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EAB overview May 2017

EAB publishes its Annual Report

We have published our latest Annual Report monitoring BT's compliance with the Undertakings.

In her introduction to the report, Isabel Hudson, the EAB Chair, reports that we consider BT’s overall compliance continues to be good and that, while there were aspects where BT could have done better, it has remained committed to the Undertakings. The year has seen a significant amount of uncertainty and speculation as BT and Ofcom have discussed possible changes to the Undertakings and the EAB as a consequence of the DCR. We have remained focused on our role throughout, but believe that the time is right for a new regime which will allow all issues to be investigated more widely - not just through the narrow prism of Equivalence. So we welcome the introduction of a new governance structure for Openreach and, most importantly, we look forward to better outcomes for all CPs.

download  Read the report

EAB governance

Since our last bulletin, we have agreed with Ofcom a protocol for managing Edward Astle’s conflict of interest whilst he serves on both the EAB and the Openreach Board. We have also agreed working practices with the new Openreach Board Audit, Risk & Compliance Committee (OBARCC), to the effect that the OBARCC will rely on the EAB’s monitoring of the Undertakings.

EAB meetings

We met in April, receiving updates on the progress of the DCR and systems separation delivery from BT, as well as considering our work plan for the coming year. Openreach presented to us its 2017/18 Annual Operating Plan, the first to be approved by the new Openreach Board. We also reviewed our previous monitoring of Deemed Consent, following the outcome of the Ofcom investigation into this, and concluded that the limiting of our reviews to Equivalence matters had prevented us finding the issues identified by Ofcom.

Undertakings delivery report

Delivery of systems milestones

BT reported in April that it remained on track to achieve its internal forecasts for EoI and CSR migrations. The figures at the end of April 2017, reported in our annual report, were that 99.84% of customers were using exclusively EoI products and 98.75% of all customer records had been migrated to separated systems. The customer records figure includes 98.9% of all ISDN2 lines and channels, with the remainder due to be migrated during 2017/18. 99.99% of business customers are now serviced using BT’s strategic OSS, irrespective of whether any of their underlying records remain to be formally separated. BT has not yet completed the migration of all customer records for the ISDN30e product and reports that this will be progressed as part of the ongoing migrations programme. We will continue to monitor migrations progress quarterly.

EAB's future work plan

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

  • Undertakings change;
  • organisational change;
  • capex prioritisation;
  • access to new products;
  • Openreach SoR process;
  • end to end working;
  • mandatory training; and
  • systems and tools. 

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

Breaches

There were two breaches on which we concluded at our April 2017 meeting, plus one further case on which we came to a provisional conclusion, pending a final report being provided:

 

Description

Materiality

Remedy

A BT compliance review of Openreach systems identified a number of non-compliant user accesses.

Provisionally agreed to be Non-Trivial

All non-appropriate user profiles will be removed from all systems. The BT User Access Audit Tool (UAAT) will monitor access to all relevant Openreach systems going forward.

An Openreach report covering Time Related Charges was made available to BT Consumer but not to the rest of industry.

Non-Trivial

BT intends to remedy the breach by issuing an improved report to all CPs, which is due to be included in an Equivalence Management Platform (EMP) release scheduled for July 2017. In the interim, at the EAO’s request, Openreach introduced a manual report that can be requested by all CPs.

Openreach inadvertently shared details of CP credits with BT Wholesale & Ventures.

Trivial

The email was deleted and the person who shared the information has been briefed on the need for future vigilance. The impacted CPs were advised that their information was shared.

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

CPs – Communications Providers
CSR - Customer Side Records
DCR - Ofcom’s Strategic Review of Digital Communications
EAB –Equality of Access Board
EMP - the Equivalence Management Platform, Openreach’s strategic product management platform
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
OBARCC - Openreach Board Audit Risk & Compliance Committee
OSS - Operational Support Systems
SoR - Statement of Requirements process, the process by which CPs request changes to Openreach and BT Wholesale & Ventures products
UAAT - User Access Audit Tool, BT’s automated tool for monitoring access to systems