IREG met on the 15th January 2020 and discussed the following MRA Issue Forms (MIFs) and Electricity Central Online Enquiry Service (ECOES) changes.
MIF219 – Full review of the Working Practice Product Set (WPPS)
IREG were presented with draft Change Proposals (CPs) for the removal of WP145 from the WPPS and for the guidance within WP124 to be moved in to MAP14. IREG noted and agreed the draft for the removal of WP145. IREG discussed a number of questions relating to the removal of WP124. It was agreed that these questions would be posed at the next Pre-Payment Metering Forum (PPMF) meeting as the committee had more expertise in this field than IREG.
MIF288 – Industry Contacts Database
IREG were advised that the upgraded MRASCo Industry Contacts Database would be going live on 21st January 2020 and that a new User Guide was being drafted to be released shortly.
MIF296 – Review of the Non-Domestic Customer Access to ECOES
IREG noted the three solutions which had been developed following previous discussions for the Non-Domestic Customer (NDC) ECOES access procedure and to ensure that the process was GDPR compliant. The group were reluctant to agree any solution which placed more requirements on Suppliers. An IREG member advised that they would like to have seen a solution whereby all NDC users of ECOES would be subject to an annual Audit the same as MRA Parties and Third-Party Intermediary (TPI) users have to complete. IREG were advised that this had been considered when discussing solutions internally however it was identified that there were around 1,200 NDC users of ECOES and to conduct even a desk-based audit would require both huge financial and human resource. The Group discussed potential options in the short term which included removing NDC’s access if they had not accessed ECOES in the past year.
The group discussed the next steps for the issue as they were not happy with the three potential solutions including the option for full automation. It was agreed that further investigations should be carried out on the auto deletion of NDC accounts if they had not viewed ECOES within 12 months. A steer on this issue from the MRASCo Security Committee (MSC) would be sought and to present the issue to the MRASCo Executive Committee (MEC) at their next meeting for consideration.
MIF301 – Post Implementation Review of the DTC CP 3554
IREG were advised that the issue identified within MIF301 had been raised at the MRPS Service Management Group (SMG) meeting in December 2019. The Chair informed IREG that the result of these discussions was that the MPRS Service Provider required tangible real-life examples of the issues identified within the MIF and the subsequent Request for Information (RFI) in order to further investigate potential MPRS processing improvements. IREG agreed that the RFI questions to parties would be re-issued and also request parties respond with real life examples of the issues.
MIF305 – Change Management for MPAS Validation Procedures
The Chair asked if any of the Distribution Business representatives had attended the December 2019 MPRS SMG meeting. It was advised that none of the DNO IREG members attended and as such discussions on this issue were deferred to the next meeting.
MIF306 – MAP08 – Missing/Disputed Read Process Issues
IREG were advised that a paper would be taken to the MEC and MRASCo Board meetings to be held on the 28th January 2020 requesting a steer and funding for the training. IREG would be updated on their decision at their next meeting.
MIF 307 – Incorrect Designation for Domestic Elective Half Hourly MPANs in ECOES
The Chair advised that the Proposer of MIF307 had sent their apologies for the meeting and as such the MIF would be deferred to the next meeting.
MIF308 – Prepayment Clearance Volumes
IREG noted the annual Unallocated Transaction report which had been provided to the group prior to the meeting. The Proposer advised that from the data presented it did not look as if the D0312 Data Flow change had any unforeseen impact on the figure. To further validate this a request was made to provide figures for the Clearance and the Volume for the next meeting to allow for full analysis.
MIF309 – Related MPAN Objection
IREG were advised that investigations had taken place in respect of the 3A and 3B reports to identify which Suppliers were taking on MPANs without all of the Related ones. 53 Suppliers had been found to have been doing this and all of those were contacted with a message, reminding them of their obligations within the MRA and to the Switching Programme along with examples of the problem MPANs. It was highlighted that the majority of the Suppliers in question had responded advising that they had resolved the issues with the MPANs and had put internal procedures in place to prevent the issue happening again.
The Proposer asked how the reports were created for the Related MPANs and advised that it was an issue, that it would be good to monitor through the Switching Programme. An advisor highlighted that building the report had been a very manual process and to generate this monthly would require a formal request. It was agreed that some preliminary investigations into the cost to Industry of producing this report on a monthly basis.
Safe Guarding Working Group (SCWG) Update
The SCWG representative advised that the D0225 Data Flow changes would be implemented on 27th February 2020. It was highlighted that at the previous SCWG meeting there were discussions around a Schedule Performance Index (SPI) as a legal basis for sharing data having been held amongst a small number of energy companies and legal views sought internally. These discussions had concluded that although there is merit in considering this at a future date. The current project for sharing data between Suppliers and DNO’s and DNO’s and Water Sector would remain requiring explicit consent to share PSR data. The item was passed to the DPO group who would be considering all GDPR implications around data and data sharing. It was advised that the next DPO meeting will be held on 15th January 2020.
IREG noted that the final draft of the DPIA, covering changes in the PSR process as well as sharing data with water companies has been issued for SCWG agreement. The “PSR Needs Codes training and reference framework” which is a training aid will be sent out to SCWG members prior to the PSR Water Share project go live in April 2020. A copy will be held on the ENA website and will be shared with Water UK. In addition, a copy would been made available to IREG members. It is not a rules and obligations document, just a best practice aid to create internal training for staff to assist with customer experience.
Secure Data Exchange Portal (SDEP) User Requirement Specification (URS)
IREG noted the amendments to the SDEP User Requirement Specification (URS) which had been circulated as a change marked document prior to the meeting. It was advised that following an action at the December 2019 meeting, a section had been added for the for bulk uploads process, where the file size was set at 2MB. IREG were informed that after 30 Days, messages on the SDEP would be automatically archived and if there had been no action taken on the archived message for additional 30 Days they would be automatically deleted.
The group discussed the Bespoke Data Items which had been added to section 4.1 of the SDEP URS. It was advised that these had been added based on the Data Items listed in all the current MRA Agreed Procedures (MAPs) and SPAA Schedules. It was agreed that MPxN would be added to all Use Cases as an optional field so that parties have the option to use both the Search Tag and the Bespoke Data Item. IREG agreed that a Data Flow File ID would be added to all escalations for Bespoke Data Items. A party advised that it would be useful to add the Data Flow sent date to the Disconnections Use Case Bespoke Items, IREG agreed for this to be added.
The group discussed the Misdirected Payments Use Case, with a party advising that it should include the Claim Start and the Claim End Date. IREG agreed that the Use Case should include Bespoke Data Items for Meter Serial Number (MSN), MPAN, Claim Start Date, Claim End Date. IREG also agreed to add a Use Case for Registration Escalations.
IREG were informed that there would be preliminary training material and User Guides based on the UAT version of the SDEP, so there may be slight changes to the User Guides, however due to the size of the service it was to try and allow for staff training as early as possible. An advisor highlighted that considerations were under discussion regarding releasing the SDEP 7 Working Days (WDs) prior to the solution becoming mandated to allow parties to get used to using the SDEP. It was advised that further details of the User Guides release would be discussed at the January 2020 MRASCo Executive Committee (MEC) meeting.
The next IREG meeting is scheduled for 12th February 2020.