EAB overview - December 2011

14 December 2011

Undertakings delivery report

Systems milestones

The fourth UK business stack milestone due on 31 December 2011 requires BT to begin customer migrations at volume. These non-binding milestones were proposed by BT as a way of making progressive steps towards reaching a target of 90% of customer records to be held on separate systems by December 2012.

Ofcom and BT held discussions on the success criteria for this milestone, which are now more focused on delivering functionality rather than volumes of migrated customers. The EAB asked for a further briefing once the discussions with Ofcom have concluded.

Other systems updates

PricewaterhouseCoopers completed its bi-annual mandatory audit of user access controls for 19 systems specified in the Undertakings and found no issues.

The EAO has provided Ofcom with the third six-monthly report on those systems referred to as ‘core-hybrid’. These are 11 Operational Support Systems (OSS) which it was agreed could have continued shared access by both Openreach and the rest of BT because of some shared operational network elements. Unlike other OSS there is only a requirement for access controls rather than separation.

The EAB has to carry out checks every six months to monitor access to these core-hybrid systems by BT employees and report to Ofcom. The EAB concluded that non-Openreach user access to these systems was of limited numbers and only existed where there is a demonstrable operational need—in line with the original intent of the obligation.

Ongoing compliance reviews

Industry issues

The EAO is reviewing a number of issues raised by industry as part of its ‘Quick Checks’ process. It had recently completed an investigation of Openreach’s project services product to assess the impact that it might have on the standard order provision process. The EAO found that the process was operating equivalently and Openreach held a conference call with interested CPs to give a further explanation on the operation of project services.

Other issues currently under review include orders potentially progressed outside of Openreach’s Statement of Requirements process and some concerns raised by CPs in Northern Ireland.

Information sharing review

The EAO has completed a detailed review of information sharing arrangements in BT’s Managed Ethernet Access Services (MEAS) Enterprise Programme. MEAS is BT Wholesale’s Ethernet service to mobile operators which enables them to supply high-bandwidth to their end users. The review highlighted some areas for improvement - such as updated guidance on BT Wholesale’s intranet site - on which BT will continue to work.

Breaches

There were two new breaches reported to the EAB at its November meeting:

 

Description

Status

Remedy

There had been a failure to apply equivalence and inappropriate disclosure of information through a system which was used to manage broadband network incidents affecting BT since the inception of the Undertakings.

Non-trivial

System withdrawn for all people with inappropriate access and communications around usage was improved. Other remedial actions are ongoing.

There had been inappropriate sharing of customer confidential information as part of an exercise to resolve which lines of business owned circuits in some data centres.

Trivial

Changes were made to the system and a briefing offered to relevant employees. The EAB agreed that the remedial actions had been completed and this breach case could be closed.

Update on breaches reported in the last Overview:

 

Description

Status

Remedy

Failure to apply effective user access controls and inappropriate disclosure of BT Wholesale information in the Contract Governance Review system, which manages the in-life performance of major contracts.

Non-trivial

The EAB agreed that the remedial actions had been completed and this breach case could be closed.

Inadvertent sharing of information within the Integrated Services Digital Network Automation Tool Management system, which was used for diagnostic testing in the ISDN30 repair process.

Trivial

The EAB agreed that the remedial actions had been completed and this breach case could be closed.

BT has reported to the EAB that it was putting in place proactive mitigation against further systems breaches by revisiting the entire catalogue of systems to check that each system was being operated in compliance with the Undertakings. This would be accompanied by a training programme to remind systems’ owners to check compliance. Corrective action would continue to take place for individual breaches.

BT also made a number of changes to its breaches process, involving changes to the way that breaches are reported within BT to improve processing times.

Industry viewpoint

Colm O’Neill, CEO BT Ireland and John Ellison, Head of Regulation, Northern Ireland attended the EAB’s November meeting. Discussions were focused on how the subset of Undertakings applicable in Northern Ireland were being implemented in practice and some of the issues that had been raised by CPs operating there.

New EAB Chairman appointed

Carl Symon is stepping down from his chairmanship of the EAB pending his retirement as a BT non-executive director in January 2012. He extended his thanks to the EAB members for their commitment and diligence. He also thanked the Director EAO and his team for their hard work. The EAB members and the Director EAO thanked the Chairman for the leadership he had provided over the last six years, and noted the benefit his independence had provided to the entire industry.

BT non-executive director Phil Hodkinson will take up the Chairman’s role at the EAB’s January meeting. Phil Hodkinson was appointed to the Board on 1 February 2006 and is a member of the Nominating & Governance Committee, the Committee for Sustainable & Responsible Business, and the Pension Scheme Performance Review Group. He is a non-executive director of HM Revenue & Customs, Travelex, Resolution and Business in the Community, and a trustee of Christian Aid and BBC Children in Need. Prior to his retirement in 2007, Phil’s roles included group finance director of HBOS, chairman of Insight Investment and Clerical Medical, and chief executive of Zurich Life and Eagle Star Life. He is a Fellow of the Institute of Actuaries.

Product KPIs

BT publishes key performance indicators (KPIs) showing the output performance of its regulated wholesale products. The KPI charts for each product portfolio compare service performance to CPs within BT to that for non-BT CPs.

The EAB asked the EAO to pay close attention to Ethernet Access Direct repair after the sharp downturn in performance for non-BT CPs. It also requested that the EAO investigate the status of Wholesale Line Rental 3 provision and repair.

Glossary

Business stack – a collection of inter-related systems which allow BT’s business customers to be served equivalently
EAB – Equality of Access Board
EAO – Equality of Access Office
KPI - key performance indicator
MEAS – Managed Ethernet Access Services
OSS – Operational Support System