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EAB Overview: March 2015

EAB’s January 2015 meeting

The EAB met in January and had presentations from Ofcom, the OTA2 and BT.


Jonathan Oxley, Ofcom's new Group Director for competition, presented to our January meeting, updating us on Ofcom's views on the Undertakings and its programme of work for the coming year. We discussed BT's progress towards system separation, its proposal to move some Openreach systems to an internal Cloud computing environment, and the actions BT was taking to ensure it remained compliant with the Undertakings as it looks into a potential acquisition of EE.

Rod Smith, CEO of the OTA2, also presented to the meeting. He highlighted current industry concerns, particularly around Ethernet as Openreach moves to implement its Differentiated order Journey (DoJ). Two EAB members, Edward Astle and Emin Gurdenli, had attended the OTA2 Executive meeting held on the same day, and reported back to us how valuable it had been in enhancing their understanding of the industry context in which the Undertakings operated. Our remaining members will attend another OTA2 Executive meeting later this year.

Sean Williams, Director of Strategy, Policy & Portfolio for BT, updated the EAB on BT's strategy. He answered questions about how BT was ensuring Undertakings compliance whilst considering a potential mobile acquisition. He also confirmed BT's commitment to system separation, and the rationale for a move to a Cloud environment.

We received an annual update from the Director of BT's Group Internal Audit, highlighting the findings of relevant audits conducted by his team, and our regular quarterly report from Joe Garner, Openreach CEO. BT additionally provided an update on its management of employees who had privileged access to Openreach information, through inclusion in the teams listed in Annex 2 of the Undertakings.

We reviewed our risk register for 2015/16, and agreed that we should take into account reports which would be made at our April meeting, before deciding on the final priorities of the identified risks. We also agreed the structure and themes for our 2015 annual report.

Undertakings delivery report


BT is due to update us on its progress in its ongoing migrations programme at our April meeting, when we will be reviewing whether we still consider BT's plans to be ‘reasonably practicable and proportionate’, as required by the Undertakings. We consider it would be beneficial for BT and Ofcom to reach agreement on plans for the ‘tail’ of customers and records which were not specified as part of the formal migration milestones of the Undertakings, and were concerned about progress in these discussions, although we noted that a meeting had now been arranged.

Ongoing compliance

BT has reassured us that it supports a policy of ‘zero tolerance’ for non-completion of Undertakings training, and provided an update on the programme in place to enforce this. We will continue to monitor this through our newly expanded report on behavioural KPIs.

We have asked the EAO to review an area of concern around Openreach information sharing raised by a CP at the OTA2 Executive meeting we attended, and to confirm that Openreach's rejection of a ‘dark fibre’ SoR request was compliant with the SoR rules.


We have concluded four cases were breaches:





Inappropriate provision of a service to BT Wholesale customers, in breach of an exemption allowing service to a specific customer only


BT has now sought a further exemption from Ofcom and ensured the employees concerned are now aware of the restrictions

Openreach Confidential Information (CI) was made available on an information-sharing site, without the correct access restrictions (although there was no evidence that the information was accessed inappropriately)


The correct access permissions are now in place and the EAB has requested a report on how BT intends to mitigate the likelihood of similar incidents on this site in future

Individuals without the correct Annex 2 Part A status had membership of a committee which had the potential to influence Openreach Commercial Policy Trivial The committee has been disbanded and updated guidance issued to avoid a recurrence
Openreach CI was inappropriately shared with BT Wholesale in a slide pack Trivial BT is reviewing how it identifies CI and will be presenting to the next EAB meeting on the controls it has in place

Product Key Performance Indicators (KPIs)

BT published 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.


CI - Confidential Information
CPs – Communications Providers
EAB –Equality of Access Board
EAO - Equality of Access Office
KPIs – Key Performance Indicators
OTA2 - Office of the Telecommunications Adjudicator 2
SoR - Statement of Requirements