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EAB Overview: May 2016

EAB publishes its Annual Report

It is over 10 years since the Undertakings took effect in September 2005 and we have published our latest Annual Report monitoring BT's compliance with them.

In her introduction to the report, Isabel Hudson, the EAB Chair, reports that we consider BT remains committed to the Undertakings but that it is not faultless in its compliance. Our report notes the significant and positive changes that have been seen in the UK telecoms market since 2005, and includes a review of BT’s compliance over this period. We acknowledge, however, that service issues are the biggest current concern for the Industry and that it remains to be seen how these wider concerns will be addressed following the conclusions of Ofcom’s strategic review (DCR). Until that is resolved, we will maintain our robust monitoring and vigilance regarding compliance with the current Undertakings.

Read the report at www.bt.com/eabreport

EAB meetings

We met in April, receiving presentations from Ofcom and PwC, the external auditor of our annual report, as well as BT and Openreach. Sharon White and Jonathan Oxley shared with us changes to Ofcom’s regulatory approach following its recent strategic review of UK digital communications markets and the conclusions from its latest review of business connectivity markets. Clive Selley presented Openreach’s Annual Operating Plan, as well as a review of its Q4 operations. PwC reported on its 2016 assurance and we had presentations from BT regarding migrations, an internal audit review of BT’s training completions, and breaches.

EAB members met members of the Ofcom board in May to brief them on our Annual Report.

Undertakings delivery report

Delivery of systems milestones

At our April meeting, we reviewed with BT its plans for migrations to April 2017. While we were pleased to note that it was ahead of its published commitments to migrate 99% of Equivalence of Input (EoI) products and 96% of Customer Side Records (CSR) by the end of March 2016 (achieving 99.5% and 97.1% respectively), we were concerned to note it has missed the expectations it set on ISDN30 and is now lowering its forecast for where it expects to be on customer records by April 2017. We have asked BT for a further report at our next meeting in July and will be monitoring this closely in the coming year.

Complaints

In this year’s Annual Report, we differentiate between Informal Complaints and Information Requests received by the EAO through its Quick Checks process. The number of complaints to BT about the Undertakings and Informal Complaints to the EAO is down this year on last year. However, at the end of January this year, we received a formal complaint from Vodafone, alleging that BT’s Customer First programme allowed BT CPs to influence Openreach’s actions and developments in a way that was not open to other CPs. We are continuing to investigate this complaint and will provide an update in our next bulletin.

EAB's future work plan

In the next year the EAB will be focusing on the following key risks:

  • Undertakings change;
  • organizational change;
  • systems and tools;
  • technology change;
  • capex prioritisation;
  • end to end working; and
  • the CSR and EoI migration tail. 

These risks, along with our mitigating actions, are explained in detail in our annual report.

Breaches

There were five breaches on which we concluded at our April 2016 meeting:

 

Description

Materiality

Remedy

An audit by BT identified two individuals who had moved from BT Wholesale to BT Global Services but continued to have access to the BT Wholesale finance SharePoint site and files which contained CCI.

Trivial

Access to the site for the two people was removed. Individuals involved in managing this site have been briefed on the information sharing and user access control requirements of the Undertakings

Openreach job controllers were co-located with some CPs, who were experiencing issues with placing Ethernet orders, but there was not appropriate governance in place to ensure these arrangements were equivalent.

Trivial

BT has developed a governance process for co-location of job controllers and will apply this to all current and future co-location arrangements against standard criteria.

BT Wholesale information was inadvertently shared with a BT Business employee during the sign-off process for BT’s response to the Business Connectivity Market Review (BCMR).

Trivial

The information was deleted without being read and sign-off meetings involving cross-LoB data will in future be restricted to Annex 2 people.

Sub-Loop unbundling tie cable data was visible to BT Global Service employees using shared systems. A BT Global Services employee used information relating to one tie cable order to contact a non-BT CP in an attempt to prevent the order from failing.

Trivial

Openreach plans to move all of the completed SLU orders onto an EoI system and raise all new SLU orders onto a separated EoI system. There will also be a small number of ‘in progress’ orders which Openreach proposes to leave until completed and then move to the EoI system.

Openreach CCI relating to customer satisfaction was inadvertently shared with the BT Global Services leadership team by a member of the BT Group Customer Experience team.

Trivial

Participants were asked to delete the slides and printed copies were handed back at the meeting when the slides were due to be discussed. Briefings and a knowledge call were delivered to the whole of the team responsible for the slides on information sharing and document marking.

The EAB also reviewed a case concerning an Openreach system not being correctly separated which had previously been agreed to be a trivial breach. Openreach had subsequently identified that the system had been correctly separated but the data records had been incorrectly modified and this had led to the supposition that a breach had occurred. The EAB concluded that no breach had occurred but has asked BT to provide details on how the governance weakness which led to the incorrect breach notification would be addressed in future.

Product KPIs

BT published Key Performance Indicators (KPIs) showing the output performance of its regulated wholesale products. The KPI charts for each product portfolio compare service performance for BT’s business units to that for other CPs.

Glossary

BCMR – Ofcom’s Business Connectivity Market Review
CCI - Customer Confidential Information, which is restricted under the Undertakings
CI - Commercial Information, which is restricted under the Undertakings
CPs – Communications Providers
DCR - Ofcom’s Strategic Review of Digital Communications
EAB –Equality of Access Board
EAO - Equality of Access Office
EoI – Equivalence of Inputs, which means that BT provides the same product or service to all CPs on the same timescales, terms and conditions and by means of the same systems or processes
KPIs – Key Performance Indicators
LoB - Line of Business, used to describe the different parts of the BT Group
OSS - Operational Support Systems