This is Icebreaker One’s response to the Call for Input for Data Best Practice – Review and Evolution. Our response is here.
Please note that throughout this consultation, Icebreaker One uses the terms Open, Shared and Closed data as defined here.
If you have any questions about our submission or require clarifications please do not hesitate to contact us via firstname.lastname@example.org. We have omitted questions which we did not answer.
Call for input response:
2. Question: If your company is not currently operating under the DBP Guidance, we would seek your views on the following:
- Would you consider, or have you considered, signing up to this voluntarily?
- If not, can you provide reasons or considerations for your answer?
- Do you have any suggestions for improvement and why?
- Would further enhancements or changes make you more likely to consider adopting the DBP Guidance voluntarily?
- Have you received any stakeholder queries regarding DBP Guidance? If so, can you provide a brief outline of the subjects?
- Can you provide a breakdown of costs for your organisation if you made the decision to adopt the DBP Guidance?
Response to question 2:
For background, Icebreaker One’s model and associated projects – e.g. Open Energy – are not data repositories. Rather, we facilitate the search and discovery of open and shared data and the exchange of shared data through a trust framework, without directly accessing the data ourselves. Icebreaker One adopts open working principles across all aspects of the organisation, including the open consultations, open sourcing its code, supporting open standards and the publishing of open data where relevant. We also publish a range of other open resources including, but not limited to: user guides, technical, operational and policy documentation and research findings.
While we have considered voluntarily adopting the DBP guidance, we have determined that it is not suitable for two core reasons. Firstly, the guidance does not adequately govern the wider scope of open resource publishing conducted by our organisation. This is particularly significant as our organisation makes searchable and discoverable non-data open resources as well as open data. In its current form it would not be appropriate to attempt to apply principles outlined in the DBP guidance to other types of resource publishing decisions. It is therefore preferable to maintain independent open policies to ensure consistency in our decisions across a range of data and resource types.
Secondly, our trust framework model supports the exchange of Shared data by our users (i.e. third parties). While we do not as standard hold access to the datasets shared by users of the trust framework, the processes of facilitating data exchange create operational data and metadata that is sensitive. We would not be able to adequately conduct Open Data Triage on such datasets as these sensitivities implicate a wide variety of primary and secondary stakeholders that reach far beyond our own organisation. It would not be feasible, cost effective nor appropriate for Icebreaker One to attempt to make these assessments as the rights and information required to do so sit with our users, not only with us. As such, any requirements for Icebreaker One to comply with the DBP Guidance presents risks to our business model which has been designed to securely facilitate Shared (i.e. sensitive) data exchange.
3. Question: If you are currently operating under the DBP Guidance, whether obligated to or not, how has your experience of common data standards been affected by the DBP Guidance?
- In your experience, would data sharing benefit from the regulator mandating common formats for data? Please provide information to help us understand your answer.
Response to question 3:
Icebreaker One has conducted extensive sector research supporting the creation of the Open Energy trust framework, including inquiry into whether this framework should mandate common standards for licensing, metadata, and data quality. Synthesised research results from across the Open Energy project suggest the following sector priorities:
- Adoption of standardised licences for Open data should be prioritised. Research demonstrated that creation of bespoke ‘Open’ data licences present risks to data usability, by increasing the costs (time, financial, legal) of interpreting non-standardised licences and/or by permitting data publishers to create licences which do not actually produce Open data (either through error or evasion). We would support Ofgem to standardise their approach to this issue within the DBP guidance. Rather than creating a new licence for this purpose, we strongly suggest that Ofgem mandates existing well-known licences (e.g. Creative Commons, Open Government Licence or similar). In order to minimise unnecessary conflict which could surround the choice of a single Open data licence, as well as costs of change for organisations that already adopt different but well-known standard Open data licences, we suggest that Ofgem specifies a limited set of well-established standard Open data licences that must be used to publish Open data under the DBP guidance.
- Adoption of metadata standards is a highly politicised topic associated with low feasibility of reaching industry consensus on a single standard. At present, there are significant differences among standards used by different actors across the sector. We suggest that mandating a single metadata standard risks producing inadvertent barriers to the publication of Open data. For example, it may present an unfair distribution of costs to organisations required to change standards or may lead to a reduction in volume of Open data that is voluntarily published if organisations have to invest resources into metadata standards change. This is particularly significant if DBP guidance is extended to parts of the sector beyond energy networks, in which metadata standards adoption is more varied. Rather than mandating a single pre-existing metadata standard, we suggest that Ofgem extends the guidance to support all organisations to produce appropriately descriptive metadata in order to improve Open data discoverability and searchability. This could potentially take the form of specified minimum descriptive metadata – for example stating that Open data published under the DBP Guidance must be associated with metadata containing basic items such as: publisher details, title, associated licence, brief description of contents, publication date, update frequency, etc. While this may seem a basic approach in contrast to more extensive technical standards, our research suggests that the introduction of minimum descriptive requirements could have a significant impact in practically supporting the discovery and use of Open data in the sector, without requiring difficult political consensus or significant additional cost.
- Adoption of data quality standards for Open data is highly contested, particularly for historical datasets and those influenced by legacy technologies. The main reason given for contesting data standards was the influence of legacy equipment, operational processes and infrastructures on data quality. This may not easily be rectified in accordance with one specific data quality standard. As such, without some flexibility, there is a risk that mandating specific quality standards could discourage the publication of valuable Open datasets. Similarly to our recommended approach to metadata, we suggest that Ofgem does not seek to adopt one single data quality standard to govern all Open data produced under the DBP guidance. Rather, we recommend that there would be value in offering support for organisations around two key issues associated with poor data quality: transparency and improvement. Firstly, we recommend that DBP guidance is amended to encourage data publishers to include details of known quality issues in their descriptive metadata. For example, this may include a note of known gaps or inconsistencies in the dataset. This would improve transparency around known quality issues in the data, supporting data users to apply Open data for appropriate purposes. Secondly, we recommend that Ofgem includes recommendations for basic data quality checks in the DBP supporting information. This does not need to be extensively technical, however it should aim to help data publishers ‘troubleshoot’ common quality issues prior to publication and thus to improve the baseline of Open data quality published under DBP guidance. For example, this could address common issues flagged within the Open Energy project, such as missing units of measurement or use of notation/acronyms without adequate explanation.
5. Question: What are your views on expanding the obligation of DBP Guidance to other licenced entities in the energy sector, such as generators, suppliers, and code bodies? Please provide as much detail as possible to support your answer.
Response to question 5:
Icebreaker One supports the expansion of DBP guidance to other licensed entities. We suggest that expansion to all licensed entities is considered, including Electralink, Smart DCC and code bodies. In parallel, we caution that further research is likely to be necessary in order to ensure guidance is suitable for entities holding data in substantially different formats, or with different sensitivities, to that held by energy networks. For example, this may include exploration of different commercial sensitivities surrounding datasets produced by generators – e.g. if/where certain datasets may open potential for market ‘gaming’. Additionally, it would be pertinent to consider any issues surrounding the treatment of personal data held by suppliers under an extension of the DBP guidance, including if and how different aggregation or anonymisation procedures may support the expansion of Open data publishing.
We also suggest that due consideration is given to the formats of datasets to be included within DBP parameters if these are expanded. Specifically, we would like further information about how non-quantitative datasets (e.g. text, image etc.) may be considered under the DBP guidance, as applied to all actors. This is particularly pertinent to the application of DBP guidance to code bodies who hold extensive text-based datasets pertaining to code modifications and governance. We suggest that such datasets could hold significant public value and should at least be considered when evaluating the future scope of DBP guidance.
6. Question: Do you exchange data, or have an expectation to share data in the future with any of the companies participating in these initiatives?
- If so, what is your experience of the data sharing in this space?
- Do you believe that obligating these companies to abide by the DBP Guidance would improve these interactions, or not?
- If you do not share data with these companies, do you believe that obligating these companies to abide by the DBP Guidance would improve these interactions, or not?
Response to question 6:
As outlined in Response 2, Icebreaker One does not directly share data with actors in the new regulatory spaces detailed in point 6.4, as we facilitate data sharing without requiring dataset access. However, a number of actors in these spaces have been involved in projects with Icebreaker One and have thus fed into our research and trust framework design. We strongly advocate that there is a pressing need for a more holistic, whole-systems approach to developing the energy data ecosystem – reflecting the interconnectedness of different energy vectors as well as their impacts on emissions. As such, we would support Ofgem to adopt a broad approach to exploring the extension of DBP guidance – so long as backed by appropriate research – into new regulatory areas such as heat networks and CCUS, as well as areas surrounding EV charging.
7. Question: Do you exchange data, or have an expectation to share data in the future with any companies who do not currently fall under Ofgem’s regulatory remit?
- If so, what is your experience of this data sharing process?
- Do you believe that obligating these companies to abide by the DBP Guidance, or the companies voluntarily abiding by the DBP Guidance, would improve these interactions, or not?
- Has your company experienced sharing data with non-energy sector participants, such as companies active in the telecommunications, utilities, or transport sectors?18 If so, can you describe the interactions (both good and bad), with due consideration to any commercial sensitivities.
Response to question 7:
As outlined in Response 2, Icebreaker One does not directly share data with non-regulated actors as we facilitate data sharing without requiring dataset access. However, particularly given the volume and importance of non-regulated actors in the emerging digital energy ecosystem, we have engaged extensively with a range of these actor types. As the design of our trust framework is intentionally multi-sectoral – reflecting the concept of a cross-sector ‘web of net zero data’ – we have also engaged across multiple sectors including banking, finance, telecommunications, insurance, water, food systems, electricity, heat, transport and the built environment, among others.
In our experience, data sharing with this wider network of companies is likely to grow in importance due to two interrelated factors. Firstly, digitalisation increasingly challenges ‘traditional’ sector boundaries, for example through sector coupling and development of cross-sector digital business models. Secondly, the 2050 net zero target integrates actors across different sectors in order to address environmental challenges that must account for sectoral dependencies, for example including finance or supply chains.
Reflecting higher levels of cross-sector integration, we are supportive of initiatives that aim to increase and improve data sharing across boundaries. However, we are unsure whether introducing an obligation to comply with DBP guidance reflects the only, or most cost-effective, approach to stimulating data sharing. Our position reflects two key research findings from the Open Energy project:
- General demand for data-sharing between regulated and non-regulated stakeholders stems primarily from Shared data, not Open data.
- Open data alone will not be sufficient to achieve net zero. Data exchange between regulated and non-regulated stakeholders for net zero purposes/projects is also primarily driven by Shared data, not Open data. This concerns data shared by and to regulated entities.
Reflecting the above points, we recommend that future investment in the ecosystem of energy and related data should focus on specifying a unified approach to sharing types of data that do not meet the criteria to be published as Open data. While we fully support all efforts to improve the energy sector Open data ecosystem, our research and technology development as MEDA competition winners (Open Energy project) strongly suggests that the development of Shared data infrastructure is of high importance to the role of data and digitalisation in enabling net zero. As such, we suggest that this be appropriately prioritised alongside new initiatives to expand DBP guidance.
We suggest that a future approach builds from industry-tested foundations developed through the Open Energy trust framework in order to implement a clear and consistent approach to Shared data governance which can support an ecosystem of commercially, socially and environmentally valuable Shared data. We recommend that this includes:
- The establishment of a system of data sensitivity classes, to improve consistency in sector understanding and categorisation of Shared data.
- The implementation of a standardised approach to Shared data access, based on a standardised range of access conditions, to enable flexible governance of data access within well-defined parameters.
- The introduction of a standardised approach to Shared data licensing, based on a standardised range of licence conditions, to enable flexible creation of licences within well-defined parameters.
While we acknowledge that conceptual debates regarding how to facilitate data access are ongoing in the sector, Icebreaker One’s Open Energy project provides a proven trust framework to meet energy sector needs for data sensitivity classification, access control and licensing, as established through a competitive process with extensive sector input, peer review and scrutiny. It has been designed to deliver many of the EDiT recommendations for the Digital Spine. As such, we propose that the Open Energy trust framework model be considered as a means to facilitate Shared data exchange that would meet the needs of both regulated and non-regulated actors, with co-benefits to their expanding sets of data stakeholders within and beyond the energy sector. Operated as an independent, neutral non-profit, the model works to deliver private sector benefits in the broader context of the public interest. The model can further support the implementation of multiple schemes, governed by different bodies (e.g. regulators, code governance bodies or trade bodies) to enable a framework for interoperability across domains. A diagram of the trust framework is included in Figure 1 below and further information on the model can be found in Footnote 5. We would also be happy to discuss this further with Ofgem and other relevant parties.
Figure 1: Understanding scheme governance for data infrastructure
8. Question: Do you agree with our minded-to decision to require DNOs to treat de-personalised smart meter demand data, collected as set out in DNOs’ Data Privacy Plans, as Energy System Data?
- Do you see any potential sensitivities with this data being classified as Open Data? If so, please provide information to support your answer.
- Do you have any additional methods you are aware of, or are considering, to de-personalise or aggregate smart meter data?
Response to question 8:
We are not able to offer definitive comment on this proposal without further detail regarding the exact methods of de-personalisation that are proposed to be used. At present, we raise the following questions:
- Will de-personalisation methods mirror DNOs’ privacy plans in their current forms, or will any alternative methods be used?
- Will methods be standardised across different DNOs’ geographic remits?
- Will data only be aggregated, or will other de-personalisation methods be used? If so, which methods and for what purposes?
- What size of ‘n’ will be considered appropriate and safe for smart meter data aggregation, particularly in sparsely populated areas where postcode level aggregation does not provide sufficient privacy?
In our own work, Icebreaker One recommends that anonymised personal data should only be made Open if it complies with recognised robust methodologies, for example as set out by the ICO. We recommend that Ofgem formally adopts similar, standardised guidance for DNOs if this option is taken forwards.
We also caution that no form of de-personalisation can occur without some level of risk, which must be appropriately managed at the sector level. We suggest that Ofgem takes responsibility for risk management going forwards, incorporating monitoring and adaptation of guidance if required. While by no means exhaustive, the primary risk we identify in this space is the risk of individual re-identification through dataset combination. This issue is complex and can evolve in unforeseen ways as the available data landscape changes, particularly with increased opportunities to combine energy and non-energy data sources as discussed in Response 7. If de-personalised smart meter data is to be made Open, we recommend that Ofgem establishes a clear point of contact through which concerns regarding re-identification can be raised. We also recommend that re-identification risks are catalogued by Ofgem, made publicly available, and reviewed on a regular basis as the data landscape evolves.
Beyond the proposals outlined in this consultation, we agree with Ofgem’s assessment that publishing Open, de-personalised smart meter data can be useful but has limitations. Accordingly, and as detailed in Response 7, we emphasise the importance of developing a parallel approach to Shared data classification, access and licensing as part of developing the sector’s Digital Spine. This combined approach to development of the sector’s Open and Shared data ecosystems will most effectively maximise the potential benefits of energy data to net zero, innovation, and wider society.