Annual Report 2012
BT Group plc
Book 1.indb 1
21/05/2012 23:52
2
The Equality of Access Board
was established on 1 November
2005 as part of the Undertakings
offered by BT to Ofcom. We are
a committee of the BT Group plc
Board although our structure,
membership and obligations to
Ofcom make us unique.
Look out for…
00
Further reading
Further reading online
PwC assurance
The Equality of Access Board is a committee of the BT Group plc Board (“BT”). BT Group plc is a public limited company
registered in England and Wales. This is the EAB Annual Report for the period ended 31 March 2012. Unless otherwise
stated all facts, statistics, events or developments are correct to the nearest practical date before 15 May 2012. The
opinions expressed are those of the EAB, not necessarily those of BT Group plc. The EAB Annual Report is a requirement of
the Undertakings given to Ofcom by BT pursuant to the Enterprise Act 2002.
PricewaterhouseCoopers LLP provides independent assurance on key elements of the EAB’s Annual Report and these
are indicated by the following symbol throughout the report. For the 2012 report PwC has adjusted the scope of its
assurance to reflect the fact that many of the major milestones have passed and as a result the report focuses more on the
results of reviews and monitoring activity. PwC continues to provide assurance over the completeness and accuracy of the
compilation of the summaries of the EAB’s conclusions, the compilation of product KPI information and the consistency
of these EAB conclusions with the evidence gathered on its behalf by the EAO including the underlying management
information of BT.
‘2012’ refers to the financial year running from 1 April 2011 to 31 March 2012.
Book 1.indb 2
21/05/2012 23:52
Review of the year
6
13
Assessing milestone delivery
An update on BT’s delivery of the systems
separation milestones.
Risk-based approach to ongoing compliance
Our assessment of the top risks to BT’s
delivery of the Undertakings during 2012.
4
Chairman’s introduction – a welcome
from the new EAB Chairman,
Phil Hodkinson
5
The EAB in brief – who we are and how
we work
6
Assessing milestone delivery – an update
on BT’s delivery of the systems separation
milestones
9
Investigating breaches – an analysis of
breaches of the Undertakings
10 Understanding industry concerns – the
results of our industry survey, issues
management and complaints-handling
processes
13 Risk-based approach to ongoing
compliance – our assessment of the top
risks to BT’s delivery of the Undertakings
during 2012
16 Outlook for 2013
Review of the year
3
Contents
Who we are
00
20
Our view on governance of the Undertakings
We are asked to give our views on how well
the governance arrangements supporting the
Undertakings are functioning. This section includes
a description of these arrangements and our opinion
on their effectiveness.
18 The EAB
19 The EAO and EAB Secretariat
20 Monitoring, reporting and advising
20 Stakeholder engagement
20 Our view on our governance and
resourcing
21 Wider governance of the Undertakings
Who we are
18
The EAB
Find out more details about our monitoring
processes, our work with stakeholders and more
information about our Board members.
26
28
Book 1.indb 3
Behavioural dashboard
Our dashboard includes measures such as training
completions and customer satisfaction surveys. It
provides a useful way of assessing how engaged BT
employees are with the delivery of the Undertakings.
Product KPIs
We assess key performance indicators published by
BT showing the performance of BT’s Equivalence of
Input products. These are a useful way of comparing
the services provided to communications providers
within and outside of BT.
22 Delivery of key milestones
to date
23 Systems separation obligations
25 NGA monitoring themes
26 Behavioural dashboard
28 Product KPIs
31 Comparative performance charts
33 PwC’s assurance opinion
35 Glossary
Undertakings status indicators
Undertakings status indicators
22/05/2012 00:32
4
Review of the year
Chairman’s introduction
In this context, the EAB is particularly keen
to ensure that the company’s commitment to
appropriate behaviour, for example via regular
training and performance monitoring, is
maintained. Our ‘behavioural dashboard’ gives
us a good indication of how BT employees
are behaving, for example when speaking to
customers, but this alone will not guarantee
compliance with the Undertakings.
Phil Hodkinson
EAB Chairman
The EAB must remain
alert to stakeholders’
perceptions of BT’s
compliance with the
Undertakings.
This is my first annual report as EAB Chairman
and I’m looking forward to building on the
strong foundations that Carl Symon, the
outgoing chairman, helped put in place.
On behalf of myself and the other members
of the EAB, we’d like to thank Carl for his
commendable leadership of the EAB during its
formation and the initial period of delivery of
the Undertakings.
More than six years after the Undertakings
were agreed and with many major milestones
achieved, some might think that it would be
tempting to take the foot off the pedal when it
comes to monitoring BT’s ongoing compliance.
Yet as time goes by, and as new products and
services are introduced, the need to maintain a
clear focus on compliance, and in particular BT
upholding the ‘spirit’ as well the ‘letter’ of the
Undertakings, is paramount.
Book 1.indb 4
Recent systems-related and information
sharing breaches have demonstrated that
senior management focus within BT also
continues to be important if compliance is to
remain embedded within the organisation.
The company has committed to getting to
the root causes of these recent breaches and
the proactive review of all major systems that
is currently underway is expected to identify
a number of areas of concern which, left
unaddressed might otherwise lead to more
serious breaches in the future.
We welcome this proactive review and
the remedial actions resulting from recent
investigations. Both will enable the company
to address the underlying causes so that
recurring breaches become a rare event.
When a new issue is uncovered, the EAB
offers advice and guidance at an early stage
to help BT remedy matters, but if an incident
subsequently recurs we are naturally inclined
to see it in a more serious and critical light.
Another important aspect of the work of
the EAB is our focus on and understanding
of the various interests of key stakeholders.
I’m looking forward to maintaining and
indeed strengthening our engagement in this
respect. My first meeting as EAB Chairman
proved to be an ideal opportunity to do so,
with presentations from Ofcom, the Office
of the Telecommunications Adjudicator
(OTA2) and from the Chief Executive of BT.
Alongside this, we also reviewed the findings
of the recent industry survey conducted by
the Equality of Access Office (EAO). A mix of
large and small communications providers,
and industry associations, contributed to the
survey, the results of which will be factored
into our ongoing monitoring and compliance
programmes.
In my first months in the role, it is already
evident to me that the EAB must remain
alert to stakeholders’ perceptions of BT’s
compliance with the Undertakings as closely
as we do the reality. Whilst it is understandable
that these perceptions will differ from time
to time, ultimately it will be in none of our
stakeholders’ interests if opinions diverge
too far or for too long. Like all stakeholders,
the EAB has an important role to play in
understanding where differences of opinion
may exist and what actions might be taken to
narrow those differences.
Also, the EAB as a whole is mindful that
whilst the Undertakings have served a very
useful purpose so far, for example helping to
achieve a highly competitive and innovative
marketplace in the UK by international
standards, their relevance going forward is
already being called into question by the
introduction of new products and services
not envisaged when the Undertakings were
formulated. We are committed to keeping
abreast of market developments, for example
the roll-out of Next Generation Access, so that
we can assess equivalence when called upon.
Equally, we are also conscious that it is not
the role of the EAB to propose or determine
policy in respect of matters that fall outside of
the current Undertakings. That is a matter for
Ofcom and the industry as a whole.
That said, I am in no doubt of the central role
that the Undertakings will continue to have in
shaping the future of the UK telecoms industry
and thus the ongoing importance of the role
of the EAB. I’m confident that we remain up to
the task and in saying that would like to thank
my fellow EAB members and colleagues in the
EAO for the skill, care and commitment that
they continue to bring to their roles.
Read more about the findings of
the EAO's industry survey on page
13
21/05/2012 23:52
Review of the year
5
Who we are
What we do
–– The Equality of Access Board, comprising a majority of
independent members and the Equality of Access Office
–– Monitor BT’s compliance with the Undertakings,
including its delivery of major milestones and
ongoing compliance
–– Established on 1 November 2005 as part of
Undertakings offered by BT to Ofcom
–– Oversight of the whole of BT in respect of compliance
with the Undertakings
Read more on page
How we work
Reporting
Recommendations to BT
Annual review of
compliance reported
publicly
Monitoring
Formal milestone
delivery programme
–– Report on BT’s progress annually
18
Read more on page
20
Our stakeholders
Advising
Guidance for Ofcom
–– Advise BT on areas where it needs to improve its
compliance with the Undertakings
Review of the year
The EAB in brief
Industry
Communications providers and
industry associations
Regular reports to
BT plc Board
BT
Bulletin for industry
All of BT’s lines of business with a
particular focus on Openreach
Ongoing compliance
Risk-based compliance
Breaches, complaints
and issues
Behavioural measures
Product key performance
indicators
Stakeholder
feedback
CPs
OTA2
Ofcom
BT
Ofcom
Staff and senior management
2012 in brief
Monitoring systems milestone delivery
BT has made substantial progress towards the delivery of key systems implementation targets but
there are risks around the delivery of some future milestones and some aspects of ongoing compliance.
Concerns over information sharing
There were a number of breaches involving non-compliant information sharing and BT
is taking action to address this as part of its systems compliance review.
Equivalence on the agenda
The findings of our ‘Quick Checks’ process show that BT is offering equivalent products
and services to communications providers but there were some non-compliant incidents.
Focus on processes
CPs remained concerned about the functioning of Openreach’s Statement of
Requirements and exchange space allocation processes.
Book 1.indb 5
Read more
on page
6
Read more
on page
10
Read more
on page
12
Read more
on page
13
21/05/2012 23:52
6
Review of the year
Review of the year
Our focus this year has been on better understanding current industry
issues and getting to the heart of whether BT continues to comply with
the Undertakings six and a half years after they were agreed.
To gain this insight we work in a number of different ways and we
use our findings to shape our future monitoring programme. In this
section we report on our findings against each of our activity areas
and also give our views on potential future developments and risks in
‘Outlook for 2013’ on p16.
Assessing milestone delivery
We look at major Undertakings’
milestones due during 2012 and
consider BT’s delivery record. Further
details on our earlier monitoring of
milestone delivery can also be found
in the ‘Undertakings status indicators’
section from page 22 onwards.
Investigating breaches
We give details of breaches of the
Undertakings during the year,
including our analysis of the impact
and root causes.
Understanding
industry concerns
Read more
on page
6
Assessing milestone delivery
In 2012 there was one large Undertakings’ milestone due and there
were a number of voluntary interim milestones and ongoing obligations
which needed to be delivered. The largest set of obligations outstanding
was that involving systems separation.
Systems separation
BT operates a wide range of IT systems and these are subject to
Undertakings’ obligations depending on where they sit in the company.
BT had to deliver a range of informal systems milestones during 2012 as
well as fulfilling a range of other obligations. This was to ensure that BT
made significant progress with systems separation and the migration of
business customers by 2014.
Read more
on page
9
Systems separation plays an important role in underpinning BT’s
compliance with the Undertakings. There are a number of different
systems obligations with which BT must comply. For example, BT has
an obligation to separate the systems used by Openreach from those
used by the rest of BT so that confidential or commercially sensitive
information cannot be shared inappropriately across organisational
boundaries.
BT must implement different levels of separation for each type of
system including for Operational Support Systems (OSS), Management
Information Systems (MIS) and for some other types of systems. It must
also move customer records across to newly separated systems.
Read more
on page
10
We consider complaints and issues
raised by industry and give details of
our investigations and conclusions.
A variation to the Undertakings in September 2009 saw some systems
separation obligations delayed and others cancelled. In return BT agreed
to a number of new voluntary obligations including a range of business
systems stack interim milestones. This resulted in the delivery schedule
shown on p8.
Delivery progress in 2012
Risk-based approach
to ongoing compliance
Read more
on page
13
We describe the key Undertakings’
compliance risks and actions taken
to mitigate them.
Outlook for 2013
We give our views on forwardlooking risks and forthcoming
Undertakings’ obligations.
Book 1.indb 6
Read more
on page
16
There was one systems separation milestone due in 2012 and there
were a number of informal milestones which BT had committed to
deliver ahead of full physical separation.
Systems stack for business customers
The Undertakings require that 90% of customer records should be held
on separate systems by December 2012. Achieving the 90% target
required the introduction of a new system stack for business customers.
A system stack for business customers is a collection of inter-related
systems which allow BT’s business customers to be served equivalently.
During calendar year 2011 BT was due to deliver two of these interim
targets towards building this new business systems stack:
1. Start operational trial of stack
30 April 2010
2. Initial live deployment on stack
31 December 2010
3. Migration trial starts
31 March 2011
4. Volume migration starts
31 December 2011
21/05/2012 23:52
Review of the year
The fourth and final UK business systems stack milestone (due
31 December 2011) required BT to begin customer migrations at
volume. In December 2011 BT indicated that it had achieved over
15,000 migrations and had also agreed with Ofcom the detailed success
criteria for the milestone. Our validation found that BT had delivered the
milestone against these criteria.
In our view the 90% customer side records separation target (due
December 2012) remains at significant risk. To meet this separation
target, BT needs to deliver the UK business system stack and then
populate it with a sufficient number of customers. This depends on a
highly challenging plan that rapidly accelerates the weekly migration
volumes and there appears to be little contingency in the event of
any unforeseen problems. We are concerned that the success rate for
migrations is lower than anticipated and that this could impact BT's
ability to achieve the 90% separation target. For these reasons we
believe the milestone is at significant risk and we continue to keep it
under close review.
Despite delivering its systems
obligations compliantly, BT risks
not meeting key separation and
migration milestones in 2014 if it
does not meet the interim targets
in December 2012.
Equivalence of Inputs and customer side record targets
BT’s Installed Base Migration Complete (IBMC) dates were removed
as part of the 2009 variation to the Undertakings with the exception
of a 70% interim target for Wholesale Line Rental (WLR3) analogue
telephony. Instead a series of progressive targets was established for
measuring the proportion of end users consuming the Equivalence of
Inputs (EoI) variant of certain key products. By 31 December 2012 the
second progressive target requires BT to extend that number of end
users consuming the EoI variant of certain products to 95%. We are
satisfied that BT is on track to deliver this milestone as a result of its
progress in delivering the interim targets.
Book 1.indb 7
By 31 December 2011 BT had to advise Ofcom of the further extended
target it expects to achieve by 30 June 2014. BT informed Ofcom that
it anticipates migrating a minimum of 97% of EoI lines and between
92% and 94% of customer side records. While the projected target for
the migration of customer side records is lower than projected initially,
Ofcom said that it: “welcomed BT’s continued activities to meet its
remaining commitments and the progress BT has made to meet the
December 2012 milestones. It is reassuring that BT businesses are fully
engaged with this process and we hope that the inclusion of automated
capabilities to speed up migrations will contribute to achieving a high
pace of migration. While acknowledging the percentage migrations
[BT has] advised for 2014, we would like to take this opportunity to
emphasise the importance of BT aiming to migrate 100% of business
customers, in so far as this is possible, in order to fully implement
functional separation as envisaged by the Undertakings.”
Review of the year
In respect of the third milestone, the EAB found that BT had
started the migration trial by 31 March 2011. However not all of
the success criteria had been achieved by the due date. We concluded
that the fundamental parts of the interim milestone had been achieved
and Ofcom agreed with this position.
7
Some industry stakeholders have told us that they are concerned
about the delay to the delivery of the systems milestones following the
variation to the Undertakings in 2009. Some felt that BT had gained an
unfair advantage by staying on legacy systems for longer. We monitor
whether BT is gaining an unfair advantage by staying on the ‘Classic’
product variant rather than moving to WLR3 through the ‘Comparative
performance charts’ (see p31 for more information). These charts
have typically shown that there is no incentive for BT to stay on legacy
products for longer than non-BT CPs. However, we also investigated
an issue raised by a CP on this subject which was found to be a nontrivial breach of the Undertakings (see p9, row five of non-trivial
breach table). We will continue to assess the impact of BT’s migration
programme on business customers.
Other systems obligations
There were also other systems-related obligations due during 2012. As
required by the Undertakings, we commissioned a bi-annual external
audit undertaken by PwC of user access controls for 19 systems. PwC
completed the audit and found that BT was compliant.
We also provided Ofcom with our third report on those systems listed
in Annex 6 of the Undertakings, which are referred to as ‘core-hybrid’
systems. These are 11 OSS which it was agreed could have continued
shared access by both Openreach and the rest of BT because they deal
with operational network elements. Unlike other OSS there is only a
requirement to have access controls rather than full systems separation.
We carry out checks every six months to monitor access to these systems
by BT employees and we report our findings to Ofcom. We found that
only limited numbers of non-Openreach employees access the system
and only where there is a demonstrable operational need.
In return for the 2009 variation to the Undertakings, Openreach
agreed that it would deliver a voluntary range of obligations known
as the Openreach Industry Commitments (OICs). At the time this
report was published, Openreach reported that 19 of the 23 OICs had
been delivered. These include phased initial releases of the Ethernet
Strategic Transformation product which supports the Ethernet Access
Direct (EAD) and Ethernet Backhaul Direct (EBD) products with further
21/05/2012 23:52
8
Review of the year
Timeline of major systems obligations from 2009 onwards
Jan
Feb
Mar
Apr
May
June
July
Aug
Sept
Oct
Nov
Dec
2009
30 September 2009
–– 18 month Openreach
roadmap published
describing when
commitments
to be delivered
31 December 2009
The EAB must ensure any
new OSS is compliant –
recurring annual check
–– Change control process
published.
2010
30 June 2010
31 Dec 2010
Business systems stack
initial live deployment
(non-binding)
–– External audit of user access controls
–– Implement user access controls for OSS listed
in Annex 6
31 March 2010
Openreach must update
the systems roadmap
30 April 2010
Business
systems stack
operational
trial starts
(non-binding)
–– Implement physically separate access and
user access controls for some BT employees
–– OSS physical separation
–– The EAB to perform quarterly checks of access
to OSS listed in Annex 6 from this date onwards
–– At least 90% of BT’s relevant installed end-user
base shall be migrated so that the products that
this base purchases... do so on an EoI basis
–– MIS level 2 separation
–– Non-OSS and non-MIS level 2 separation
2011
31 December 2011
31 March 2011
Business systems stack
trial migrations begin
(non-binding)
–– Advise Ofcom of
percentage migrations and
customer side records to be
achieved by 30 June 2014
–– Business systems stack
volume migrations begin
(non-binding)
2012
31 December 2012
–– 95% of installed
end-users migrated
–– 90% customer side records
level 2 systems separation
30 June 2012
–– Ensure any new OSS
is compliant – recurring
annual check.
–– Audit of customer side records
2014
30 June 2014
–– BT to achieve further increased percentage
migrations of customer side records and migration
to Eol products as previously notified to Ofcom by
31 December 2011
Jan
Book 1.indb 8
Feb
Mar
Apr
May
June
July
Aug
Sept
Oct
Nov
Dec
21/05/2012 23:52
Review of the year
Systems compliance review
In 2012 BT commenced a review of the compliance status of systems
across the company. We welcomed this review following our concerns
about the number of breaches involving non-compliant information
sharing. The review covered more than 2,000 systems and BT
reported to us that the majority of these were compliant at the time of
assessment.
BT reported that its initial findings had resulted in it doing further
investigations into 2% of the systems which appear to be at risk of not
being compliant with the Undertakings. At the time this report was
published it was looking into these in more detail.
We will assess the findings of BT’s review and conclude more fully in
our 2013 Annual Report. In the meantime we are satisfied that BT has
worked proactively to identify incidences of non-compliance which may
not have been uncovered without the review. We welcome steps the
company is planning to put in place to help to avoid similar incidents
taking place in future.
In 2012 there were seven breach cases which the EAB determined
non‑trivial:
Description
Remedy
1
Failure to maintain effective user
access controls and inappropriate
information sharing within a data
warehouse (a data processing
engine which manages billing
information across BT).
BT corrected the data streams
so that they were automatically
directed to Openreach. The
access controls for the system
were also reviewed and this
breach was closed.
2
Failure to apply effective user
access controls which allowed
BT Wholesale information to
be placed on a system without
adequate controls in place.
User access controls were
implemented and access was
restricted on the system.
Briefings were issued throughout
the business. The breach was
closed.
3
Since 2005 BT CPs had been able
to access information on major
incidents and faults via a system
which was not available to nonBT CPs. Details of the incidents
would have been made available
to non-BT CPs during the normal
course of business. The system
was not classified as high risk
initially and was not included in
compliance monitoring.
Systems access was withdrawn
for all people with inappropriate
access and communications
around usage were improved.
BT also made improvements
to access controls and system
governance. The EAB concluded
that this closed the breach.
4
An anonymous Openreach
employee complained to Ofcom
that Openreach was unfairly
prioritising frames work for a
particular customer. This meant
that Openreach did not provide
the same product or service to all
CPs on the same timescales.
The briefing to engineers to
prioritise frames work was
withdrawn and the EAB agreed
that this closed the breach.
5
A CP in Northern Ireland – which
had won business customers
from BT Retail – had trouble
migrating them from BT Retail’s
Classic product set to WLR3.
This problem also affected other
non-BT CPs moving customers
from Classic to WLR3 but it did
not affect BT Retail.
The issue will not be resolved fully
until BT has migrated all users to
the UK business systems stack.
The EAB recommended that
in the interim period BT makes
improvements to the migrations
process and to the service level
agreements that it offers.
6
BT Retail participated in weekly
calls with BT Operate and BT
Wholesale which included
information on future planned
engineering works which was not
available to other CPs.
BT Retail is no longer included on
the call and planned engineering
work information is notified to
all CPs at the same time. The EAB
concluded that this closed the
breach.
7
BT reported a failure to apply
adequate user access controls on
an OSS which records BT’s lines.
BT’s remedial actions – including
changing access rights for some
employees – were under review
by the EAO at the time this report
was published.
Our overall view on systems
The programme to deliver compliant systems is central to BT’s delivery
of the rest of its formal commitments and ongoing compliance with the
Undertakings. Until the last of these obligations is delivered in 2014,
checking that BT has delivered its systems obligations will remain one
of the highest priorities in our monitoring programme. Once these
deadlines have passed we will continue to monitor usage on an ongoing
basis.
We are satisfied that BT is committed to delivering its remaining systems
separation milestones and is also putting in place the correct measures
to ensure that its systems and their users continue to comply with the
Undertakings. We will assess the findings of the systems compliance
programme in 2013 and we will also monitor closely the company’s
progress towards the milestones due in 2014.
Investigating breaches
The EAB assesses any non-compliance with the Undertakings and
seeks to understand the impact that this might have on CPs and on BT’s
business. In particular, we evaluate breaches reported to us by BT as well
as those identified through our own investigative work, including issues
raised to us by CPs and through our formal complaints process.
The Undertakings place obligations on BT and the EAB to identify and
report on breach cases. Following a breach notification from BT, the
EAO carries out its own investigation and the EAB determines its view
on the case and its significance (non-trivial or trivial). It also considers
the appropriateness of BT’s proposed remedial actions. Alternatively the
EAO can report breaches to the EAB which it has identified during its
own investigations.
The EAB can also recommend additional actions to mitigate the
impact of a breach – particularly when a remedial action cannot be
implemented immediately as it requires the development of a new
process or systems solution. These are known as ‘consequential’ actions
and are also designed to minimise the risk of similar breaches occurring
in the future.
Book 1.indb 9
Review of the year
planned releases scheduled. The OTA2 works with Openreach and
industry to facilitate the delivery of the OICs.
9
21/05/2012 23:52
10
Review of the year
There were five breach cases which the EAB determined trivial:
Description
Remedy
8
Inappropriate and unintended
information sharing for three
days about the implementation
of mobile termination rates with
the Value Added Network team
within BT Wholesale.
A targeted scheme of refresher
training took place in BT
Wholesale and the EAB closed
the breach.
9
Inadvertent sharing of
information within the Integrated
Services Digital Network
Automation Tool Management
system, which was used for
diagnostic testing in the ISDN30
repair process.
User access controls were
implemented and the EAB closed
the breach.
Inappropriate sharing of
Customer Confidential
Information (CCI) as part of an
exercise to resolve which lines of
business owned circuits in some
data centres.
The information was deleted and
an updated version was sent out.
The EAB agreed that the remedial
actions had been completed and
this breach case could be closed.
11
Data on incoming and outgoing
call traffic was provided to BT
CPs and non-BT CPs via different
systems.
BT changed the design of the
system to resolve the issue and
the EAB closed the breach.
12
Openreach shared a presentation
containing Commercial
Information (CI) with BT Global
Services employees who were not
entitled to see it.
The EAB recommended that
Openreach and BT Global
Services review their governance
arrangements to ensure that
CI is clearly marked and that
document distribution lists are
carefully monitored.
10
There was also one trivial breach reported previously, the remedy for
which was ongoing from 2011:
13
Description
Remedy
Level Two systems separation was
not put in place for an Openreach
call-centre agent performance
monitoring system containing
CI/CCI.
This breach will be ongoing until
the system changes in 2013 and
the EAB continues to monitor
ongoing compliance with user
access controls.
Seven further potential breaches were under investigation and one
investigation was further progressed but had not yet concluded at the
time this report was published. We will report on the outcome in our
regular bulletin and in the 2013 EAB Annual Report.
Under the breach process, cases which are very minor are not fully
investigated but details of the case and the rationale for not conducting
the full factual and legal review are reported to the EAB. These are
classified as discretion cases. In 2012 the EAB exercised its discretion
over matters such as a case where an employee in BT Innovate and
Design shared information with a BT Wholesale employee regarding the
timing of an Openreach network upgrade. The timing of the upgrade
was already known to industry and was therefore unlikely to have any
impact.
Some of the breaches reported to the EAB during 2012 related to
systems and inappropriate information sharing. This was almost
certainly because greater attention has been placed on evaluating
Book 1.indb 10
BT’s systems during the past few years as a result of the large
number of formal and voluntary systems milestones included in the
Undertakings. As a result of the breaches relating to inappropriate
sharing of information, we made recommendations to BT that it
reinforces messaging on this topic so that employees remain familiar
with information sharing boundaries in the company. We also expressed
our concern at the decline in the number of Undertakings’ training
completions shown on our ‘Behavioural dashboard’ on p26 as this
training can cover topics such as how to share information compliantly.
BT reported to us that the Undertakings were not relevant to some of
the people invited to complete the training, for example third party
contractors working outside of BT sites. It said that this accounted for
the lower completion rate in some areas. We will continue to maintain
our focus on this area during 2013.
Other breaches related to CPs not receiving equivalent services from
BT. Some of these instances of BT CPs potentially receiving preferential
treatment were the result of systems errors or technical faults but
others were the result of employee behaviour. We note that some of
these breaches did not appear to have a significant impact for CPs
but nevertheless we have urged BT to maintain its focus on offering
equivalent services.
Following our feedback in 2011 that BT was not processing breaches as
quickly as it could, the company changed its process so that it informed
the EAO earlier of any potential breaches, was better at identifying
common themes and provided early notice of any long-running or
complex investigations. The EAB also revised its breaches process to
ensure that it fitted in with the BT process and would allow for ad-hoc
meetings to be convened to deal with urgent cases.
Our view on breaches
There were a higher number of breaches in 2012 compared with the
previous year, although the overall number remains low. This increased
number was partly due to BT making a greater effort to identify and
remedy non-compliance in some areas. However in the coming year
the EAB will continue to pay close attention to those cases where
BT employees appeared to have a low level of awareness about the
Undertakings and the potential consequences of their actions.
We welcome BT’s proactive review of systems compliance on which we
will report further in our 2013 Annual Report. This review may help to
resolve some issues which could have an impact on non-BT CPs and
their end users and may prevent future breaches. We would also like
BT to maintain its focus on ongoing compliance across the whole of
the Undertakings to ensure that employee behaviour does not result in
further non-compliant incidents.
Understanding industry concerns
We keep in regular contact with non-BT CPs and industry associations
and hear views on a wide range of issues through both formal and
informal channels. This includes formal complaints from CPs and
informal feedback via our issues management process. In 2012 we
also surveyed the industry to hear their views on whether BT was still
complying with the Undertakings six and a half years after they were
first agreed.
Complaints to the EAB
There was only one complaint investigated during 2012. In early
2011 the EAB received a complaint from a CP which wished to remain
anonymous on pricing for the EAD product. The complainant flagged
potential non-equivalent behaviour by BT Global Services and
Openreach in relation to a bid by BT Global Services. One of the key
allegations made in the complaint was that BT Global Services had prior
knowledge of the launch of a term discount for Openreach’s EAD
product which it then used to gain a competitive advantage in the bid.
21/05/2012 23:52
Review of the year
11
Complaints to BT
As in previous years the EAB continued to receive regular reports of the
complaints to BT from CPs relating to the Undertakings. BT received 15
complaints up to the end of March 2012 which is slightly less than the
17 received in the previous year. The charts below show the complaint
themes which were most common and the number of complaints
upheld:
Chart 1
Complaint themes
1
Equivalence
Process
2
Behaviour
Spirit
9
3
One case alleged that Openreach had withdrawn calling line identity
information from a report containing calls data, and that BT Retail still
received this information. Openreach investigated the allegation and
found that the information BT Retail receives is related to ‘classic’ PSTN
lines rather than WLR3 and that a report containing WLR3 data was
made available to all CPs in June 2011. The CP was advised and no
further action was requested.
One case alleged that BT was allowing deliberate early life failures on
analogue and digital lines for non-BT CPs which led the customer to
think that the CP was at fault. Openreach investigated the complaint
and visited the CP in question and no further action was taken. We have
requested further evidence that the complainant was satisfied that the
complaint could be closed.
One case alleged that BT CPs may have been aware of a special offer
that Openreach notified in November 2011, in advance of notification
to industry. Openreach investigated the complaint and found that BT
CPs had not received notification of the special offer in advance of
industry. The CP was advised and no further action was requested.
Process
One case alleged that Openreach had transferred a CP end user to BT
without permission – so-called ‘slamming’. An Openreach investigation
found that the losing CP had received the appropriate notification of a
pending transfer and did not act upon it.
Source: BT
Chart 2
Complaints upheld/not upheld
Upheld
6
Not upheld
9
Source: BT
A more detailed description of the complaints received under each
theme can be found below:
Equivalence
Four of the complaints received alleged that Openreach had supplied
BT CPs with an earlier service provision than that offered to the
complainant. Openreach investigated these and in one case it upheld
the complaint. In this case, a CP’s order had been delayed in the system
due to a technical error. It did not uphold the other three cases as it
found that in one case a CP had not placed an order correctly and this
had not been completed, in another case provision lead times had
improved following the introduction of additional resource and in the
third case, extra appointment slots had been added for all CPs and BT
had picked one of these.
Book 1.indb 11
Two cases alleged that CP end users had been transferred to BT Retail
by Openreach before the standard 10 day transfer window had elapsed.
Following an Openreach investigation, both allegations were found to
be true. This led to disciplinary action being taken and the Openreach
team concerned received further training in the correct process. We
have requested further details on this case in order to gain assurance
that these are isolated incidents.
Review of the year
The other key allegation was that BT Global Services and Openreach had
not followed the equivalent process for calculating Excess Construction
Charges in relation to the bid. In July 2011, following a detailed
investigation, the EAB decided not to uphold the complaint as the
evidence indicated that neither of the actions raised by the complainant
had taken place.
One case alleged that Openreach had made certain telephone numbers
available which should not have been. Openreach investigated the
allegation and found that the numbers had become available due to an
Openreach advisor’s taking incorrect action. The teams concerned were
re-briefed to ensure the correct process was followed.
One case alleged that a piece of equipment had been incorrectly
annotated with a BT Retail fault reporting telephone number.
Openreach found that the number in question should not have been
shown on a circuit which had been installed on behalf of one of
Openreach’s CP customers. Openreach plans to issue a briefing to its
engineering community informing it of the correct practice.
Behaviour
Two cases related to allegations of inappropriate comments made by
Openreach employees whilst on site at customer premises. In both cases
the Openreach employee denied making the comments and no further
action was taken.
Spirit
One case was received by BT Northern Ireland (BTNI) regarding
information that a CP alleged had been inappropriately shared by
the upstream part of the organisation with the downstream part. BT
investigated the allegation and found that there was inappropriate
information shared within BTNI. However there was no breach of the
Undertakings as they do not apply in the same way in Northern Ireland.
Nonetheless, BT treated this case as non-compliance with the spirit of
the Undertakings.
As in previous years the number of formal complaints received by the
EAB remains very low. The number of Undertakings related complaints
received by BT also remains just below the same low level as last year.
21/05/2012 23:52
Review of the year
12
Where appropriate, we have sought further assurance from BT that
complaints are being correctly identified and reported to the EAB.
Issues management
We look into issues raised informally by key stakeholders including BT,
non-BT CPs, Ofcom and the OTA2 as part of our ‘Quick Checks’ process.
The process allows us to record and track issues and to assess rapidly
whether they need more detailed, formal investigation.
In 2012 we investigated 26 issues. Common themes are shown in the
chart below:
Chart 3
EAO Quick Checks 2011-2012 themed areas
1
1
1
Equivalence of Inputs
8
2
Governance
NGA
Copper
2
Space and power
Ethernet
Information sharing
5
6
One ongoing area of concern is
around the development of Ethernet
products. We continue to pay close
attention to how this product
functions although we have not
identified any non-compliant
incidents.
Openreach Statement
of Requirements process
Source: EAO
The theme of equivalence occurred the most in our issues management
process – and this was also reflected in the formal breaches process
(see p9 for more information). We looked into a number of issues
concerning equivalence including whether the provision performance
of Openreach’s EAD product was equivalent. We found that BT CPs
often used a value-added project management service which helped
to reduce issues and this service was also available to non-BT CPs but
rarely used. Openreach offered a briefing to CPs to explain the options
available.
In December 2010 Openreach took the decision to restrict pricing
details for Ethernet orders above 1Gb and move to a ‘terms on
application’ approach resulting in less transparency around pricing
and other terms. CPs told us that they were concerned as to whether
the pricing and terms for greater than 1Gb orders were operating
equivalently with pricing detail withheld from general visibility.
In response we assessed a sample of orders supplied by CPs and
reviewed the detail of how the connection and rental pricing had been
determined by Openreach. These were then compared to a sample of
similar BT CP orders and cross-referenced with the Openreach pricing
list to establish whether in each case the pricing details quoted to both
BT CPs and non-BT CPs had been completed equivalently. We were able
to provide industry with assurance that both connection and rental
charges for greater than 1Gb orders had been constructed using system
driven menus and that the process was operating equivalently for BT
CPs and non-BT CPs.
Chart 4
EAO Quick Check reviews 2011 - 2012
We also looked into equivalent access to the Openreach industry portal
following a concern raised by a CP. We found that access controls for the
portal were operating in compliance with the Undertakings.
Two CPs in Northern Ireland raised concerns via our issues management
process. One of the issues raised also applied to CPs operating in the UK
mainland and concerned how Openreach managed order transfers. This
was later investigated via the EAB’s breach process and found to be a
non-trivial breach (see p9, row five of the non-trivial breaches table for
more information).
The other issue raised involved BTNI field technicians mistakenly
treating new orders from the CP as BT Retail orders. BTNI must comply
with the Undertakings while acting as an agent for Openreach and BT
Wholesale. It does not operate on functionally separate lines and not
all of the Undertakings apply in the Province. To resolve the issue BT
Northern Ireland updated its field engineer training and BT made a
systems change to make it clear to technicians which orders related to
each CP.
Book 1.indb 12
No actions
recommended, BT
and CP briefed
3
3
14
6
Actions
recommended to BT
and CP briefed
Actions
recommended to BT
(internal only)
Potential breach
identified
Source: EAO
All Quick Checks completed during 2012 resulted in the EAO’s providing
Undertakings’ compliance assurance/clarification to Ofcom, CPs or the
UK Competitive Telecommunications Association (UKCTA); two resulted
in BT taking corrective action internally; and two resulted in Openreach
running learning sessions with CPs to enable greater understanding
of the areas of concern. One Quick Check influenced the scope of
a scheduled compliance check on space and power and three have
triggered more detailed potential EAB breach investigations.
21/05/2012 23:52
Review of the year
13
Four CPs were satisfied with how the Undertakings had been delivered
but fewer respondents gave a positive response than in a previous
survey we conducted in 2009. Those who did respond recognised that
BT had worked hard to deliver the Undertakings.
A number of common themes emerged from the survey, including
concerns around whether equivalent products were on offer in all
instances, for example one respondent expressed concern that BT CPs
were not required to move to the WLR3 product as quickly as non-BT
CPs and this may lead to advantages in terms of improved functionality.
Some CPs said that they believed that BT was offering equivalent
services while others said that there was an ongoing perception that
the opposite was true – that BT’s downstream business received
preferential treatment from Openreach. The EAB concluded that this
perception relates predominantly to those dissatisfied with service
performance. Balancing service performance with equivalence is an
ongoing issue for some CPs, but service performance falls outside the
remit of the Undertakings and hence is not a matter that the EAB is able
to investigate.
We assess whether there is any evidence of
non-equivalent performance through BT’s
product
key performance indicators. See page
28
Other concerns expressed in the survey stemmed from the development
of NGA products, with some respondents concerned that there had
been a gradual erosion of the principle of equivalence when it came
to NGA. More information on our NGA monitoring programme can be
found on p25.
We have followed up on all of the issues raised in the industry survey
which required further investigation. Industry feedback is vital in
helping us to understand the concerns expressed by different CPs and
also in shaping our future monitoring programme.
We will continue to work with those in industry where we may be able
to assist with the resolution of some of the issues raised. Other points
raised via the survey and the issues management process require wider
consideration and have been fed back to both Ofcom and BT for further
action.
Risk-based approach to ongoing compliance
We take a risk-based approach to assessing BT’s ongoing compliance
with the Undertakings based on the findings of our monitoring work
and on feedback from stakeholders including CPs, Ofcom and BT. We
evaluate our risk register regularly to make sure that our work covers the
most relevant concerns.
During 2011 we identified the following risks relating to BT’s
compliance with the Undertakings and these shaped our monitoring
work during 2012. These are described in summary in the table and
then in more detail below:
Risk
What we did
1.
Openreach’s Statement of
Requirements (SoR) process –
operation and industry confidence.
Review of Openreach’s
SoR process and ongoing
engagement with the OTA2.
2.
Next Generation Access – risk of
launch of non-EoI product(s) and/or
non-compliance with passive input
obligations.
Ongoing reviews and
recommendation made to
Openreach.
3.
Inappropriate information sharing
and issues with user access controls
on systems.
Assessment of breaches and
scheduled assessment of BT’s
systems compliance review.
4.
Systems implementation of the
business systems stack, associated
user access controls and audit of
ongoing compliance of existing OSS
user access controls.
Regular monitoring of BT’s
delivery of the Undertakings.
5.
Ineffective compliance governance
processes (e.g. space and power
allocation).
Review of space and power
allocation process.
Some respondents suggested that it might be time for a formal review
of the Undertakings, stating that the large number of exemption
requests made by BT and agreed by Ofcom had undermined the
credibility of the Undertakings.
Our view on industry concerns
While many CPs are satisfied with the way that the Undertakings are
functioning, there are a number of common and recurring themes
raised via complaints, our issues management process and through the
industry survey. These include:
–– fears that equivalent products and services are not on offer, even
though we have seldom found instances of non-compliance
–– particular concerns around the Ethernet product portfolio – with most
attention focused on the EAD product
–– wider policy concerns around BT’s delivery intent and governance of
the Undertakings
–– a feeling that it may be time to review the Undertakings to check that
they are relevant to current industry issues.
We are aware that there are a number of industry concerns which
remain unresolved over time and that smaller CPs and CPs with
business customers feel that their needs are often overlooked in the
formal consultative processes and working groups. We will continue to
encourage BT to engage with industry on these points and we will look
into issues that relate to the Undertakings as and when they arise.
Book 1.indb 13
Review of the year
Industry survey
Industry opinion shapes our work. In November 2011 we surveyed CPs
and industry associations with a direct interest in the Undertakings to
hear their views on whether BT had fulfilled its Undertakings’ obligations
and whether it was continuing to meet these obligations on an ongoing
basis. Ten CPs and industry associations completed the survey.
In 2012 we explored each of these risks in more detail as described in
the following pages and this has led us to reprioritise the risks as part of
our forward-looking risk register (see p16 for more information).
1. Openreach’s SoR process
The operation of Openreach’s SoR process has been discussed
frequently in the past few years. In 2012 CPs once again drew attention
to the functioning of the process in response to our survey. The SoR
process is the main conduit for CPs to raise requests for new products or
variations to existing products.
In previous years CPs had expressed their concern that requests by nonBT CPs via the process were not as likely to succeed as those raised by BT
CPs. In response to industry feedback Openreach launched a new SoR
process in 2009 which allowed CPs to see SoRs raised by other CPs and
encouraged collaborative working.
We have an ongoing programme to assess the functioning of the SoR
process. Our reviews in previous years concluded that the process
21/05/2012 23:52
Review of the year
14
was working equivalently although we made recommendations on
increasing the transparency of how requests were processed.
We concluded in previous years
that the SoR process was working
equivalently. However we recognise
that it is not functioning to the
satisfaction of all CPs and we will
continue to monitor its performance.
Overall we are satisfied that BT is committed to running an equivalent
SoR process although output is low and speed of throughput remains a
concern, and the evidence that it is equivalent in practice is inconclusive.
We will continue to monitor the performance of the SoR process at
regular intervals and we will factor the concerns about it into a full review
of the process which was ongoing at the time this report was published.
We will report the 2012 figures in the 2013 EAB Annual Report once we
have completed our review. We will also continue to listen to industry
feedback on the performance of the tool on a regular basis.
2. NGA
BT continued to roll out its Next Generation Access (NGA) network
during 2012. This included the continued roll-out of Fibre-to-theCabinet (FTTC) – which involves installing fibre to street cabinets and
re-using the existing copper lines into premises – and Fibre-to-thePremises (FTTP), which involves installing fibre into homes or premises
as an overlay of the copper local loop.
We take a ‘principles-based’ approach to monitoring BT’s delivery
of NGA. This involves assessing aspects such as checking that NGA
products are developed and launched on an EoI basis and monitoring
that the choice of backhaul for CPs is not limited by the NGA products
which Openreach deploys.
Chart 5
Openreach’s SoR process
%
More information on our NGA monitoring
programme can be found on page 50
18
40
5
8
5
8
16
14
10
11
7
9
10
20
28
30
0
Reject/Cancel
Review Stages
In Development
Delivered
2010 and 2011 figures combined
Non-BT CPs
Source: Openreach and the OTA2
BT CPs
As shown in the chart above, more SoRs were delivered for BT CPs than
for non-BT CPs during 2010 and 2011. The OTA2 reported to us that
it wanted to understand why the number of SoRs delivered for BT CPs
was higher than those delivered for non-BT CPs. It recognised that one
explanation could be the higher number of SoRs submitted by BT CPs,
often relating to WLR3. There are, however, a wide range of reasons
why SoRs may be rejected, for example an unclear benefits statement
in support of the SoR and at present our analysis of how this process is
functioning is ongoing.
CPs have expressed their concerns to us that NGA requests are
processed at the NGA Trialist Working Group and outside of the formal
SoR process. Some smaller CPs have told us that it is more difficult for
them to attend all industry working groups where new requirements
may be discussed. Following an industry survey to better understand
concerns on the SoR process, we recommended to Openreach that all
CPs should be able to see new NGA requirements via the SoR tracker
tool even if not all requests are entered into the formal SoR process.
Openreach made notes from the NGA Trialist Working Group more
widely available and we have since seen a number of NGA SoRs entered
via the tracker tool. We will continue to monitor that Openreach makes
NGA requirements visible to industry.
Book 1.indb 14
25
34
53
60
62
39
70
In October 2011 Openreach completed a consultation with industry
on FTTC passive inputs as required by the Undertakings. Passive inputs
include access to the copper wires between a BT FTTC cabinet and
the end-user premises and the provision of a cabinet to a CP. They
provide greater flexibility for CPs planning to develop and offer their
own NGA products but they require high initial investment costs. We
recommended a revision to the wording of the consultation so that
it would help to capture CP views on passive inputs and Openreach
accepted and included this recommendation. Openreach received only
one response to the consultation.
During December 2011, as required by the Undertakings, Openreach
reviewed with Ofcom whether the Undertakings relating to FTTC needed
to be varied, superseded or released in the light of FTTC deployment,
as well as relevant market and technological developments. Following
the review Openreach informed Ofcom that it would not be seeking
any changes to the Undertakings and Ofcom stated that: “any
future changes to regulation in this area, including in relation to the
development, provision and operation of FTTC, are most appropriately
considered as part of the next WLA market review, which is due to
commence in 2012.”
More information on our monitoring programme for NGA is included
on p25. Our monitoring programme shows that BT is delivering its NGA
obligations although we still have some concerns on whether the design
principles for future passive input products were incorporated into the
design of FTTC. However Openreach’s industry consultation on passive
inputs has gone some way towards allaying these concerns.
3. Inappropriate information sharing
One of our key focus areas since the establishment of Openreach has been
to assess information flows across organisational boundaries within BT. We
examine information sharing boundaries in different parts of the business
on a rolling basis and our findings feed into our risk register. The increased
number of breaches reported during 2012 relating to inappropriate
information sharing also confirmed our ongoing focus in this area.
21/05/2012 23:52
Review of the year
The review did not find any instances of non-compliance but
highlighted some areas for improvement including the need for
an increased focus on compliant information sharing within the
programme, updates to website materials and refresher compliance
training for a small number of individuals. We also sought further detail
on the operational relationship between BT Wholesale and BT Operate
to assess whether it was consistent with the Undertakings.
Given the complex rules around information sharing, and the number
of breaches reported, we consider that non-compliant information
sharing will remain a high risk. This is because we believe that systems
access controls and systems separation should better control the flows
of information between different parts of the business. We will maintain
a particular focus on end-to-end BT programmes in the coming year.
4. Systems implementation
As discussed on p6 we consider this to be a high risk area on which we
will continue to focus during the coming years. Our work encompasses
BT’s delivery of future systems milestones and our assessment of the
company’s systems compliance review which was ongoing at the time
this report was published. More information on our forward-looking
work programme can be found on p16.
5. Ineffective compliance governance processes, such as exchange
space and power allocation
We continue to assess the governance processes that BT has put in place
to manage its implementation of the Undertakings. More information
on our view of BT’s governance arrangements can be found on p21.
One key process which we continue to monitor on an ongoing basis
is the availability of exchange space and power. Space in BT’s local
exchanges is an important part of the infrastructure supporting the
delivery of the Undertakings. BT Operate manages the local exchanges
which house the access nodes owned by Openreach.
In October 2008 BT and Ofcom agreed a variation to the Undertakings
in response to CPs’ concerns that they had difficulty in reserving space
in BT exchanges. The variation required BT to:
–– publish guidelines for the process of allocating exchange space and
power for Openreach’s LLU and Ethernet products
We carried out our regular audit of
exchange space and found that,
although the process was operating
equivalently, it was still largely
reactive to CPs’ forecasts and orders.
We also looked into an issue raised by two CPs on space and power
allocation at Poplar exchange in London, which serves the main London
Olympics site. We found that space and power requirements at the
exchange were being handled equivalently but there were issues with
other processes. This investigation helped to shape our wider review
of exchange space. Exchange space remains an area of concern for CPs
and we will keep track of progress through our ongoing monitoring
programme.
Review of the year
Programmes which operate across BT divisions and involve sharing
information between upstream and downstream divisions are by their
nature high risk. In 2012 we completed a review of information sharing
arrangements in BT’s Managed Ethernet Access Services (MEAS)
programme. MEAS is BT Wholesale’s Ethernet service to many mobile
operators which enables them to supply high-bandwidth to their
end users.
15
Our overall view of BT’s compliance in 2012
Our view is that BT continues to be committed to compliance with the
letter and the spirit of the Undertakings. The Undertakings have led to
significant changes in the way that the UK telecoms industry functions
and functional separation and EoI have been included as potential
remedies in the new European Union framework. However six and a half
years after the Undertakings were first agreed BT needs to maintain a
focus on compliance in areas such as inappropriate information sharing
and systems.
There is also a risk of BT’s becoming more complacent as it moves
towards ongoing compliance rather than working towards the delivery
of major milestones. We understand that priorities may shift over time
but it is important to ensure that compliance with the Undertakings
remains uppermost in the minds of all BT employees and is fully
supported.
It is also our view that the long-running and challenging nature of the
systems obligations may make it likely that some of the forthcoming
delivery milestones will be missed. We discuss this in more detail in
‘Outlook for 2013’ overleaf. We will continue to listen to industry views
and use them to shape our ongoing monitoring work as well as keeping
abreast of current concerns.
–– conduct a proactive review of exchanges with a view to freeing up
space
–– develop and launch a space-only allocation product on an EoI basis
–– review the scope of the existing LLU co-mingling product to allow
more flexible use of exchange space.
The variation also required the EAB to carry out regular audits of
exchange space and review allocation processes focusing on those
exchanges where the main distribution frames were constrained.
In 2012 we carried out our regular audit of exchange space and found
that, although the process was operating equivalently, it was still largely
reactive to CPs’ forecasts and orders. Openreach implemented our
recommendation that it improve its communication with CPs so that
they will be aware of planned activities and exchange sites of interest.
Openreach is required to identify options to free up space at a list of
sites agreed between Openreach and Ofcom. At the time this report was
published Openreach was reviewing exchange sites with Ofcom to agree
an appropriate list of sites.
Book 1.indb 15
21/05/2012 23:52
16
Review of the year
Outlook for 2013
The EAB takes a risk-based approach to planning its forward-looking
monitoring plan by evaluating non-compliant incidents and the output
from the previous year’s monitoring programme. Our work is also driven
by the outstanding Undertakings’ milestones due in the forthcoming
year.
Forward-looking risks
We reviewed our risk register in February 2012 and agreed that the
findings of our monitoring work and an increase in non-compliant
incidents relating to systems had led to significant changes in our top
five risks:
Risk area
EAB’s planned action
1.
Ineffective controls over systems
access.
We will assess the findings of BT’s
system compliance programme
and continue to perform our own
assessments.
2.
Inappropriate information
sharing.
We will continue our programme
of rolling reviews into different
areas of the business, including a
further review of BT Wholesale’s
MEAS programme.
3.
Systems implementation to
achieve customer records
migration and EoI targets by
31 December 2012.
We will continue to attend the
Ofcom quarterly roadmap review
sessions and will review progress
with BT on a monthly basis.
4.
Inappropriate influence on
commercial policy as a result of
the drive for increased end-toend working within BT.
Review of the guidance provided
to BT and review of the Annex
2 process which controls access
rights.
5.
Direct interfaces into BT Operate
by other BT lines of business.
Review of governance
arrangements put in place by BT.
The highest potential risk is around inappropriate access to systems
following a number of breaches identified in this area. BT has put in
place a programme to mitigate this risk – see more information on BT’s
systems compliance review on p9 – and we will assess its effectiveness
once it is complete. Inappropriate information sharing also retained
a high position in the risk table due to the risk that non-compliant
incidents may continue to occur in this area.
Forthcoming Undertakings’ obligations
The systems delivery milestones in the Undertakings stretch until 2014
and some of the major milestones are due by 31 December 2012. The
largest of these milestones is for 90% of customer side records to be
held on separate systems.
To meet this separation target BT needs to deliver the business system
stack and then populate it with a sufficient number of customers. This
depends on a highly challenging plan that rapidly accelerates the weekly
migration volumes with little contingency for unforeseen problems.
For these reasons we believe the milestone is at significant risk and we
continue to keep it under close review.
In May 2011 Ofcom agreed to grant BT an exemption relating to the
Olympics. The exemption will allow BT in exceptional circumstances to
use processes other than the standard EoI processes. It will also allow for
a certain number of engineers from Openreach and BT Operate to work
cross-functionally at any one time. We will continue to monitor actively
that BT is complying with the terms of this exemption and Openreach
has been reporting to us on a monthly basis and will continue to do so in
the run up to and during the London Olympics.
Book 1.indb 16
21/05/2012 23:52
17
THIS PAGE INTENTIONALLY LEFT BLANK
Book 1.indb 17
21/05/2012 23:52
18
Who we are
Who we are
The Equality of Access Board was established on 1 November 2005 as
part of the Undertakings offered by BT to Ofcom. We are a committee
of the BT Group plc Board although our structure, membership and
obligations to Ofcom make us unique.
The EAB has oversight
of the whole of BT when
monitoring compliance with
the Undertakings. It has terms
of reference setting out its role,
monitoring and reporting remit,
its powers, how its members are
appointed and its organisation.
For more information
See www.bt.com/eab.
The Undertakings require that
the EAB has five members: three
independent members, one BT
Group plc non-executive director
and one BT senior manager. In
January 2012 Phil Hodkinson
was appointed as the new EAB
Chairman following the
retirement from the BT plc
Board of Carl Symon.
Phil Hodkinson, Chairman
Phil Hodkinson was appointed to the BT Group plc Board on 1 February 2006.
He is a member of the Audit & Risk Committee, Nominating & Governance
Committee, the Committee for Sustainable and Responsible Business, and the
Pensions Committee. He is a non-executive director of HM Revenue & Customs,
Travelex and Resolution, and a trustee of Action Medical Research, Business in the
Community and BBC Children in Need. Prior to his retirement in 2007, Phil’s roles
included group finance director of HBOS, chairman of Insight Investment and Clerical
Medical, and chief executive of Zurich Life and Eagle Star Life. He is a Fellow of the
Institute of Actuaries.
Sir Bryan Carsberg, Independent
Sir Bryan Carsberg was Professor of Accounting and Business Finance and Dean
of the Faculty of Economic and Social Studies at Manchester University, before
becoming Professor of Accounting at the London School of Economics from
1981 to 1984. He was Director General of Oftel (the former telecommunications
regulator) from 1984 to 1992, Director General of the Office of Fair Trading from
1992 to 1995 and Secretary General of the International Accounting Standards
Committee from 1995 to 2001. Sir Bryan holds a number of non-executive board
appointments. He is a Chartered Accountant.
Stephen Pettit, Independent
Stephen Pettit is a non-executive director of National Grid plc and Halma plc.
He is a former executive director of Cable & Wireless plc. Before joining Cable &
Wireless, Stephen was Chief Executive, Petrochemicals at British Petroleum. He
was previously Chairman of ROK plc, a non-executive director of National Air
Traffic Services, KBC Advanced Technologies plc and Norwood Systems Limited.
Dr Peter Radley, Independent
Dr Peter Radley is a Fellow of the Royal Academy of Engineering and has worked in
the telecommunications industry since 1965, involved in pioneering fibre optics,
GSM and broadband. Between 1991 and 2002 he held positions in Alcatel with global
responsibility for technology and marketing and as Chairman and CEO for Alcatel
UK. He was a founder of the Broadband Stakeholder Group set up by the UK
Government. Since 2002, Peter has been an independent advisor to a number of
organisations including the DTI and South East England Development Agency and
he is also chairman of technology start-up companies in the broadband, IP and
mobile sectors.
Dr Tim Whitley, BT senior manager
Dr Tim Whitley is Managing Director of Research and Technology and BT’s
Adastral Park research and development facility. He started working for BT in
1981 as an apprentice engineer in North Wales and has since held roles in areas
including optics research, technology consultancy, technical architecture and
recently served as BT’s Group Strategy Director.
Book 1.indb 18
21/05/2012 23:52
Who we are
19
How we work
Audit & Validation plan
Milestone validations
Product KPIs
Exemptions & variations
EAO monitoring report
Regular & ad
hoc BT Reports
CPs
EAO
CPs
Complaints
Issues management
EAO reviews
BT
EAB breaches process
EAB Meetings: deliberation & decisions
Complaints & breaches
EAO assessments
Direct CP
views
Who we are
Behavioural measures
EAB minutes & overviews
Annual Report
Ofcom briefing
The EAB is supported by the EAO and the EAB Secretary on all matters
within its remit. The EAO reports regularly to the EAB on the detailed
status of BT’s delivery of the Undertakings. It carries out investigations
into complaints made by CPs and into possible breaches of the
Undertakings on the EAB’s behalf.
Book 1.indb 19
During 2012 the EAB Secretary organised four Board meetings. Minutes
have been provided to Ofcom and the EAB Chairman regularly reported
the EAB’s views to the BT Group plc Board.
21/05/2012 23:52
20
Who we are
Monitoring, reporting and advising
The EAB monitors BT’s delivery of key Undertakings, reports on progress
to Ofcom and industry and offers advice to BT on its compliance with
the Undertakings.
Monitoring
We conduct a wide range of monitoring activities to assess BT’s
compliance with the Undertakings. On the EAB’s behalf, the EAO
monitors BT’s delivery of the milestones listed in the Undertakings.
The EAO also assesses BT’s ongoing compliance with obligations
from previous years. It runs an Audit and Validation plan through
which it audits BT’s ongoing compliance with specific sections of the
Undertakings on a rolling basis.
The EAB also agrees a programme of ongoing compliance reviews based
on areas of known or potential risk. In devising the programme, the EAB
considers common themes arising from breach cases or issues identified
during the EAO’s monitoring work. The EAB also takes account of
the findings of relevant internal and external audit reports that have
assessed BT’s delivery of the Undertakings, as well as issues raised by
stakeholders.
The EAB’s monitoring methodologies are included in the table below:
Monitoring activity
How we perform it
Milestones
We validate that products and systems separation
are delivered by the timescales specified in the
Undertakings, for example products such as WLR3.
Principles
We assess BT’s compliance with agreed areas of focus
for NGA through attending working groups. We also
validate the delivery of some NGA products with
launch dates at BT’s discretion.
Ongoing
compliance
A combination of monthly, quarterly or annual
reviews and ‘spot checks’ of areas mandated by the
Undertakings (such as product KPIs) and a rolling
programme to review areas identified as high risk.
Non-compliance
Investigations into complaints raised directly by CPs
via the EAO’s complaints process and investigations
of breaches raised either by BT or the EAO.
Issues management
Reviews of issues raised informally by CPs, Ofcom and
other stakeholders.
The EAB applies similar criteria across all of its monitoring activities:
Blue
Undertaking delivered or review completed.
Green
Undertaking delivery on track, or in the case of ongoing
compliance, review completed with no issues identified
Amber
Undertaking is at risk, or in the case of ongoing compliance,
issues identified.
Red
Undertaking date has been missed or is in jeopardy, or review has
identified major deficiencies or issues.
Book 1.indb 20
The EAO Director makes the decision to move the delivery status from
Green to Blue before reporting the outcome to the EAB. This applies
to both the delivery of milestones and the completion of ongoing
compliance reviews. As part of its assurance opinion, PwC assesses the
EAB’s work across all of these monitoring areas. Those activities referred
to in its assurance opinion are marked by throughout the report.
Reporting
The EAB is required by the Undertakings to conduct an annual review
of BT’s compliance with the Undertakings, and upon completion send a
report to Ofcom. It is also required to publish a summary report which is
to be made available on BT’s website. Currently, the EAB aggregates all
of its findings into one report and publishes it to all concerned.
The EAB is required to report on particular areas including its views on
the governance of the Undertakings, BT’s delivery of major milestones,
potential future breaches and the findings of the product KPIs.
The EAB also publishes a regular update about its activities
on its website: http://www.bt.com/eab.
Advising
The EAB advises BT on areas where it believes improved compliance
with the Undertakings can be achieved. During 2012 we made
recommendations to BT on topics such as systems compliance and
information sharing.
Stakeholder engagement
We have three sets of direct stakeholders in the UK: CPs and telecoms
industry associations, Ofcom and BT.
During 2012 the EAB heard the views of industry stakeholders at its
meetings and it paid close attention to the output from the EAO’s
‘Quick Checks’ process. It also heard regularly from the OTA2. The EAO
continued to hold meetings with CPs and industry associations as well
as attending the Connectivity Services forum and NGA working groups.
The EAO also continued to maintain contact with CPs in Northern
Ireland by attending the Northern Ireland Telecom Stakeholder Forum.
In November 2011 the EAO surveyed CPs to hear their views on
whether the Undertakings had been delivered six years after they were
agreed.
We hold regular meetings with Ofcom. An Ofcom Board member
attended an EAB meeting in January 2012 and the EAO has monthly
meetings with Ofcom policy directors. The EAO has also met the OTA2
regularly to discuss progress.
The EAB met a range of BT stakeholders during 2012. This included
the BT Group Chief Executive and the Chief Executive of BT Northern
Ireland, who attended a meeting to give an update on the company’s
activities in the Province.
Our view on our governance and resourcing
The Undertakings require the EAB to give a view on how well its
governance arrangements are functioning and whether it is satisfied
with the level of resourcing available. The EAB considered factors such
as the development of the EAO’s monitoring process in response to
changes and the findings of a BT Internal Audit review of the EAO’s and
EAB’s processes in Q4 2012. The EAB also completed an annual board
effectiveness survey. It confirmed that its governance arrangements are
functioning well and that it is satisfied with the level of resourcing made
available by BT.
21/05/2012 23:52
Who we are
Wider governance of the Undertakings
BT has a company-wide responsibility to deliver its Undertakings’
commitments. The EAB engages with each of BT’s lines of business to
monitor compliance with the Undertakings and is required to assess the
effectiveness of the governance framework that BT has put in place to
support the Undertakings.
BT’s governance structure
Openreach does not report to BT’s Operating Committee to support
functional separation of the organisation from the rest of the company.
BT’s governance structure to support the delivery of the Undertakings
has continued to evolve over the past six and a half years. During 2012
it consisted of:
–– The Enterprise Programme Steering Board (PSB): this forum is the
most senior governance body within the programme and has a
group-wide responsibility for setting policy and direction, managing
priorities, resolving risks and issues and ensuring consistency across
BT’s business units.
–– BT Undertakings’ Customer Delivery Board (CDB): this forum provides
pan-BT monitoring and governance across workstreams. It ensures
effective risk and issue mitigation and reporting.
21
The EAB and BT’s governance framework
The EAB conducts reviews of different aspects of BT’s governance of the
Undertakings on a year-by-year basis.
As part of our regular monitoring of Next Generation Access we have
attended the NGA Trialist Working Group, the NGA Business user forum
and Ethernet and Copper Product and Commercial Group meetings to
assess whether Openreach’s engagement with industry is operating
effectively. We also attend Ofcom’s systems roadmap sessions.
Openreach continues to present its annual operating plan to us on an
annual basis. At the time this report was published we were reviewing
Openreach’s product management process. We were also reviewing how
BT handles external complaints relating to the Undertakings.
Our view on BT’s governance of the Undertakings
The EAB has considered the effectiveness of BT’s governance framework
by looking at factors including the measures in place to detect breaches
and address potential breaches and the reporting mechanisms in place
to give updates on the Undertakings. We are satisfied that BT has a
suitable governance framework in place although we recommend that
the company reviews its arrangements to ensure that the Undertakings
are fully supported in terms of adequate numbers of compliance officers
and ongoing employee engagement.
–– Workstream Execution Boards: the programme is divided into three
key workstreams: UK Business Solutions, Migrations and Openreach
Industry Commitments, each of which has its own lead who is
responsible for the governance of a portfolio of projects via their own
Execution Boards.
–– The Undertakings programme: consists of an Undertakings
representative for each line of business – reports progress, plans and
issues into the leadership team within BT Innovate and Design on a
monthly basis via its own Customer Delivery Board/Execution Board to
ensure that any major delivery issues are resolved.
The Undertakings programme reports to the BT Design Council on
a monthly basis. It also reports to the BT Operating Committee on a
quarterly basis to ensure that the programme is cost-effective and is
consistent with BT’s strategic direction.
Who we are
–– Breach Review Group: consists of Undertakings and legal
representatives across the business and assesses the status of
potential breaches.
BT has a responsibility to ensure that its employees have the necessary
tools and training to comply with the Undertakings. The company issued
a Code of Practice to BT employees in the UK in December 2005. This
was updated and re-launched in March 2008.
E-learning courses, based on the revised Code, were launched at the
end of June 2008. These are designed to ensure that BT people are
familiar with the Undertakings and their associated responsibilities.
Book 1.indb 21
21/05/2012 23:52
22
Undertakings status indicators
Undertakings status indicators
The EAB monitors the delivery of major EoI products
covered by the Undertakings. Many of those with set
delivery dates have been delivered in previous years
and the remaining WLR3 obligations were removed
in 2009. The EAB also monitors the delivery of NGA
products to ensure that they are launched on an EoI
basis, even though these do not have set launch dates
in the Undertakings.
Undertakings status indicators
Key
Achieved
Concerns
Removed
Not achieved
On track
Replaced
Delivery of key milestones to date
This table lists our view of the status of all the key Undertakings that were due to be delivered up to 31 March 2012 including those
delivered in previous years. The key gives an explanation of the different terms used in the table.
Undertaking
Date due
Milestone status
Comments
IPstream EoI RFS
31 Dec 2005
Relevant Broadband service using EoI IPstream/IBMC
31 Dec 2006
LLU EoI RFS
30 June 2006
Non-trivial breach resulting; BT paid allowances to CPs.
The EAB confirmed that the breach was remedied in
December 2006.
IPstream using EoI LLU IBMC
31 Dec 2006
Non-trivial breach; BT completed delivery end of Aug 2007.
WES, BES, WES Backhaul and WEES EoI RFS
30 Sept 2006
Relevant Retail Ethernet Service using EoI WES IBMC
31 March 2007
WLR Analogue EoI RFS (informal milestone)
31 Dec 2006
WLR Analogue EoI RFS
30 June 2007
WLR Analogue IBMC 30% target
30 June 2008
Milestone reached November 2008.
WLR Analogue IBMC 70% target
30 June 2009
Milestone reached September 2009.
WLR Analogue IBMC 100%
30 June 2010
Revised obligation included in 2009 variation.
WLR ISDN2 EoI RFS
30 Sept 2007
Trivial beach regarding some new end-user orders.
BT’s Retail ISDN2 using EoI WLR ISDN2 IBMC
31 March 2009
Non-trivial breach; revised obligation included in 2009
variation.
WLR ISDN30 EoI RFS
28 Feb 2008 (was
31 Dec 2007)
BT’s Retail ISDN30 Service using EoI WLR ISDN30 IBMC
31 Dec 2009
Book 1.indb 22
BT paid allowances to CPs.
Revised obligation included in 2009 variation.
21/05/2012 23:52
Undertakings status indicators
23
Undertaking
Date due
Milestone status
Comments
IPstream Connect available for order; start of BT and CP
end-user base migration
31 Oct 2008
Achieved ahead of schedule.
IPstream Connect IBMC and migration of CP end-user
base
31 March 2009
Achieved ahead of schedule.
GEA over FTTP
Not applicable
Not applicable
Launch review completed by EAB.
GEA over FTTC
Not applicable
Not applicable
Pre-launch review completed by EAB.
Systems separation obligations
The EAB monitors the delivery of systems separation through either full physical separation of systems, or through the implementation of user
access controls. During 2009 there was a variation to the Undertakings that resulted in changes to the delivery dates for systems separation.
OSS separation – User access controls and physical separation
Undertaking
Date due
Milestone status
Comments
User Access Controls for WLR3, SMPF, MPF and ISDN2
30 June 2007
Mostly delivered by the required date, but only fully met in
late September 2007 due to a trivial breach.
Operational support systems separation independent
external audit of User Access Controls including ISDN2
and ISDN30
30 June 2008
Achieved ahead of schedule.
Implement physically separate OSS for WLR manual
exception tasks
31 May 2009
Non-trivial breach; milestone removed by 2009 variation.
Additional audit of User Access Controls
30 June 2010
Achieved ahead of schedule.
Implement User Access Controls for OSS listed in
Annex 6
30 June 2010
Implement physically separate access and user access
controls for BT people not listed in 5.44.6 (a)
30 June 2010
OSS physical separation
30 June 2010
Milestone removed as part of 2009 variation; BT now has to
deliver physical separation when “reasonably practical and
proportionate”.
EAB to perform quarterly checks of access to OSS listed
in Annex 6 starting in June 2010
From June 2010
onwards
Moved to six monthly in agreement with Ofcom.
Migration to EoI products
Date due
At least 90% of BT’s relevant installed end-user base
shall be migrated so that the products that this base
purchases, that consume the Measured Products, do so
on an EoI basis from Openreach
30 June 2010
BT to advise Ofcom of the further increased percentage
migrations of the relevant installed end-user base
achieved by 30 June 2014
31 Dec 2011
(latest) or 6
months after
completion
of business
systems stack
migration (if
earlier)
At least 95% of BT’s relevant installed end-user base
shall be migrated so that the products that this base
purchases, that consume the Measured Products, do so
on an EoI basis from Openreach
31 December
2012
BT to achieve further increased percentage migrations
previously notified to Ofcom by 31 Dec 2011
30 June 2014
Book 1.indb 23
Milestone status
Comments
BT informed Ofcom that it would migrate 97% of the relevant
installed end-user base.
Undertakings status indicators
Undertaking
21/05/2012 23:52
24
Undertakings status indicators
Customer side records migration
Undertaking
Date due
Milestone status
Comments
Ready to mass migrate PSTN customer side records
31 March 2008
50% of relevant customer side records migrated to
physically separate OSS
30 Nov 2008
50% of non-WLR supply side records migrated to
physically separate OSS
31 Jan 2010
Non-trivial breach; milestone removed by 2009 variation
Ready to mass migrate customer side records relating
to Featureline
30 June 2009
Non-trivial breach; revised obligation included in 2009
variation.
90% of relevant customer side records migrated to
physically separate OSS
30 Sept 2009
Revised obligation included in 2009 variation.
90% of non-WLR supply side records migrated to
physically separate OSS
31 Jan 2010
Removed by 2009 variation.
90% of users migrated to physically separate OSS for
WLR manual exception tasks
31 March 2010
Removed by 2009 variation.
At least 80% of BT’s customer side records relating to
the Measured Products held on OSS shared between
Openreach and the rest of BT are migrated to at least
Level 2 system separation;
30 June 2010
BT to advise Ofcom of BT’s customer side records to be
achieved by the 30 June 2014
31 Dec 2011
(latest) or 6
months after
completion
of business
systems stack
migration (if
earlier)
BT informed Ofcom that it would migrate between 92% and
94% of customer side records.
Implementation and ongoing application of the
obligations in relation to customer side records in
section 5.44.2 is subject to an audit commissioned by
the EAB on an ongoing basis at least every 24 months
from 30 June 2010.
30 June 2012
(latest)
Initial audit of achievement of 80% migration milestone has
been completed.
At least 90% of BT’s customer side records relating to
the Measured Products held on Operational Support
Systems shared between Openreach and the rest of BT
are migrated to at least Level 2 System Separation;
31 December
2012
Achievement depends on successful delivery of the UK
business system stack and a rapid migration of customers.
BT to achieve further increased percentage migrations
previously notified to Ofcom by 31 Dec 2011
30 June 2014
UK business systems stack implementation (non-binding milestones)
Undertaking
Date due
Business systems stack – Operational Trial Starts
30 April 2010
Business systems stack – Initial Live Deployment
31 Dec 2010
Business systems stack – Trial Migration Begun
31 March 2011
Business systems stack – Volume Migration Begun
31 Dec 2011
Book 1.indb 24
Milestone status
Comments
21/05/2012 23:52
Undertakings status indicators
25
MIS and other systems separation
Undertaking
Date due
Milestone status
Comments
Management Information Systems separation
22 Oct 2006
Includes Level 1 separation for Annex 5 systems and Level 2
separation for others.
MIS roadmap
30 June 2007
MIS Level 2 separation
30 June 2010
BT did not implement Level 2 separation for all its MIS.
Non-OSS and non-MIS Level 1 separation
30 June 2010
Although the milestone was achieved, ongoing compliance is
high risk due to the solutions adopted by BT.
NGA-related Undertakings
Undertaking
Date due
Milestone status
Comments
NGA related Undertakings cease to apply to future
deployments (conditional)
31 Dec 2010
The number of end user premises capable of being served
by a BT FTTC enabled cabinet had exceeded 500,000 before
31 December 2010.
BT to consult on demand for FTTC Passive Inputs and
Backhaul over fibre
31 Dec 2011
Consultation completed, one industry response received.
BT and Ofcom to review NGA Undertakings
31 Dec 2011
No changes to the Undertakings.
Next Generation Access monitoring themes
We monitor six areas of compliance for NGA:
Status
Activity
Consultation and engagement – Openreach is required
to consult with industry on key changes and product
developments.
Openreach continues to engage with industry through working groups
and fora. Some in industry have expressed concern that requirements
for NGA products are processed via the NGA Trialist Working Group
rather than Openreach’s formal SoR process. Openreach held an industry
consultation on passive inputs.
Products – to be designed, launched and CPs’ users migrated to
the new product on an EoI basis.
We concluded a pre-launch review of the GEA product over FTTP in pilot
phase and found that it was operating compliantly although there were a
few aspects which could only be reviewed after full launch had taken place.
Equipment and locations – to ensure that NGA solutions are not
made unattractive to CPs, either because of cost or availability
of equipment, space or power.
We have found that all NGA developments and products use existing
Openreach exchange space and power products, and there is also the
option for CPs to use their own infrastructure.
Backhaul – to ensure that the NGA product does not preclude
or dictate the choice of backhaul for CPs or make the product
commercially unattractive because of the cost or limitations of
the backhaul solution.
No CPs have raised concerns with us on this topic so we conclude that
Openreach is fulfilling its obligations.
Passive components – a range of requirements resulting from
a variation to the Undertakings, including a requirement to
consult with industry and a stipulation that Openreach should
use the same components, processes and systems it uses itself
for the purposes of its active product.
Openreach held an industry consultation on passive inputs and accepted
the EAO’s advice on a change to the wording of the consultation.
Governance – A range of obligations including the use of
statement of requirements processes on the same basis for
all CPs, appropriate sharing of customer confidential and
commercial information and all transactions to be carried out
on an EoI basis.
Some new NGA requirements are being progressed using the SoR tracker
tool and are discussed at the NGA Trialist Working Group. At the time this
report was published we were reviewing the SoR process.
Book 1.indb 25
Undertakings status indicators
NGA theme
21/05/2012 23:52
Undertakings status indicators
26
Behavioural dashboard
BT employees must comply with the Undertakings in the way that they behave when working with colleagues and dealing with customers. We
monitor BT’s progress towards encouraging Undertakings-related behavioural change by assessing a range of behavioural indicators:
Measure
Status
Manager and Team Member Undertakings training completion
100
Percentage of Completion
95
90
85
80
75
70
BT
Operate
Openreach Innovate
& Design
Global
Services
Wholesale
Retail
Group
UK Based BT Managers - Target 95%
UK Based Team Members - target 90%
Source: BT
Training completion rates for UK managers
remained above target across the company,
although figures for training completions
continue to be below target for team members
in BT Global Services and for contractors
in BT Global Services and BT Group. BT has
undertaken a number of initiatives to drive up
completions and the EAB has recommended
that BT continues to provide effective training
to maintain awareness of the Undertakings. BT
also reported to us that the Undertakings were
not relevant to some of the people invited to
complete the training, for example third party
contractors working outside of BT sites. It said
that this accounted for the lower completion
rate in some areas. We will continue to monitor
completion rates across BT.
UK Based Contractors - target 90%
Openreach brand awareness – Business only
Awareness levels of the Openreach brand
decreased slightly in 2012 but the graph
shows that there has been a gradual increase in
awareness over time. Openreach continues to
place the Openreach brand on its vans with only
a small number left to be rebranded.
50
40
% Brand Awareness
Comment
30
20
10
0
Jan-06
Jan-07
Jan-08
Jan-09
Jan-10
Jan-11
Source: Openreach
Openreach delivers products equivalently
% customers agree
The chart shows the twelve month rolling average.
There has been a downward trend for this measure
during the year. This trend was mainly caused by
a greater number of CPs answering ‘Don’t know’
to the question. At the beginning of the year
there was a change to the mix of CPs asked this
question, with more smaller CPs involved in the
survey and their responses showed that they were
more likely to answer ‘Don’t know’.
Mar-11
May-11
Source: Openreach
Book 1.indb 26
Jul-11
Sep-11
Nov-11
Jan-12
Mar-12
Openreach ran knowledge calls on equivalence
for smaller CPs throughout 2012 and 75 CPs
joined the calls. Openreach reported that a
number of the issues raised by CPs in response
to this question related to service rather than
equivalence. It has told us that it will be addressing
a range of issues raised by CPs on the calls in its
compliance programme for the coming year.
21/05/2012 23:52
Undertakings status indicators
27
Measure
Status
BT Wholesale only manages two products on an
EoI basis in 30% of the UK. For those products,
the chart shows that the level of confidence that
BT Wholesale delivers its products equivalently
has been maintained and shows improvement
since last year.
BT Wholesale delivers products equivalently
New survey
process April 08
% customers agree
90
85
80
The data to form this chart was obtained through
telephone interviews with customers. Bearing
in mind the reduced sample size and the cost of
running these types of interviews, BT Wholesale
decided to discontinue this measure from
December 2011 onwards.
Question no longer asked
therefore no scores are
available from April 09
75
70
65
Jan-06
Jan-07
Jan-08
Jan-09
Comment
Jan-10
Jan-11
Confidence that BT will deliver Telecom Strategic Review commitments
Believe BT delivers products equivalently* to all customers
*equivalence applies to certain key Products and Services
as defined in the Undertakings
Source: Openreach
Satisfaction with Openreach engineers
The rolling 12-month average for this measure
fell during 2012 and is below target, although
a similar measure for Openreach account
managers maintained a good performance. We
will continue to monitor this measure as two CPs
have raised engineering behaviour as an issue.
% appropriate behaviour
100
95
90
85
80
75
70
Mar-11
May-11
Jul-11
Sep-11
Nov-11
Jan-12
Mar-12
Source: Openreach
Openreach SoR process
This is covered in more detail on p14. The
Openreach SoR process was under review by the
EAB at the time this report was published.
BT Wholesale SoR process
The chart shows SoRs were delivered for a higher
number of non-BT CPs than for BT CPs. We are
satisfied that this process is running equivalently
and without issues.
April 2011 to March 2012 (as at 03/04/2012)
40
30
25
20
15
10
5
0
Received
Pending
Rejected
Accepted
Delivered
SoRs raised by non-BT CPs
Source: BT
Book 1.indb 27
SoRs raised by BT CPs
Undertakings status indicators
Number of SoRs
35
21/05/2012 23:52
Undertakings status indicators
Product KPIs
The EAB assesses key performance indicators (KPIs) published by BT
showing the performance of BT’s EoI products. The KPI charts for each
product portfolio compare service provided to CPs within BT to that for
non-BT CPs.
The KPIs are shown as line charts with one line representing the product
performance experienced by BT CPs and the other the performance as
experienced by non-BT CPs. If the two lines are consistently different
it may indicate that there is an equivalence issue. However there are
several factors that can cause differing performance and these do not
necessarily indicate a breach of the Undertakings. Tests are also applied
to assess whether any difference is statistically significant. These factors
are explained on a product-by-product basis below for a selected
number of KPIs.
Chart 16
WLR3 Analogue Top Level Repair (all care levels)
% faults completed in objective time
100
90
80
70
Source: BT
% orders completed by CCD
100
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Apr 11
Chart 15
WLR3 Analogue Top Level Provision
Jun 11
60
Openreach
May 11
28
Non-BT CPs
BT CPs
WLR3 analogue repair performance appears to have favoured BT
CPs during the year. However our analysis highlighted no significant
equivalence issues once the different service levels that CPs chose to
order are taken into account.
98
96
94
94
92
Source: BT
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
90
Jul 11
During the year, WLR3 analogue provision performance favoured
non-BT CPs. The WLR3 analogue provision KPI metric comprises the
sub-order types New Provides, Migrations and Transfers, which each
have different average times to process. Non-BT CP orders comprised
a higher percentage mix of the more simple Transfers and Migrations
orders while a higher percentage of BT CP orders were New Provides
which required the installation of a new copper line. We have concluded
that there is no indication of non-compliance with the Undertakings’
requirements.
96
Jun 11
BT CPs
May 11
Mar 12
Feb 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jan 12
Non-BT CPs
98
Apr 11
Source: BT
Jul 11
% orders completed by CCD
100
Jun 11
90
May 11
Chart 17
LLU Provision – SMPF Basic Provides
Apr 11
92
Non-BT CPs
BT CPs
SMPF Basic Provide performance favoured BT CPs for the majority of the
year. Non-BT CPs operate mainly in locations of high business density
and in just three out of the nine BT operational zones. Any service
delivery issues within these locations can impact non-BT CPs’ overall
performance while BT CPs’ operations are spread across the entire UK
and are therefore more resilient to issues in any particular area. This, in
combination with significantly greater volumes of BT CPs, resulted in
higher BT CP performance levels for some of the year.
Book 1.indb 28
21/05/2012 23:52
Undertakings status indicators
29
Chart 18
LLU Provision – MPF New Provides
Chart 20
NGA Provision – GEA over FTTC
% orders completed by CCD
100
% orders completed on time
100
90
98
80
96
70
94
60
92
50
Source: BT
Non-BT CPs
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
May 11
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
May 11
Apr 11
Source: BT
Apr 11
90
40
Non-BT CPs
BT CPs
BT CPs
The provision performance for MPF favoured non-BT CPs throughout
the year. A very high percentage of BT CP orders are ‘multiple orders’
whereas nearly all non-BT CPs orders are ‘single orders’. This means
that when a BT CP order fails it often results in a multiple customer
order failure, whereas non-BT CP orders that fail usually only affect
one customer order and this affects the performance chart. Following
analysis, including disaggregation of the order types, we have found no
indication of failure to comply with the Undertakings.
GEA over fibre to the cabinet provision performance for BT CPs and
non-BT CPs remained broadly equivalent throughout the year and we
have found no indication of a lack of equivalence.
There are too few BT CP repairs for MPF to make a valid comparison.
BT Wholesale
Chart 21
IPstream Connect Provision
Chart 19
Ethernet Provision – Ethernet Access Direct
% orders provided on time
100
% orders completed by CCD
100
99
98
98
96
97
94
96
92
BT CPs
EAD provision performance favoured BT CPs for the majority of the year.
We found that BT CPs chose to purchase a high volume of the ‘project
managed service’ product with some of its orders. The use of project
services removes some of the reasons for order failure and this has
had the effect of improving BT CP performance. The project managed
service is available from Openreach to all CPs on an equivalent basis
under its ‘Project Services’ contract. We concluded that there is no
indication that EAD provision does not comply with the Undertakings.
Source: BT
Mar 12
Feb 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
Jan 12
Non-BT CPs
BT CPs
IPstream Connect provision performance favoured non-BT CPs. We
found that the Simultaneous Provide order type (where the copper
line and the IPstream broadband service are provisioned at the same
time) impacted on the overall result. Simultaneous Provides are more
complicated than standard orders and therefore have a lower provision
success rate than other order types and BT CPs consume a much higher
number of Simultaneous Provide orders than non-BT CPs. We found no
Undertakings compliance concerns in this area.
Undertakings status indicators
Non-BT CPs
May 11
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
May 11
Apr 11
Source: BT
Apr 11
95
90
Book 1.indb 29
Although GEA repair volumes are currently very low, early analysis
indicates that current performance is equivalent. We will continue to
monitor both provision and repair performance carefully during the
coming year.
21/05/2012 23:53
Undertakings status indicators
30
Ofcom removed regulatory obligations for Wholesale Broadband
Connect (WBC) in the competitive Market 3 during 2008; therefore
the EAB monitors WBC in the regulated Markets 1 and 2. During the
year performance favoured non-BT CPs as with the IPstream Connect
product. We identified that the Simultaneous Provide order type – which
is complex and has a lower target timescale success rate than other
order types – affected the performance chart. BT CPs receive a higher
percentage of Simultaneous Provide orders than non-BT CPs and analysis
has shown that when this order type is excluded performance appears to
be equivalent.
Chart 22
IPstream Connect Repair
% faults cleared on time
100
95
90
Chart 24
WBC Migrations
85
% migrations provided on time
100
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
May 11
Apr 11
80
96
Non-BT CPs
Source: BT
98
BT CPs
94
IPstream Connect migrations
We found that IPstream Connect migration performance has been
equivalent throughout the year.
92
Source: BT
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
May 11
90
Apr 11
IPstream Connect repair performance favoured BT CPs during the
year. This was because CPs can choose which diagnostic tool they use
as part of the repair process and BT CPs chose to use the Openreach
Broadband Boost tool to log complex faults, the statistics for which are
not shown in this chart. In contrast, non-BT CPs logged more faults
using BT Wholesale’s Special Fault Investigation tool, on which this chart
is based. Despite this difference in approach we found no indication of
non-compliance with the Undertakings.
Non-BT CPs
BT CPs
Performance favoured BT CPs during the year. A major project
that required a migration of orders between CPs affected the chart
performance. Root cause analysis indicated that orders received by
BT Wholesale are allocated taking factors such as exchange capacity,
exchange equipment footprint and engineering availability into
consideration. BT CP and non-BT CP orders are handled on the basis of
‘ratio of orders by telephone exchange’ and if the overall requirement
for an exchange cannot be delivered, the number of orders is reduced
while maintaining the ratio of BT CPs and non-BT CP orders.
Chart 23
Wholesale Broadband Connect Provision
% orders provided on time
100
95
In the case of the large project the likelihood of an exchange’s having
only non-BT CP orders was high while the likelihood of an exchange's
having only BT CP orders was low, therefore due to volume, failures on
a ‘per exchange’ basis were statistically more likely to affect non-BT CP
order performance. BT assured us that when the major project order was
excluded from analysis, performance for BT CPs and non-BT CPs was
equivalent.
90
85
Source: BT
Mar 12
Feb 12
Jan 12
Dec 11
Nov 11
Oct 11
Sep 11
Aug 11
Jul 11
Jun 11
May 11
Apr 11
80
Non-BT CPs
BT CPs
Book 1.indb 30
21/05/2012 23:53
Undertakings status indicators
In the course of agreeing the OSS variation in 2009, Ofcom reflected
industry concerns that slower progress towards migration to the new
EoI products following changes to the remaining IBMC dates might
have adverse consequences on equivalence in practice. Accordingly BT
offered to provide Openreach’s Comparative Performance Charts (CPCs)
to the EAO.
The EAB’s analysis of the CPC metrics from
April 2011 – March 2012
CPC
Commentary
Analogue repair
The performance levels of the ‘repeat
repairs’ metric shows that there appears
to be a potential incentive while the repair
performance metric shows a potential
disincentive for ensuring all new analogue
telephony provisions are EoI. This ‘mixed’
picture means that it is unlikely for there to be a
significant impact on BT’s behaviour.
ISDN2 provision
Performance levels of the both provision
metrics show no clear disincentive for migration
to the EoI version.
ISDN2 repair
For the majority of the year there has been no
clear incentive regarding repair performance to
ensuring that all ISDN2 circuits are migrated to
the EoI systems.
ISDN30 provision
There is a potential incentive and a potential
disincentive to ensuring all ISDN30 provisions
for all end users are processed on EoI systems.
The transaction volumes are very low with
little or none for the classic BT product and
this ‘mixed’ picture means that it is unlikely
therefore to have a significant impact on BT’s
behaviour.
ISDN30 repair
For the majority of the year there has been only
a potential disincentive to ensuring all ISDN30
products are migrated to the EoI variant and
thus supported by the new systems. Once
again transaction volumes are very low with
little or none for some of the year for the classic
BT product. This potentially could impact BT’s
behaviour.
The intent of the CPCs is to indicate whether Openreach’s service
performance levels for the EoI and non-EoI product variants
disincentivise the rest of BT from migrating to the EoI product variants.
The CPC reports indicate whether or not BT may be getting better
performance by leaving its installed customer base on the non-EoI (i.e.
‘classic’) product variant rather than migrating them more quickly to the
EoI variant (WLR3) following the resetting of the IBMC dates.
Ofcom’s OSS variation statement said:
“Given the consultation responses Openreach will also advise the EAO,
at least quarterly, of the comparative performance stats between EOI
and non-EOI for the main product sets (PSTN, ISDN2, ISDN30, WLR2,
and WLR3) where the IBMC dates have been reset by the variation.”
“Openreach will report to the EAO on a quarterly basis, from January
2010 at the latest, on key performance metrics comparing EOI and
non-EOI/legacy supply. Measures will cover installation times, early life
fault rates, fault repair times and repeat fault rates. The relevant (highvolume) products covered include WLR Analogue, ISDN2 and ISDN30."
Ofcom continued: “We consider that this will place pressure on
Openreach to deliver broadly equivalent performance to CPs and
those BT downstream customers depending on non-EOI inputs. This
additional reporting and monitoring has been agreed between BT and
us subsequent to comments made in responses to the consultation.”
The CPCs provided to the EAO since October 2009 are not necessarily
comparing ‘like for like’ products, and some categories shown on the
charts may be consumed by a small number or even a single CP and
hence expose commercially confidential information. As a result, BT and
Ofcom have agreed that the charts should not be published. However,
Ofcom and BT have asked the EAB to publish its opinions on the charts.
It is also important to note that the CPCs do not perform the same
function as the EoI product equivalence KPIs shown on the previous
page and they should be viewed independently as both the subject
matter and the statistical approach are different.
Two metrics are examined for both provision and repair processes for
each of the Analogue, ISDN2 and ISDN30 products:
Provision:
1. Time to install (in working days)
2. The percentage of provisions suffering early life failures.
Repair:
1. Time to clear the fault (in working hours)
2. The percentage of repairs requiring a repeat repair to clear.
To draw a conclusion, the EAB reviews both metrics to assess whether BT
would benefit by remaining on the non-EoI product variant. In the case
of a ‘mixed picture’ where one metric is an incentive and one metric is
a disincentive, the EAB assumes that it is unlikely to have a significant
impact on BT’s behaviour.
Book 1.indb 31
The EAB found no obvious examples of there being a clear and
consistent disincentive across all of the metrics of a particular product
to cause BT to delay moving to the EoI product and systems. In most
of the cases there was a mixed picture. For example, the EoI product
would perform better in one metric but worse in the other metric. In
some cases the CPCs indicate there will be a benefit in a particular metric
of a product; but in all but two cases this is offset by a disadvantage in
another metric. The two areas where this was less clear are ISDN2 and
ISDN30 repair, where for some of the year the CPC metrics indicated
that there was only disincentive to migrating all ISDN2 and ISDN30
products to the EoI platform. The EAB will continue to monitor the
planned activity roadmap in this area closely while it is aware that
current volumes are very low.
Undertakings status indicators
Comparative performance charts
31
21/05/2012 23:53
32
Undertakings status indicators
On this basis, the EAB can provide some reassurance to Ofcom that
the metrics which it specified indicate that BT is not gaining a clear
advantage compared to non-BT CPs by remaining on non-EoI products
and systems longer than originally planned.
In addition, BT’s progress towards the delivery of its remaining
Undertakings’ obligations for current generation products and systems
would also support the CPCs in showing that BT is not gaining an
advantage by remaining on non-EoI products.
The systems variation agreed in September 2009 set out targets
relating to separation of BT’s systems. In relation to the migration of its
customer base to equivalent products, BT had previously reported that
by 31 March 2010, 90% of its residential customers were served on an
equivalent basis, which included the migration of over 12m consumer
customers. The EAB validated this assertion.
This year BT reported two non-binding system migration milestone
achievements, firstly confirming that business customer migration trials
had started in March 2011 and secondly that the volume migration
of business customers had started during December 2011, The EAB
validated both of these non-binding assertions.
During December 2011 BT advised Ofcom of the further increased
percentage migrations of both the relevant installed end-user base
and BT’s customer side records to be achieved by the 30 June 2014.
The EAB validated that BT had met its commitment to inform Ofcom by
31 December 2011.
Book 1.indb 32
21/05/2012 23:53
Undertakings status indicators
33
Independent Assurance Report
to the Equality of Access Board
and Ofcom
We have been engaged to express an independent opinion on selected
aspects of the Equality of Access Board (“EAB”) Annual Report for
the year ended 31 March 2012 (the “Report”). The preparation of
the Report in accordance with the requirements of the Undertakings
given to Ofcom by BT Group plc (“BT” or the “Group”) pursuant to the
Enterprise Act 2002 effective 22 September 2005 (the “Undertakings”)
is the sole responsibility of the EAB.
There are no generally accepted standards for reporting on compliance
with the Undertakings or in respect of related performance measures.
The reporting policies adopted by the EAB in forming their opinions
expressed within the Report are described in the sections entitled
“Monitoring Reporting and Advising” on pages 20 and 21.
Scope and approach
Our engagement was designed to provide assurance on:
• whether, in our opinion, the conclusions reached by the EAB in
respect of:
–– the validation of milestone deliveries in the period set out on
page 7;
–– the investigation of breaches set out on pages 9 and 10;
of the EAB Conclusions only and did not perform testing over the
generation of data within the underlying management information
systems of the Group or the sufficiency of evidence gathered by the
EAO.
• whether, in our opinion, the Product Key Performance Indicators
for WLR3 Analogue Top Level Provision, WLR3 Analogues Top Level
Repair (all care levels), LLU Provision – SMPF Basic Provides, LLU
Provision – MPF New Provides, Ethernet Provision – Ethernet Access
Direct, NGA Provision – GEA over FTTC, IPstream Connect Provision,
IPstream Connect Repair, Wholesale Broadband Connect Provision
and WBC Migration shown on pages 28 to 30 are properly compiled
from the underlying management information of the Group. In this
regard, we planned our procedures to provide us with reasonable
assurance they are properly compiled from underlying management
information. We completed tests over data consolidation and
reporting only and did not perform testing over the generation
of data within the underlying management information systems of
the Group.
In addition, we reviewed the minutes of EAB meetings, discussed with
employees of the EAO the processes to collate the Report and reviewed
the remainder of the Report for consistency with our knowledge of
the Group in order to report whether anything came to our attention
to indicate that the remainder of the Report is inconsistent with the
findings of our work.
–– the review of key compliance risks as set out in the table on
page 13;
We planned and performed our evidence-gathering procedures to
obtain a basis for our conclusions in accordance with the International
Standard on Assurance Engagements 3000 (Revised) – “Assurance
Engagements other than Audits or Reviews of Historical Information”.
We have not performed an audit, and therefore do not express an audit
opinion in accordance with International Standards on Auditing (UK and
Ireland).
–– the key risks included in the EAB risk register as set out on page 16;
and
We believe that our work provides a reasonable basis for our
conclusions.
–– the Undertakings status indicators as set out on pages 22 to 25.
Considerations and limitations
–– the investigation of complaints made to the EAB and BT set out on
page 11;
–– the themes and results of quick checks performed in the period as
set out on page 12;
(the “EAB Conclusions” each indicated by the
are complete and
consistent with the underlying management information of the
Equality of Access Office (“EAO”) and are consistent with the evidence
gathered by the EAO in accordance with the Reporting Policy.
In this regard, we planned our procedures to provide us with
reasonable assurance on the completeness and consistency of the
EAB Conclusions with underlying management information. We
obtained an understanding of the relevant controls and procedures
applied by the EAB and the EAO to generate, aggregate and evaluate
information in respect of the Group’s governance, delivery and
ongoing compliance with the Undertakings, including the EAO
monitoring and reporting, audit and validation plan, quick checks,
exemptions and variations and breaches and complaints processes.
We completed tests over data consolidation and reporting in respect
Book 1.indb 33
The Group’s governance measures to ensure compliance with the
Undertakings represent a set of internal controls and other actions
designed to provide reasonable assurance regarding compliance, in
all material respects, with each of the Undertakings and to support
reporting of compliance with those Undertakings. Further, the EAB’s
governance measures to monitor, assess and report on the Group’s
compliance with the Undertakings represent a set of internal controls
and other actions designed to provide reasonable assurance regarding
the assessment of compliance, in all material respects, with each of
the Undertakings. Because of the inherent limitations in any set of
internal controls, for example the degree of judgement required in
applying certain controls, internal controls may not prevent, detect
or report non-compliance with the Undertakings. Also, projections
of any evaluation of effectiveness to future periods are subject to the
Undertakings status indicators
Respective responsibilities of the Equality of
Access Board and PricewaterhouseCoopers LLP
21/05/2012 23:53
34
Undertakings status indicators
risk that controls may have become inadequate because of changes
in conditions, or that the degree of compliance with the policies or
procedures may deteriorate.
This report, including the conclusions, has been prepared for and only
for the EAB and Ofcom for the purpose of allowing the EAB to meet its
requirements under the Undertakings and for no other purpose. We do
not, in giving these conclusions, accept or assume responsibility for any
other purpose or to any other person to whom this report is shown or
into whose hands it may come save where expressly agreed by our prior
consent in writing.
Conclusions
In our opinion:
• the conclusions reached by the EAB in respect of:
–– the validation of milestone deliveries in the period set out on
page 7;
–– the investigation of breaches set out on pages 9 and 10;
–– the investigation of complaints made to the EAB and BT set out on
page 11;
–– the themes and results of quick checks performed in the period as
set out on page 12;
–– the review of key compliance risks as set out in the table on
page 13;
–– the key risks included in the EAB risk register as set out on page 16;
and
–– the Undertakings status indicators as set out on pages 22 to 25.
(the “EAB Conclusions” indicated by the
are properly compiled
from the underlying management information of the EAO and are
consistent with the evidence gathered by the EAO in accordance with
the Reporting Policy;
• the Product Key Performance Indicators for WLR3 Analogue Top
Level Provision, WLR3 Analogues Top Level Repair (all care levels),
LLU Provision – SMPF Basic Provides, LLU Provision – MPF New
Provides, Ethernet Provision – Ethernet Access Direct, NGA Provision
– GEA over FTTC, IPstream Connect Provision, IPstream Connect
Repair, Wholesale Broadband Connect Provision and WBC Migration
shown on pages 28 to 30 are properly compiled from the underlying
management information of the Group; and
Based on the work performed, nothing has come to our attention to
indicate that the remainder of the EAB Annual Report for the year
ended 31 March 2012 is inconsistent with the findings of our work.
PricewaterhouseCoopers LLP
Chartered Accountants
London
15 May 2012
Book 1.indb 34
21/05/2012 23:53
Undertakings status indicators
35
Glossary
MIS
Management Information Systems
MPF
Metallic Path Facility, a circuit comprising a pair of twisted
metal wires between an end-user’s premises and a main
distribution frame
BT Wholesale and BT’s two downstream businesses BT
Global Services and BT Retail
NGA
Next Generation Access
Non-BT CPs
Communications Providers external to BT
Business
systems stack
A collection of inter-related systems which allow BT’s
business customers to be served equivalently
OICs
BTNI
BT Northern Ireland
Openreach Industry Commitments, a voluntary range
of obligations in return for the 2009 variation to the
Undertakings
CCI
Customer Confidential Information
OSS
Operational Support Systems
CDD
Customer Delivery Date
OTA2
Office of the Telecommunications Adjudicator
CI
Commercial Information
Passive inputs
CPs
Communications Providers
CPCs
Comparative Performance Charts
Products that allow greater access to the underlying
infrastructure on BT’s Next Generation Access network
with no use of electronics/power
EAB
Equality of Access Board
PwC
PricewaterhouseCoopers LLP
RFS
EAD
Ethernet Access Direct, a point-to-point access product
in the Ethernet portfolio offering high bandwidth
connectivity, linking end user sites, CP networks and BT
exchanges
Ready for Service, which is the date by which an EoI
product or service is available for use by other CPs for their
new end-users
SMP
Significant Market Power
SMPF
Shared Metallic Path Facility, access to the non-voiceband
frequencies of the Metallic Path Facility
Annex 2
Less stringent restrictions related to the Undertakings
applied to BT employees
BES
Backhaul Extension Service, a legacy product in the
Ethernet portfolio
BT CPs
Equality of Access Office, the team which supports the EAB
EBD
Ethernet Backhaul Direct, which provides uncontended
access from an access node to a handover point
SoR
Statement of Requirements, the process by which CPs
submit their product requirements to BT
EMP
Equivalence Management Platform, the strategic system
underpinning the delivery of EoI products
WBC
Wholesale Broadband Connect, a next generation copper
broadband product
EoI
Equivalence of Inputs, which means that BT provides the
same product or service to all CPs on the same timescales,
terms and conditions by means of the same systems and
processes
WES
Wholesale Extension Service, a legacy product in the
Ethernet portfolio
WEES
Wholesale End-to-End Service, a legacy product in the
Ethernet portfolio
WLR
Wholesale Line Rental, a product supplied by Openreach
which is used by CPs to offer telephony services using their
own brand, pricing structure and billing, but using BT's
network
WLR3
An EoI version of Wholesale Line Rental
FTTC
Fibre-to-the-Cabinet, an NGA technology that involves
installing fibre to street cabinets and using the existing
copper infrastructure from the cabinet into the home
FTTP
Fibre-to-the-Premises, an NGA technology that involves
installing fibre into homes or premises as an overlay of the
copper local loop
GEA
Generic Ethernet Access, a product enabling broadband
connections over Next Generation Access
IBMC
Installed Base Migration Complete, which is the date by
which the migration of all of the relevant BT installed
customer base to the EoI product or platform is completed
IPstream
Connect product supplied by BT Wholesale to enable BT
CPs and non-BT CPs to offer broadband services to end
users
ISDN/ ISDN2/
ISDN30
Integrated Services Digital Network a technology allowing
voice, internet and video to be delivered via the same
dedicated line
KPI
Key performance indicator
LLU
Local Loop Unbundling, the process by which CPs can rent
the copper lines between BT's exchanges and customer
premises from Openreach to provide voice and broadband
services using their own equipment
Book 1.indb 35
Undertakings status indicators
EAO
21/05/2012 23:53
BT Group plc
Registered office: 81 Newgate Street, London EC1A 7AJ.
Registered in England and Wales No. 4190816.
Produced by the Equality of Access Office
Registered office: 81 Newgate Street, London EC1A 7AJ.
Registered in England and Wales No. 4190816.
Produced by BT Group.
Designed by saslondon.com
Printed by RR Donnelley.
www.bt.com
Please recycle
Book 1.indb 36
21/05/2012 23:53