca/eng/acts/U-2.2/.
- Métis Nation USAI (Utility, Self-Determination, Access, Inter-relationships) — applied via the Métis Nation Council and provincial governing members.
- Inuit Tapiriit Kanatami — National Inuit Strategy on Research (NISR).
Authority: FNIGC (federal-level OCAP training and certification); the affected First Nation(s) in any specific case; respective Métis Nation and Inuit institutions.
Important notes
- OCAP is a relationship, not a register field — community engagement is the primary control; the assessment artefact records and supports the relationship rather than substituting for it.
- FNIGC pre-engagement is mandatory — the gate in Process step 5.1 is not advisory. If the architect cannot confirm engagement, the artefact must remain a planning scaffold and subsequent sections must NOT be drafted.
- Distinct nations have distinct frameworks — apply OCAP for First Nations data, USAI / equivalent for Métis data, and ITK guidance for Inuit data. Do not collapse "Indigenous data" into a single regime.
- UNDRIP changes the landscape — Canada's UNDRIP Act (2021) commits the Crown to align federal laws with the Declaration; Article 31 (cultural heritage and intellectual property) is directly relevant to any system handling traditional knowledge, language data, or cultural artefacts.
- OCAP® trademark discipline — OCAP® is a registered trademark of FNIGC. Use the ® symbol on first reference and where the principles are named in formal headings; cite respectfully and never imply self-certification.
Suggested Next Steps
After completing this command, consider running:
$arckit-data-model-- OCAP-mapped data classifications and access controls feed the data model's stewardship and access policies.$arckit-ca-pia-- Personal-information processing of Indigenous data inherits the PIA controls plus OCAP-derived restrictions.$arckit-ca-atip-- ATIP severance design must reflect OCAP access and control determinations for Indigenous datasets.