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3. Core Policies

3.1. Introduction (Core Policies)

This section aims to outline core policies and principles with implications for all members of the Open Energy ecosystem. Please note that it is beyond the scope of Open Energy Phase 3 to produce detailed guidance and tooling accompanying all policies in this section. Development of these resources is a priority for future development and will be approached openly; using consultation with Advisory Groups, tester organisations and members to ensure that resources meet member needs. All terminology used in this section is outlined in the Open Energy Glossary.

3.2. Metadata

Data sets are described by Data Providers through metadata files. The format for these can be found at Data Set Metadata

3.3. Data Sensitivity Classes

The Open Energy ecosystem incorporates a range of categories of data that have varied levels of sensitivity. In order to handle this complexity, and to ensure data is appropriately protected, Open Energy has developed a system of data sensitivity classification.

In Open Energy Phase 2 (September - December 2020), the Policy and Membership Advisory Group established that a system of data classes should be used to distinguish data of different sensitivities shared within the Open Energy ecosystem. This policy builds from Phase 2 foundations and has been created with input from the Open Energy Advisory Groups, Review Track, and public consultation responses.

3.3.1. Policy details

Open Energy operates a system of five data sensitivity classes, graded across three dimensions of sensitivity: personal, commercial, and security. Personal sensitivity considers data defined as ‘personal data’ by the UK DPA 2018, and related privacy and consumer protection implications. Commercial sensitivity considers intellectual property, risk and commerciality. Security sensitivity includes critical national infrastructure and cybersecurity.

Classes are presented in the table below. A definition, specification and dataset examples for each class will be provided in the Open Energy Operational Guidelines. Data Providers will then assess their datasets using the Operational Guidelines and allocate them to a class, prior to sharing them via the Open Energy ecosystem.

Open Energy data classes are designed to supplement, not replace, the Modernising Energy Data Best Practice Guidance (Point 12) determining whether data should be made Open, Shared or Closed. In particular, Open Energy data classes are designed to provide further nuance to the category of Shared data - identifying three different classes in this space, with different sensitivity profiles.

Detailed guidance and tooling, designed to support Data Providers to classify datasets consistently and fairly, will be inserted in due course beyond Phase 3. This will follow processes of consultation with Advisory Groups and tester organisations.

Table 3.1 data sensitivity classes in the Open Energy ecosystem

Data Class	Description	Example Datasets	Personal Sensitivity	Commercial Sensitivity	Security Sensitivity
OE-C	Closed data - limited to internal organisational access only or limited, bespoke bilateral contracts under specific circumstances. May be subject to hard legal barriers to sharing. May be security-critical information relating to operational technology supporting critical national infrastructure owned by an Operator of Essential Services. Never suitable to share within the |OE| ecosystem.	Business-critical proprietary information or IP, critical asset locations, classified information.	Very High	Very High	Very High
OE-SP	Datasets which include personal data, requiring appropriate consent to share, or other legal bases to data processing, as defined by the EU GDPR and brought into UK law via the DPA 2018. Currently not suitable to share within the |OE| ecosystem, with future extensibility subject to consultation.	Smart meter data, home temperature preferences, protected characteristics or special category data (e.g. dependence on power due to health conditions), individual Electric vehicle charging records, transaction data.	Very High	Medium / High	Medium / High
OE-SB	Datasets which do not include personal data and which can/could be shared, but currently require bilateral contract negotiation. May include data currently shared on the basis of group-based, name-based or purpose-limited access. May include aggregated data about individuals, subject to best practice adherence (e.g. ICO anonymisation code.) Anonymised data using non-aggregative techniques are currently not suitable to share within this sensitivity class due to complex risks related to individual re-identification. Future extensibility to sharing anonymised data is subject to consultation.	Public Electric vehicle charge-point performance, generation asset performance, aggregated smart meter data, aggregated microgeneration export profiles, ‘Investment grade’ data (e.g. suitable granularity for financial decision-making), sensitive asset data.	Medium	Medium / High	Medium / High
OE-SA	Shared data - datasets which can/could be shared, but which require the user to agree to ‘light touch’ T&Cs to access and use (e.g. non-commercial clauses such as those under CC-BY-NC).	Network capacity, outage data, weather predictions, European space agency data, daily smart meter installations, geolocation information for non-sensitive assets (e.g. Renewable Assets, EPC certificates).	Low	Medium	Low
OE-O	Open Data – full open access, under an open data licence. Free to use, by anyone, for any purpose.	Lower Super Output Layer ID (LSOA), Digest of UK Energy Statistics, regulatory data (e.g. licensing categories, institutional charters or Terms of Reference, etc.)	Very Low	Very Low	Very Low

3.4. Data Access Conditions

This policy focuses on data access. Data access refers to determining what types of conditions may be specified for |DCs| to meet in order to gain access to datasets in different sensitivity classes, and how access rules are articulated. This policy has been created with input from the Open Energy Advisory Groups, Review Track, and public consultation responses.

The Open Energy Governance Service (OEGS) is responsible for providing Data Providers with verified information about Data Consumers, in line with specified access conditions for each dataset. However, the Data Provider is solely responsible for determining whether any given API request should be honoured (i.e. data access granted), and the licensing terms for any data returned in response to that request. This is due to requirements for control to rest with the Data Provider only.

It is expected that Data Providers will grant access reliably and fairly, in line with the access conditions that they specify. In the event that access is refused, there will be a mechanism for flagging this with the OEGS for review and dispute management. Data Providers must be able to show clear justification for access refusal. Repeat refusal or non-compliance with specified access conditions may result in penalties (to be determined after Phase 3).

This policy focuses on access conditions for classes OE-SA and OE-SB only. Personal data (OE-SP) are out of scope for development during Phase 3. Future extensibility of the Open Energy ecosystem to OE-SP data will be consulted on in future phases of project development.

3.4.1. Policy details (Data access conditions)

Data Providers will allocate each of their datasets to a sensitivity class prior to sharing them within the Open Energy ecosystem. Data access conditions will then be applied in a manner that is proportionate to the sensitivity profile of each class. We propose to use the data sensitivity classes previously established as a basis for considering access conditions, but not as a complete determinant.

Our approach must serve the goal of reducing friction in sharing energy data, while also balancing two distinct sets of needs:

1. Data Providers: to retain control over their data.

2. Data Consumers and Service Providers: to access multiple datasets in a clear and manageable way.

As such, we define a standardised range of access condition types as a mechanism to balance the factors outlined above. This acknowledges the need for more nuance than would be captured under a ‘one size fits all’ approach for each sensitivity class. Instead, our policy enables some tailoring within defined parameters.

The table below describes access conditions for each of the Open Energy data sensitivity classes. It also demonstrates the rationale for this guidance - identifying the lack of standardised access conditions for OE-SA and OE-SB datasets as a cause of cost and friction in energy data sharing.

Table 3.2 Data sensitivity classes and access conditions in scope

Data Class	Access Conditions
OE-C	Determined and governed by the Data Provider only.
OE-SP	Currently determined by legislation including, but not limited to: GDPR / DPA 2018, the Data Access and Privacy Framework, and the Smart Energy Code. Data Providers may also apply additional non-standard access conditions, such as payment or purpose-based. Determining access conditions for personal data is beyond the capacity of Open Energy in Phase 3 (February - July 2021) and beyond the scope of this consultation. Future extensibility to be considered based on consultation in due course.
OE-SB	Currently non-standardised, determined by bilateral contract and bespoke negotiation. Subject of the current policy.
OE-SA	Currently some standardisation, however bespoke arrangements remain common. Subject of the current policy.
OE-O	No access conditions - free and accessible to all users.

Table 3.3 Open Energy access conditions

Condition domain	Considerations (examples - not exhaustive)	Applicable class
Payment	Free or paid data Graduated payment rates (e.g. higher granularity) One-off or subscription payment rates	OE-SB and OE-SA
Security compliance	UK Government Minimum Cybersecurity Standard UK Government ‘Secure by Design’ IoT guidance Codes of conduct governing Critical National Infrastructure	OE-SB and OE-SA
Regulatory compliance	Networks business separation provisions Competition law Adherence to section 105 of the Utilities Act 2000	OE-SB and OE-SA
Standards compliance	Meets MED Data Best Practice Guidance Meets relevant ISO standards	OE-SB and OE-SA
Organisation type	Local Authorities Energy networks Schools, colleges and universities Code signatories Charities Specific Open Energy membership tiers (e.g. SME)	OE-SB
Group membership	Certain use cases (e.g. community energy project development) Commercial or development partnerships Certain purpose-based groups (e.g. consortium of fuel poverty-reduction organisations) Social housing retrofit Public Electric vehicle charge-point planning	OE-SB
Other	Auditing clauses Individuals handling the data within a Data Consumer must have completed certain training (e.g. ONS Safe Researcher).	OE-SB and OE-SA

3.4.2. Group based access control

There are two ways in which group-based access can be defined.

1. The group can be externally defined. In this case, an external source provides documentation group membership and duration. For example, a group could be created that encompasses all UK retail energy suppliers licensed by Ofgem, or the members of a research consortium listed on a particular grant. In both cases, group membership is clearly defined by an external document (e.g. Ofgem licensee list, grant contract) applicable for a defined time period.

2. The group can be self-defined. In this case, documentation of group membership and duration is provided by group members themselves. For example, a set of organisations partnering on a particular use-case or commercial partnership may be able to self-define as a group. Documentation may comprise a project plan or multilateral commercial agreement.

Further policy-development is required to ensure the inclusion of self-defining groups in the Open Energy ecosystem is fair and transparent. Appropriate governance arrangements will also need to be established, for example to prevent confusion for Data Providers or instability associated with too-frequent changes in group creation or membership. As such, it is likely that group-based access defined through authoritative external sources will be explored first in OEGS development going forward.

3.4.3. Use case based access control

This type of access condition is difficult to design due to inherent subjectivity in defining the bounds and meaning of particular use cases. While some Data Providers could be comfortable granting access on the basis of broadly defined use cases, such as fuel poverty reduction, this may not be appropriate to all Data Providers or for more sensitive datasets. As such, it is proposed that use case-based access could also be facilitated through the creation of either externally-defined or self-defined groups as outlined above. For example, partners within a Local Authority social housing retrofit project could form a group. This group would be accompanied by information about the specific use case it represents - for example participants, timescale, activities, commercial status etc.) enabling Data Providers to make an informed decision regarding whether to grant access. Any future consideration of access based on more broadly-defined use-cases would be subject to consultation and further policy development.

3.4.4. Prioritisation

Inclusion of all access conditions outlined above will require significant technical build. In the near future, Open Energy may prioritise the establishment of access conditions that industry feedback has indicated take priority. These include: payment, security compliance, regulatory compliance and externally defined groups. As flagged above, in order to maintain robust governance and the Open Energy trust framework, development of additional access conditions may require further policy work.

3.5. Data Licensing

This policy has been created with input from the Open Energy Advisory Groups, Review Track, and public consultation responses. These policies are presented jointly as they unite the processes of determining who can access a particular dataset and what can be done with that dataset. Please note that this policy does not outline draft legal text of the final licences - this is being developed separately with legal support. All ideas outlined in this document remain subject to legal assessment.

3.5.1. Creating access rules

The previous section on Data Access established a set of concerns (e.g. group-based access, payment-based access etc.) which may be considered when determining who can access a dataset. To facilitate this policy, we propose a system whereby access and capability grants are determined, for each request to a Data Provider’s API, on the basis of a set of rules defined and published by that Data Provider.

Grants are based on three sources of information:

1. Information from the Open Energy Governance Service (OEGS) about the Data Consumer making the request

2. Information known by the Data Provider (separately from Open Energy) about the Data Consumer making the request, such as customer status, commercial relationships, bilateral agreements, active payments/subscriptions or similar

3. Rules defined by the Data Provider - predicated on information provided by OEGS and/or, where necessary to preserve privacy or security, properties known to the Data Provider only

Information provided by OEGS to Data Providers can cover two kinds of properties:

• Inherently true properties known to Open Energy, such as:

  • The unique ID of the Data Consumer

  • The Data Consumer represents a Local Authority / SME / Enterprise / Community Organisation / Academic group, etc

  • The Data Consumer has a particular identity such as a registered name

  • Open Energy has performed identity assurance to a particular level

• Transient, time-bounded properties known to Open Energy, such as:

  • The Data Consumer is a member of a particular scheme, group, or consortium (e.g. a two-year academic research project under a particular named grant)

  • The Data Consumer has signed a particular document on a particular date (e.g. documentation of a research partnership)

When defining an access rule, Data Providers will also be required to confirm whether the rule is definitive or indicative. Definitive rules stipulate that a Data Consumer satisfying the stated conditions will be given access. Indicative rules stipulate that a Data Consumer satisfying the stated conditions may be given access, but there may also be other conditions (e.g. the existence of a payment or bilateral agreement) that must be confirmed by the Data Provider outside the Open Energy ecosystem before access is granted. If access requests are refused, Data Providers must be able to demonstrate a justifiable reason for doing so. Data Consumers can challenge access refusals through a dispute-resolution mechanism (part of the OEGS) if this is required. Guidance regarding acceptable/unacceptable reasons for access refusal, the dispute-resolution mechanism, and OEGS dispute-resolution processes will be developed and published in Phase 4 of the project.

The flow of information associated with access control is shown below - this assumes the Data Consumer has already acquired an access token from the authorization server. Access control and capability grants are processed on a pre-request basis, within the Data Provider, in the box Make access and license decision based on details:

Fig. 3.1 Access control authorization flow showing application point for access control and capability grant rules

3.5.2. Associating access rules with capabilities

In the Open Energy model, licensing is expressed as the grant of a set of capabilities and associated obligations, scoped to the results of a single API call and verified through a non-repudiable digital signature.

This is defined using a rules language, the details of which can be found at Access Control and Capability Grant Language

3.5.3. What are licenses and capabilities?

A data licence is a legal instrument setting out what a Data Consumer can do with a particular artefact (e.g. dataset). This grants certain ‘capabilities’ to the Data Consumer, comprising a clear expression of things they can do with the artefact. For example, the CC-BY 4.0 Creative Commons licence is highly permissive, granting capabilities such as: reuse of the licensed artefact for any purpose, redistribution of the artefact, and sharing derivatives of the artefact - so long as the author is credited with the original. By contrast, the CC-BY-ND 4.0 Creative Commons licence grants the capability to reuse the licensed artefact for any purpose, however it does not grant the capability to redistribute derivatives of the artefact.

3.5.4. How will capability grants work in practice?

Each time a Data Consumer makes an API call, the data returned will be associated with a particular set of capability grants. These can be bound to the data through a non-repudiable digital signature, designed to ensure transparency in the event of any disputes regarding data use. Capability grants will be converted into a licence through the Open Energy Governance Service (OEGS). Alongside the legal text of the licence, the OEGS will make details of capabilities available to Data Consumers as an easy to understand set of notation/icons. Open Energy Search will also show the license (capabilities and obligations) associated with a dataset in the search results, allowing for searches to be filtered by license in order to promote transparency from the outset.

Open Energy defines a set of common capabilities - Data Providers may create custom capabilities, but we strongly suggest that this should only be done in exceptional cases. The common initial set of capabilities can be found at Standard capabilities. We propose to use this list as the building blocks for our system of capability grants; whereby the range of capabilities, associated legal text, and ‘human readable’ notation/icons is standardised within the Open Energy ecosystem.

Note

There is potential for redistribution of derivatives to be managed in more granularity through use of the data pyramid (see Figure 2 below). This could permit Data Providers to specify what level of derivative insights can be passed on (e.g. raw data / results of analysis / recommendations building on analysis).

Fig. 3.2 The data pyramid

3.5.5. Obligations accompanying capability grants

Capability grants will be accompanied by details of any obligations that the Data Consumer must abide by when exercising a capability. Data Providers must specify any such obligations when associating capabilities with an access rule. As with capabilities, the range of obligations will be standardised within the Open Energy ecosystem and will be included in the digital signature binding the API return with the capability grant.

Open Energy research has identified a set of common obligations associated with capabilities granted by licences used in the energy sector. These include obligations to:

• Credit the author(s) of the original artefact.

• Provide a statement accompanying derivatives works/products/services explaining that the original (credited) artefact was used in their creation.

• Provide ownership statements for derivative works/products/services.

• License any derivative works/products/services with the same capabilities (‘share-alike’).

• Establish a limit in liability for use of the data in its current state.

We propose to use this list as the building blocks for our system of obligations accompanying capability grants; whereby the range of associations, associated legal text, and ‘human readable’ notation/icons is standardised within the Open Energy ecosystem.

3.5.6. Why are we proposing this approach?

Constructing a single licence for each dataset, designed to govern all possible scenarios for its use, has to date resulted in the creation of long, complex licensing agreements that are not easily readable by Data Consumers. Industry feedback indicates that this creates friction and costs, for example associated with data-related legal support or accidental misuse of licensed data. These issues are further compounded by growth in the creation of bespoke licences that include non-standard capabilities or legal wording.

Open Energy has identified an alternative approach to single data licences, which is currently more commonly used within data science and software development communities outside of the energy sector. This approach permits dual or multiple licensing of an artefact, whereby the individual licences are kept as simple as possible. For example, dual licensing is commonly used in circumstances where software code is released for free under one licence, then to paying customers under a more permissive licence.

Our approach accepts that a degree of licence pluralism is necessary, and indeed valuable, in supporting a diversity of data types, actors and use-cases within the energy data ecosystem. We are aware that a multiple licensing approach may prompt some concern regarding a risk of licence proliferation and/or opacity. However, our approach can reduce these risks by rationalising and standardising the parameters in which licensing occurs. To do this, Open Energy will work to standardise the range of capabilities offered, the legal text governing how these capabilities are expressed, and the ‘human-readable’ ways in which these capabilities are communicated to Data Consumers. Beyond Phase 3, we will further develop guidance for Data Providers encouraging simplicity and discouraging unnecessary protectionism, while also maintaining appropriate protections for higher sensitivity classes of data.

Early feedback from Advisory Groups and critical friends has suggested that benefits of this approach could include reduced legal, staff and time costs associated with improved searchability, transparency, readability and standardisation of capability grants. By making licensing simpler and faster, it could also help level the digital playing field by offering particular benefits to new, small or ‘public interest’ actors lacking in-house expertise or budget. In the longer term, adoption of this approach could have benefits across the sector as new data markets incentivise Data Providers to align with Open Energy standardisation.

Fig. 3.3 Licensing model per API call

3.5.7. Example access control and capability grant scenarios

Note

These scenarios have been created to reflect decisions that could be faced by Data Providers in our Phase 3 use-case, in which a Local Authority is seeking data to plan the retrofit of social housing with low carbon technologies. Please note that the scenarios are exemplary only and do not necessarily represent the stances of any Data Providers involved in testing.

Table 3.4 Scenario 1

Dataset	DNO capacity/constraint data
Sensitivity class	OE-SA
Access control domains	Access granted to all Open Energy members equally
Access rules	oe:member unary access condition
Capability grants	oe:member grants oe:use_any, all Data Consumers who are members of Open Energy can access this data set, and receive the right to use for any purpose (see Standard capabilities for more detail)
Obligations	Derivatives of the artefact must be accompanied by text stating that the original artefact was used in their creation. oe:member grants oe:use_any requires oe:by (see Standard obligations for more detail)

Table 3.5 Scenario 2

Dataset	Public Electric vehicle chargepoint use and economic performance profiles
Sensitivity class	OE-SB
Access control domains	Group-based and payment-based access conditions
Access rules	Two distinct access constraints: oe:org_type in ['local_authority', 'academic'], provider:customer_level == 1 - local authorities and educational institutions are granted access if they are paid customers of the Data Provider at their standard rate provider:customer_level >= 2 - energy networks are granted access if they are paid customers of the Data Provider at their large business level
Capability grants	In this scenario it would be technically possible for the Data Provider to apply different capability grants to the two different access rules. In this case the Data Provider chooses not to as they have charged commercial entities a higher access fee and are therefore happy for all Data Consumers to be granted the same capabilities. The result is the same set of capabilities (the same licence) is applied to both access rules. oe:org_type in ['local_authority', 'academic'], provider:customer_level == 1 grants oe:use_any provider:customer_level >= 2 grants oe:use_any
Obligations	The Data Provider chooses the same obligations to be applied to both access rules oe:org_type in ['local_authority', 'academic'], provider:customer_level == 1 grants oe:use_any requires oe:by provider:customer_level >= 2 grants oe:use_any requires oe:by

Note

Scenario 2

This more complex scenario detailed above involves a combination of properties known to Open Energy (the market sector of the Data Consumer - Local Authority, Educational Institution, or Energy Network) along with properties which are only known to the Data Provider (the payment status of the Data Consumer). We can do this because the rules are evaluated within the Data Provider, and not externally within Open Energy’s Governance Service, an entity which is not aware of any commercial arrangements between the Data Provider and Data Consumer.

Table 3.6 Scenario 3

Dataset	Solar panel performance data
Sensitivity class	OE-SB
Access control domains	Use case-based and payment-based access conditions
Access rules	Two rules are created oe_group:plymouth_lct - access to use case participants, here defined as a group lct managed by plymouth (the ID of a local council organisation) and administered using the OEGS facilities provider:customer - access to all other Open Energy members if they have a paid account with the Data Provider
Capability grants	The Data Provider chooses to apply two different capability grants (dual licences) for the two access rules, reflecting the fact that their dataset is commercially sensitive, therefore they require payment for its use beyond non-profit or development activities. oe_group:plymouth_lct grants oe:use_dev, oe:use_noncom provider:customer grants oe:use_any, oe:redistribute_combined, oe:combine_any, oe:adapt_any
Obligations	The original source of the artefact must be credited in all direct uses, derivatives of the artefact must be accompanied by text stating that the original artefact was used in their creation, and derivatives must be licensed under the same terms as the original. oe_group:plymouth_lct grants oe:use_dev, oe:use_noncom requires oe:sa, oe:by The original source of the artefact must be credited in all direct uses, and derivatives of the artefact must be accompanied by text stating that the original artefact was used in their creation. There is no obligation to license derivatives of the artefact under the same terms as the original. provider:customer grants oe:use_any, oe:redistribute_combined, oe:combine_any, oe:adapt_any requires oe:by

3.5.8. Risks of license proliferation

As outlined in previous consultations, the Open Energy data ecosystem is more complex than Open Banking. We are therefore proposing a different approach to licensing in order to balance a wide range of needs and data types. The approach further responds to feedback from our Advisory Groups and Review Track that data access and licensing cannot be served by a one size fits all approach as this would risk restricting the diversity of the ecosystem and potentially undermining the strength of the trust framework.

We are aware of concerns within the industry that multiple licensing could present risks of licence proliferation, introducing complexity to the landscape which can act as a barrier for data consumption. Open Energy acknowledges this risk and presents the following points of response:

Firstly, some stakeholders have suggested that Open Energy should take a ‘modular approach’ to building a ‘single Open Energy licence’. This suggestion outlines a permissive core or standard licence that is presented to all Data Providers as the default option for publishing their data. If this is not appropriate for a particular dataset, Data Providers would then have the option of adding restrictions (i.e. removing capabilities) by adding modular sections of legal text. In practice however, a modular approach doesn’t reduce licence plurality as each modification of a licence (e.g. addition of modular text) is viewed legally as the creation of a new licence. Open Energy’s approach instead accepts a degree of licence plurality, but will work to standardise the discoverability, scope and ease of understanding of that pluralism by offering a limited, standardised and searchable range of capabilities. This will be accompanied in due course by guidance for Data Providers, tailored to each sensitivity class, encouraging as much openness as possible while publishing data safely and creating a thriving marketplace.

Secondly, we acknowledge that the energy data landscape already incorporates a significant degree of licence proliferation. For example, it is already common for energy system actors to publish data under bespoke licences containing non-standard clauses and/or legal wording. In standardising the range and expression of capabilities, Open Energy aims to rationalise some unnecessary forms of licence proliferation in the sector and reduce legal costs to Data Providers by reducing the circumstances under which bespoke licences are necessary.

3.5.9. Is there a risk of licences changing too frequently or without notice?

In any licensing model that is not explicitly time-bound, there is a risk that the Data Provider may choose to change the licence arbitrarily. We have received feedback that bespoke licensing in the energy sector already produces insecurity for Data Consumers, who are concerned about the longevity of particular licences in a changeable environment. For example, an energy forecasting company relies on predictable access to, and capabilities to use, a range of datasets (e.g. weather data). Changes to the capabilities granted for any of these datasets undermine this kind of business model, with additional proxy consequences for carbon savings that could be achieved as a result of better integration of renewable energy generation.

Open Energy aims to address this problem by encouraging Data Providers to indicate the length of time they commit to retaining the same capability grant for a particular access rule. Although this will be optional, we hope that Data Providers will be incentivised to do so as this encourages confidence in the market. We are also exploring the possibility of building a notification system to alert Data Consumers either to upcoming or new changes in capability grants to ensure this is done transparently and with adequate warning where possible.

Note

The time ranges described above are NOT a time limit on the capabilities granted in response to a single request, it instead specifies a range within which the access rules and their corresponding capability grants will not change.

Beyond designing positive behavioural and market incentives, it is beyond the scope of Open Energy to control licence-changes as this remains within the legal rights of the Data Provider.

3.5.10. Where are these rules specified?

The access control, capability, and obligation grants form part of the metadata for a dataset. This is expressed in a file, hosted and maintained by the Data Provider responsible for the data set. The provisional structure of the entire file can be found at Data Set Metadata, in particular the section on the Access Block

3.5.11. Where are these rules evaluated, and by whom?

Following our guiding principle that Data Providers remain in control of their data at all times, these rules are evaluated within the Data Provider API implementation. This is necessary to allow for decisions predicated on information only known to the Data Provider, but this could impose additional complexity when setting up and implementing a Data Provider. To mitigate this, we will provide clear specifications and semantics for the rules language, along with a reference implementation in the Python language.

The current language specification can be found at Access Control and Capability Grant Language, the time bounds and other properties form part of the Access Block specification in the metadata file format.

3.6. Service Desk and Notifications

Open Energy acknowledges industry feedback regarding the need to develop a Service Desk and notifications function. Developing the full function is beyond the scope of project Phase 3, however it remains an active area for future development. In the meantime, members will be directed to use a specific email address to catalogue emerging needs and discuss appropriate OEGS support. We proposed to use learning from this prototype to inform future service and policy design.

3.7. Dispute Resolution

Open Energy acknowledges industry feedback regarding the need to develop a dispute resolution function as part of the OEGS. While developing the full function of dispute resolution falls beyond the scope of Open Energy Phase 3, this remains an active area for future development. Given the complexity of this topic, ongoing stakeholder engagement and consultation will be used to shape the future service. In the meantime, members will be requested to use a specific email address to catalogue any difficulties and discuss appropriate OEGS support. Learning from this prototype will inform future service and policy design, alongside consultation activity.