Mid-term internship report

LIST OF ABBREVIATIONS1 VCCI Vietnam Chamber Commerce and Industry 2 USAID The United States Agency for International Development 3 PCI The provincial competitiveness index 4 CDCS The USA

FOREIGN TRADE UNIVERSITY SCHOOL OF ECONOMICS AND INTERNATIONAL BUSINESS

-*** -MID-TERM INTERNSHIP REPORT

Major: International Business Economics

PROVINCIAL COMPETITIVENESS INDEX (PCI) AND RECOMMENDATIONS TO THE VCCI RECORDING TO THE PROVINCIAL COMPETITIVENESS INDEX

Full Name: Nguyen Thi Hong Ha Student ID: 1515150041

Class: English 26 – High quality program Course: 54

Instructor: MA Nguyen Huyen Minh

Hanoi, August 2018

TABLE OF CONTENTS

LIST OF ABBREVIATIONS 3

LIST OF FIGURE 4

PREFACE 5

CHAPTER 1: GENERAL ISSUES ON THE PROVINCIAL COMPETITIVENESS INDEX 7

1.1 Overview of The provincial competitiveness index (PCI) Agencies 7

1.1.1 About USAID 7

1.1.2 About VCCI 8

1.1.2.1 General information 8

1.1.2.2 History of formation 8

1.1.2.3 Functions and missions of VCCI 9

1.1.2.4 Organization structure of VCCI 12

1.2 About The provincial competitiveness index (PCI) 13

CHAPTER 2: THE COLLECTING DATA PROCESS AND ASSESSING THE QUALITY OF THE PROVINCIAL COMPETITIVENESS INDEX 15

2.1 The process of implementing the provincial competitiveness index 15

2.1.1 Indicators constituting the provincial competitiveness index 15

2.1.2 Methodology of data collection and PCI building 22

2.1.3 The actual process of implementing the provincial competitiveness index in recent years 23

2.2 The PCI collecting data process 24

2.2.1 Position in mid-term internship process at VCCI 24

2.2.2 Details of the PCI collecting data process 25

2.2.2.1 Source data 25

2.2.2.2 The process of collecting data for PCI 25

2.2.3 Response Rate 27

2.2.4 Distribution of PCI respondents 28

2.3 Assessing the quality of the provincial competitiveness index 30

2.3.1 Utility of the provincial competitiveness index 30

2.3.1.1 Advantages of the provincial competitiveness index with related parties 30

2.3.1.2 Impacts of the provincial competitiveness index with related parties 31 2.3.2 Some disadvantages of the provincial competitiveness index 33

CHAPTER 3: RECOMMENDATIONS TO VCCI RECORDING TO THE PROVINCIAL COMPETITIVENESS INDEX 36

3.1 Recommendations to improve the quality of PCI collecting data process 36 3.2 Recommendations to increase the benefits of PCI for related parties 37

3.3 The lesson learnt and personal experiences 39

REFERENCES 42

APPENDIX 44

LIST OF ABBREVIATIONS

1 VCCI Vietnam Chamber Commerce and Industry

2 USAID The United States Agency for International

Development

3 PCI The provincial competitiveness index

4 CDCS The USAID Country Development and Cooperation

Strategy

7 FIEs Foreign invest enterprises

8 PPC Proactivity and Provincial Leadership

10 GTD General Department of Taxation

11 GSO General Statistics Office of Vietnam

12 CEO Chief executive officer

13 LLC Limited liability companies

14 DDCI Initiative of District/Department level Competitiveness

Index

LIST OF FIGURE

Number of

Figure 1.1 Diagram of organizational structure of VCCI 12

Figure 2.2 The actual process of implemeting the PCI over the

Figure 2.3 Distribution of PCI respondents by sector 28Figure 2.4 Distribution of PCI Respondents by legal form, size

Figure 2.6 Graph of the number of responded enterprises year by

Many economists consider the Provincial Competitiveness Index (PCI) to be themost objective indicator of the ability of the local government to regulate the businessenvironment However, the PCI highlights the strengths and weaknesses of provincialgovernance without indicating the cause or finding a remedy Therefore, the results ofthe study only help to classify and identify provinces based on PCI, but there are nosolutions to help provinces improve this indicator.

With the knowledge of learning at school, the initial perceptions of approachingthe practice and derived from the above thinking, I decided to choose the topic

"

Provincial Competitiveness Index (PCI) and recommendations to the VCCI recording to the provincial competitiveness index " as internship report The reportconsists of three chapters:

Chapter 1: General issues on the provincial competitiveness index

Chapter 2: The colleting data process and assessing the quality of the provincial

Truong – No.1 PCI Team Leader I hope to receive the comments of teachers andfriends, so that the ideas in your topic will soon come true

CHAPTER 1: GENERAL ISSUES ON THE PROVINCIAL

efforts that support the goal of Vietnam’s continued transformation into a responsible,more inclusive partner.

During the war years, VCCI has focused on the maintenance of trade relationsbetween Vietnam and some countries and territories according to the import andexport demand of the country

After the war, VCCI expanded its operations throughout the country,establishing relations with many countries around the world, participating in theactivities of many economic organizations In 1982, VCCI changed its name to theChamber of Commerce and Industry of the Socialist Republic of Vietnam andexpanded its operations to the manufacturing sector

Since Vietnam “opened up”, VCCI has entered a new stage of developmentthrough the Second National Congress in 1993 and the third in 1997 VCCI continues

to grow in size wide as well as depth, catch up with the pace of development of thecountry Through its domestic and foreign activities, VCCI has actively contributed tothe country's renewal process, playing an important role in the country's economic

development and transformation, as well as its integration with international andregional markets.

In 1998, VCCI became an official member of the National Fatherland Front andexpanded its contribution to the development of Vietnam

As the representative of the entire business community in Vietnam, Vietnam ofCommerce and Industry has been a dynamic and effective consultant to thegovernment in the development of the laws, mechanisms, policies and business andinvestment environment system in Vietnam VCCI has maintained close coordinationwith government agencies in guiding business operations and policy change proposals

to facilitate economic and trade development

VCCI has protected the interests of Vietnamese enterprises in the relationship athome and abroad In promoting trade, VCCI has jointly organized governmentalactivities such as investment, information and consulting, brokerage in investment andbusiness, marketing, exhibitions, trade fairs, industrial arbitration, etc Thanks to theabove activities, the Chamber has become the trustworthy representative and thelargest trade and investment promotion center in Vietnam

With admiration for organized development, VCCI will play a central role inrestoring trade associations, corporations, expanding the Chamber's trade promotionnetwork and in particular attracting more small and medium enterprises

VCCI has made a great contribution to improving the business environment inVietnam and effectively supporting domestic and foreign entities in business activities

of households in Vietnam

1.1.2.3 Functions and missions of VCCI

The Vietnam Chamber of Commerce and Industry (VCCI) is a nationalorganization that brings together and represents the business community, employersand business associations in Vietnam for the purposes of development, protection andsupport enterprises, contribute to the socio-economic development of the country,promote the economic, trade and scientific-technological cooperation betweenVietnam and other countries on the basis of equality and win-win co-operation TheChamber of Commerce and Industry of Vietnam is an independent, non-

 Mission:

- To gather and study opinions of enterprises in order to reflect, propose and advisethe State on legal matters and socio-economic policies in order to improve thebusiness environment

- Participate in the elaboration and implementation of socio-economic developmentstrategies and international economic integration, attend conferences, trade andeconomic delegations in accordance with the regulations of the State

- Organizing forums, dialogues and meetings between enterprises and employers withstate agencies, laborer's representatives and other concerned organizations at homeand abroad to exchange information and ideas on issues related to business andbusiness environment

- To carry out necessary activities to protect the legitimate interests of enterprises andemployers in domestic and international business relations

- Organizing activities of propagandizing and mobilizing enterprises to strictlyobserve the law, raise social responsibilities, ethics and business culture, build laborrelations in harmony and protect the environment and participate in other socialactivities in accordance with the VCCI's objectives

- Collect and link with business associations in Vietnam, cooperate with Chambers ofCommerce and Industry, other relevant foreign organizations, join appropriateregional and international organizations for the purposes of VCCI and for theassistance of enterprises engaged in activities in such organizations

- Conducting activities of building, promoting and enhancing the prestige ofenterprises, entrepreneurs, goods and services of Vietnam; promoting businessdevelopment support services; assist the business to develop business and investment

relations at home and abroad through measures such as clues and referrals, providinginformation, guidance and advice to enterprises and research organizations, marketresearch, seminars, conferences, fairs, exhibitions, advertisements and otherpromotion activities

- Organize training in appropriate forms to develop human resources for enterprises,help entrepreneurs improve their knowledge and capacity in management andbusiness;

- Helping to register and protect intellectual property rights and technology transfer inVietnam and abroad

- To issue certificates of origin for Vietnamese export goods and certify othernecessary documents in business; certify force majeure cases

- Helping domestic and foreign businesses solve disputes, disputes throughnegotiation, reconciliation or arbitration; general avarage allocation upon request;

- To perform other tasks entrusted by the State of Vietnam or other organizations

1.1.2.4 Organization structure of VCCI

Figure 1.1 Diagram of organizational structure of VCCI

1.2 About The provincial competitiveness index (PCI)

Introduced in 2005, the Provincial Competitiveness Index (PCI) on Vietnam’sbusiness environment conducts an annual business survey, assessment and ranking ofthe economic governance quality of provincial authorities in creating a favorablebusiness environment for development of the private sector

Provincial Competitiveness Index is the measure of the effectiveness of local economic policy government This index removes the natural and social factors that

can make this locality more advantageous than other localities in economicdevelopment Thus, the localities have the opportunity to compete equally before theeconomic policies of the State The position of the locality in the rankings is ameasure of capacity and represents in a real way the perception, thinking and method

of governance of the local authority

The Vietnam Competitiveness Index (PCI) is a result of research cooperationbetween the Vietnam Competitiveness Initiative (VNCI) and the Vietnam Chamber of

Commerce and Industry (VCCI) By the comments of enterprises, PCI assesses and ranks provinces based on the attitudes and implementations policies of provincial government towards the private economy sector The provincial competitiveness

index refers to two aspects The first aspect is the quality of governance of theprovincial government PCI does not include internal business elements such asmanagement quality, corporate value chain,… because it is completely out of control

of local government The second aspect is the exclusion of the effects of availabletraditional conditions such as infrastructure, human resources, the distance from theplace of production to the market of the product because they are also not under thecontrol of local government PCI only covers conditions that local governments canfix in the near future

In other words, PCI was developed as a measure of the competitiveness of provinces which is independent of the traditional local conditions In fact, provinces

with better infrastructure, higher skilled and technically skilled workforce,geographically located closer to the large consumer markets, the economy grows more

favorably Moreover, the advantages from the traditional conditions are reinforced bythe particularity of the Vietnamese financial system Provinces with favorableconditions, with large revenue sources, are allowed to deduct part of their revenuesbeyond the plan for further development If using traditional conditions as a measure

of economic development, the results will be inaccurate Since traditional conditionsthemselves are the result of development Traditional factors are often not directlyinfluenced by attitudes and policies implementation of current government in the short

to medium term

Differences in traditional conditions between provinces are usually maintainedfor a long time For example, Ho Chi Minh City has a bigger market than Ha Tinh,Binh Duong has always better position than Ca Mau, infrastructure of Ha Tay is betterthan Ha Giang, Developers will certainly be higher competitive ranked by havinggood traditional conditions Thus, the exclusion of traditional elements will create thebasis of equal comparison between provinces and cities; more accurately assess theefforts of local governments to improve the business environment The ultimate goal

of the PCI is to identify the provinces that operate well when the initial conditions arethe same

CHAPTER 2: THE COLLECTING DATA PROCESS AND ASSESSING THE QUALITY OF THE PROVINCIAL

COMPETITIVENESS INDEX

2.1 The process of implementing the provincial competitiveness index

2.1.1 Indicators constituting the provincial competitiveness index

PCI is calculated on the basis of 10 components as follows:

Figure 2.2 The component index of PCI

Requirements for each indicators:

 Entry costs

The goal of this sub-index is to assess the differences in entry costs for new firmsacross provinces Entry cost is the cost that is calculated based on the measurement of

PCI INDEX

Entry costs

Land access and Security

of tenure

Transpar ency and Access to informati on

Time costs and Regulator

y complianc e

Informal Charges Policy

Bias

Proactivit

y of Provincial Leadershi p

the time a business needs to register a business, apply for land and receive all kinds ofpermits, the time it takes to do all the procedures for commencing business operations,the number of licenses to be completed, and the perceived difficulty of obtaining suchlicenses To establish an index of entry costs, data on:

- Percentage of businesses that take more than a month to start a business

- Percentage of businesses that take more than 3 months to start a business

- Percentage of firms having difficulty obtaining all the papers necessary forbusiness

- Time of business registration (number of days)

- Time to re-register (number of days)

- Number of registration papers, business license and approval decision theexisting business

- The actual waiting time to be allocated land (based on the main effort of localgovernment, not supply/demand conditions)

 Land access and Security of tenure

Considering the access and use of land, two aspects are considered First and foremost

is the status of enterprises having land use right certificates, having enough premises

to meet the requirements of business expansion or enterprises which are leased land

by state enterprises In addition, we also need to pay attention to the implementation

of land transfer in the locality Next is the feeling of the business about the risks in theprocess of land use

This sub-index measures the difficulty encountered by the business in the process ofsearching for business premises and obtaining land use right certificates Difficultiesfaced in the process of obtaining land use right certificates have limited businessesaccess to credit sources due to lack of papers to mortgage at the bank

It also measures the stability of land use Stable land use will make the companysecure long-term investment capital On the contrary, if businesses are notcomfortable with the stability of their business premises, they will have short-terminvestment plans, less capital

To qualify for this sub-index, it is necessary to consider:

- Percentage of enterprises having a certificate of land use right

- Percentage of enterprises leasing land from SOEs.

- Percentage of enterprises assessing the efforts of the provincial government inconversion of agricultural land use purpose is good or very good

- Percentage of total land area in the province with a certificate of land use rightland

- Assess the company's risk of land acquisition

- Assess the company's compensation policy if the land is recovered

- Risks of changes in land lease conditions

- Assessment of fairness in the way disputes of land leasing are settled

 Transparency and Access to information

In today's information age, businesses have a high demand for transparency andaccess to government information When government activity is transparent,businesses reduce the costs, time spent on transactions with government Access toinformation necessary for business such as information on planning, socio-economicdevelopment plan of the province, land use planning,… information on infrastructuredevelopment projects, major events of the city will help businesses have betterforecast conditions in their business plans

A measure of whether firms have access to the proper planning and legal documentsnecessary to run their businesses, whether those documents are equitably available,whether new policies and laws are communicated to firms and predictablyimplemented, and the business utility of the provincial webpage This indicator isexpressed in the following aspects:

- Transparency of the planning documents

- Transparency of legal documents

- The role of "relationships" to obtain provincial planning documents

- The role of family and friends when negotiating with government officials

- Negotiation with tax officials is an essential part of business

- Ability to predict the implementation of local regulations and policies

- The provincial government has consulted with the enterprise on changes inlegal regulations

- The quality of consultancy services provided by provincial authoritiesregarding regulations at central and local levels.

- Openness: Review the provincial website

 Time costs and Regulatory compliance

A measure of how much time firms waste on bureaucratic compliance, as well as howoften and for how long firms must shut their operations down for inspections by localregulatory agencies According to the Law on Inspection in 2010, inspection activitiesmust not affect the production and business activities of enterprises However, inpractice, businesses still have to stop business to serve the state agencies to conductinspection and examination for themselves This quantitative index is synthesizedfrom:

- Percentage of firms spending over 10 percent of their time on understandingand complying with regulations

- Median number of inspections (all agencies)

- Median tax inspection hours

- Government officials are effective

- Government officials are friendly

- Firms don't have to travel many trips to obtain stamps and signatures

- Paperwork is simple

- Fees are listed publically

- No noticeable improvements are made

 Informal Charges

A measure of how much firms pay in informal charges, how much of an obstaclethose extra fees pose for their business operations, whether payment of those extrafees results in expected results or "services," and whether provincial officials usecompliance with local regulations to extract rents

- Enterprises in my line of business usually have to pay for informal charges

- Percentage of firms paying over 10 percent of their revenue for informalcharges

- Rent-seeking phenomenon is popular in handling administrative procedures forbusinesses

- Percentage of firms saying that informal charges usually or always deliverexpected results

- Informal charges are at acceptable levels

 Policy Bias – New Sub-index

This sub-index reflects the attitude of the provincial government between state-ownedenterprises and private enterprises, domestic enterprises and foreign enterprises, largeenterprises and small enterprises

- Provinces give privileges to state-owned economic group, corporations,causing difficulties to your business

- Land access as a privilege to state-owned economic group

- Credit access as a privilege to state-owned economic group

- Mineral exploitation license as a privilege to state-owned economic group

- Faster and simpler administrative procedures as a privilege to state-ownedeconomic group

- Ease in getting state contracts as privilege to state-owned economic group

- Province give priority to FDI attraction than private sector development

- Province give priority in solving problems and difficulties to foreign companiesover domestic one

- Advantage in land access for FIEs

- CIT reduction and holiday for FIEs

- Advantage in procedures (faster, simplifier) for FIEs

- More government support during FIEs operation

- "Contracts, land, and other economic resources mostly fall in the hands ofenterprises that have strong connections to local authorities"

- Preferential treatment to big companies (both state-owned and nonstate) is anobstacle to their business operations

 Proactivity of Provincial Leadership

A measure of the creativity and cleverness of provinces in implementing centralpolicy, designing their own initiatives for private sector development, and workingwithin sometimes unclear national regulatory frameworks to assist and interpret in

favor of local private firms This of each locality is expressed through the followingspecific expressions:

- Firms' assessment of the attitude of provincial government toward privatesector

- The PPC is flexible within the legal framework to create favorable businessenvironment for nonstate firms

- The PPC is very proactive and innovative in solving new problems

- There are good initiatives at the provincial level but they are not wellimplemented by departments

- Provincial leaders have good policies they are not well implemented at districtlevel Province's reaction to lack of clarity in central policies/documents: %

"delay and seek instructions" and "do nothing"

 Business support services

Used to be named "Private Sector development services", this is a measure ofprovincial services for private sector trade promotion, provision of regulatoryinformation to firms, business partner matchmaking, provision of industrial zones orindustrial clusters, and technological services for firms

- Number of trade fairs held by province in previous year and registered forpresent year

- Ratio of the total number of service providers to the total number of firms

- Ratio of the number of nonstate and FDI service providers to the total number

of service providers

- Firm has used business information search services

- Firm used private provider for above business information search services

- Firm intends to use above service provider again for business informationsearch services

- Firm has used consulting on regulatory information

- Firm used private provider for consulting on regulatory information

- Firm intends to use above service provider again for consulting on regulatoryinformation

- Firm has used business match making services

- Firm used private provider for business match making services

- Firm intends to use above service provider again for business match makingservices

- Firm has used trade promotion services

- Firm used private provider for trade promotion services

- Firm intends to use above service provider again for trade promotion services

- Firm has used technology related services

- Firm used private provider for technology related services

- Firm intends to use above service provider again for technology relatedservices

- Firm has used accounting and financing training services

- Firm used private provider for above accounting and financing training services

- Firm intends to use above service provider again for accounting and financingtraining services

- Firm has used business administration training services

- Firm used private provider for above a business administration training services

- Firm intends to use above service provider again for business administrationtraining services

 Labor and Training

A measure of the efforts by provincial authorities to promote vocational training andskills development for local industries and to assist in the placement of local labor.Enterprises also pay close attention to this index when deciding to invest in aparticular province or city as labor is a decisive factor in any production and businessproject

- Services provided by provincial agencies: general education

- Services provided by provincial agencies: vocational training

- Firm has used labor exchange services

- Firm used private provider for above labor exchange services

- Firm intends to use above service provider again for labor exchange services

- Percentage of total business costs spent on labor training

- Percentage of total business costs spent on labor recruitment

- Overall Satisfaction with Labor

- Ratio of vocational training school graduates to untrained laborers

- Secondary school graduates as % of workforce

- Percentage of workers having completed training at vocational schools

- Legal system provided mechanism for firms to appeal against officials' corruptbehavior

- Firm confident that legal system will uphold property rights and contracts

- Cases filed by by non-state entities at Provincial Economic Court per 100 firms

- Business used courts or other legal institutions to resolve disputes

- Non-state claimants as a percentage of claimants at Provincial Economic Court

- Median months to resolve court cases

- Median formal and informal costs as a percentage of case

- Provincial court judge economic cases by the law

- Provincial court resolve economic cases quickly

- Court judgements are enforced quickly

- Legal aid agencies support business to use laws to sue when disputes arise

- Formal and informal costs are acceptable

- Judgement by the court is fair

- Willingness to use court in case a dispute arises

2.1.2 Methodology of data collection and PCI building

The PCI is constructed in a three-step sequence, referred to as “the 3 Cs”:

Step 1: Collect business survey data and published data sources,

Step 2: Calculate ten sub-indices and standardize to a 10-point scale

Step 3: Calibrate the composite PCI as the weighted mean of ten sub-indices with amaximum score of 100 points.

Sampling: Firms are selected using random sampling to mirror provincialpopulations Stratification is used to make sure that firm age, legal type, and sectorare accurately represented

2.1.3 The actual process of implementing the provincial competitiveness index in

recent years

In 2005, the first year PCI was announced experimentally, the PCI wascomposed of eight components, with the ranking of 47 provinces and cities.Immediately, it has attracted the attention of various parties such as the businesscommunity, provincial government authorities, press agencies or domestic and foreigninvestors According to the plan, the provincial competitiveness index research project

in Vietnam will be studied and produced once a year Over the years, the scale of thesurvey is extended, the higher the response rate

In 2006, two new component indicators were Legal institutions and Labor andTraining, were assessed in all provinces and cities in Vietnam In 2009, afterconsidering the incentives for state-owned enterprises no longer because theequitization of state-owned enterprises took place strongly, the PCI remove the indexincentives for SOEs At the same time, the 2009, PCI also renamed The private sectordevelopment policies index to Business support services

By 2013, the index of Policy bias is added Apart from incentives for SOEs likethe old ones, the new index adds incentives to large enterprises and FDI enterprises.This is due to the fact of unequal competition between state-owned and privateenterprises, between domestic and foreign-invested enterprises, between small andlarge enterprises

The 2017 PCI is the 13th iteration of the report, based on rigorous surveys of theperceptions of domestic and foreign firms The PCI strives to augment the collectivevoice of investors in Vietnam regarding governance in the provinces where they investand the country as a whole (Result can be found in Appendix 1) The number ofprivate enterprises participating in the survey in 2017 continues to exceed 10,000

established enterprises in 2016 and 2017 Data also collected from the 21 provincesand cities with the highest concentration of foreign direct investment (FDI) Theunadjusted PCI-FDI response rate is 30 percent with only limited variation byprovince Over 80 percent of respondents hold the positions of General Director or arethe top-level manager of their company in Vietnam The survey includes FIEs from 47different countries with the highest concentration from Asia, especially South Korea,Japan, and Taiwan.

Figure 2.3 The actual process of implemeting the PCI over the years

Source: PCI User Giude 2017

2.2 The PCI collecting data process

2.2.1 Position in mid-term internship process at VCCI

From 02/07/2018 to 02/08/2018, I was admitted to Vietnam Chamber ofCommerce and Industry as an intern at the Legal Department My task in the time ofthe internship was to learn about the provincial competitiveness index project anddirectly involved in the data collection process for the project "Competitiveness Index

at provincial level 2018 In the first period, I was led by Ms Luu Ngoc Anh - Project

Manager and Mr Dang Van Truong - Team Leader to learn about the process ofimplementing PCI and the ways of contacting the enterprises Having understood thenature of work, I was assigned the task of contacting private enterprises in Hanoi, newenterprises in Hai Phong, Lai Chau, Cao Bang provinces and FDI enterprises in HoChi Minh City This is an opportunity for me to get in touch with senior leaders inbusinesses in Vietnam, understand the situation of small and medium enterprises andunderstand the business environment in some areas of the country I was alsoinstructed and arranged some papers, books, surveys or thank letters to send to thebusiness Because of the relatively short time of internship period, I had no chance toapproach with data analysis process of VCCI But this is an actual opportunity for me

to learn and explore the reality of the implementing a project of a non-governmentalorganization representing the only and largest voice of business in Vietnam

2.2.2 Details of the PCI collecting data process

2.2.2.1 Source data

PCI team utilize two general types of data to construct the sub-indices The first

is perceptions data drawn from the mail survey to private firms This “soft” data isthen combined with objective or “hard” data gathered from statistical yearbooks andother administrative sources available from government ministries The hard data isused to address perception and anchoring biases in responses After all, many SMEsmay not have an adequate understanding of other locations to rate their home province

on a five-point scale A full list of hard data used in the index can be found Appendix2

2.2.2.2 The process of collecting data for PCI