Given the many conversations I’m in at the moment I believe it very important to have as much debate as openly as possible, as this impacts everyone.

Here’s a question:

How should the UK implement its National Data Infrastructure so that it provides consistent control, sharing, and security for data, much like other public infrastructures such as roads and utilities?

“Everything should be as simple as it can be, but not simpler”
[often attributed to Einstein]

Having initiated ‘data as infrastructure’ at a political level in the UK in 2013, I’ve been watching and learning on this for a long time. We’ve made remarkable progress in some areas, less so in others.

Let’s explore, starting with some lessons learned.

One immediate reflection is that as over 60 countries moved to copy the Open Banking Standard, those who took only ‘parts’ of the system tended to experience less ideal outcomes (to the point that they often add them back in later to help course-correct — most notable are those who thought this was ‘just a tech problem’ and only took the open API principles).

We can look to past UK data initiatives like MiData and Open Banking and potentially infer that voluntary-only initiatives and centralisation do not work, and that the decentralised nature of Open Banking was more successful. However, these are shallow reflections.

We can point to three factors beyond centralised or voluntary which are dependent on the use case:

1. Market incentives: there must be an economic argument that policy can then amplify or mandate. If there is no financial incentive, there will be no movement (regardless of central vs decentralised, mandate or not — mandates are also often ignored). Midata was mostly tech-led, Open Banking was use-case led.
2. Removal of friction: Removing transactional friction may seem like something everyone wants, but not if your current business model relies on it. There must be “something in it” for everyone, or at least a path to cost reduction or a new business model. Removing friction can help everyone go together: this is never a ‘technology problem’ (e.g. absence of a data ontology).
3. Mandates: if the friction is ‘too high’, regulatory intervention is necessary to mandate participation and move the market. However, if the market can demonstrate self-initiation, then ‘endorsement’ from government can be sufficient to drive impact. Value creation must be visible in both cases.

I believe that we need to embrace these factors in our systems design.

We need to:

1. work out where the lines are drawn between central, pre-competitive and competitive areas;
2. ask what the role of regulation is, and at what granularity
3. query how things can be implemented in a way that humans (and machines) can and want to adopt
4. ensure those governing, operating and participating can be helped in their assessments of compatibility and interoperability
5. work out how to prioritise and create clear (and stable) roadmaps that enable investment to be made

I believe that we can build on the success of sector-specific approaches:

The Open Banking model’s success lies precisely in its sector-specific, incremental approach. It focused on the unique needs of banking, where security, standardisation, and customer trust were paramount.

Copying the Open Banking model into other sectors (e.g., energy, transport, health) isn’t about duplication but about applying tested frameworks tailored to each industry.

Without considering the market incentives for participation we risk techno-utopian thinking

Instead of trying to create a complex, overarching architecture that risks being too broad, a sectoral approach allows for flexibility and adaptation to industry-specific challenges. This carries a risk of fragmentation, and equally a potential to mandate cross-sector interoperability without defining exactly what this means in detail for everyone. The risk of push back on over-reach is material and catastrophic (in terms of adoption, if it fails). Further, market-incentives will be market-specific.

Avoiding Over-Standardisation

National Data Architecture risks over-standardisation and could stifle innovation instead of enhancing it. Different sectors have wildly varying levels of data maturity, hugely variable data governance needs and challenges, and a one-size-fits-all approach is highly likely to impose unnecessary constraints on sectors that are not as ready for them.

For example, imposing the level of data governance on the industrial sector that is required in the financial sector is (today) not realistic. We are, however, on the frontline of that journey with ESG reporting today, and it highlights the complexity of that real-financial sector bridging. Incremental improvements, like extending Open Banking principles to energy or transport can allow industries to evolve organically while keeping governance controls and security as a priority.

Pragmatism of the Incremental Approach

The incremental, domain-by-domain approach may seem less ambitious, but it offers a practical pathway to innovation that can be adopted today. Trying to design a top-down, comprehensive national architecture from the outset risks paralysis by analysis and over-planning. Learning from Open Banking and rolling out smart data initiatives sector-by-sector allows for continuous improvement and responsiveness to real-world feedback, which may be more effective than a sweeping, coordinated architecture.

Interoperability Requires Industry Engagement

Interoperability relies on industry engagement. This is best fostered through practical, sector-specific initiatives like Open Banking. Imposing an overarching system from above risks of alienating key industry stakeholders, who may resist changes that threaten their business models (this happens in every sector already, today). Open Banking’s success came from the balance of regulatory oversight and industry cooperation, a formula that can be replicated in other sectors.

Market Failures Can Be Addressed Incrementally

There are (always) risks of market failures such as data hoarding (castle & moat is still the prevalent investment model for data businesses). These issues should be tackled incrementally through sector-specific mandates rather than a top-down architecture, but can be accelerated with top-down principles.

The competition fostered by Open Banking and similar initiatives already shows promise in tackling data monopolies. An incremental, practical approach allows policymakers to address market failures as they emerge, rather than trying to solve all potential problems with a one-time top-down design.

Trust is Earned, Not Imposed

Trust in data systems cannot be imposed from the top. While Open Banking was catalysed by regulation, it earned user trust through transparency, security, and gradual adoption, not through a top-down imposition. Similarly, rolling out frameworks sector by sector allows consumers, businesses and citizens to see the benefits and gradually gain confidence in the approach. Attempting to ‘mandate trust’ top-down could backfire, especially in sectors like health, where data privacy concerns are particularly sensitive.

At IB1, our Trust Frameworks are one tool (of many) that can help foster multilateral collaboration, building on Open Banking principles.

Decentralisation Encourages Innovation

The decentralised, minimised and pre-competitive nature of Open Banking has led to its adoption and innovation. A large, centralised approach would have risked locking in certain standards or technological pathways that could hinder future innovations. Allowing sectors to develop their own interoperable standards fosters a more competitive, flexible landscape, where innovations in one sector can inform developments in another, without being dictated by a single framework.

Data governance should aim to balance impact on rights and security
while minimising its own footprint and reach

While the idea of a unified, overarching data framework may sound appealing in theory, in practice it would risk being too rigid, slow to adapt, and detached from the unique needs of individual sectors. A more pragmatic approach — building on the lessons of Open Banking and extending these principles to other industries — may offer the best balance of innovation, security, and user control.

Please feel free to comment, or message me (via LinkedIn or directly)

Disclosure: I sat on the MiData energy sector board (mostly tearing my hair out on these points); co-chaired the creation of the Open Banking Standard (through which I learned so many lessons it could fill a book or two); was founding CEO of the Open Data Institute; am co-Chair of the Smart Data Council, and run this non-profit (IB1.org) working on data governance at sector and national scale.

Thanks to Chris, Frank, Paul, Hadley and others for their feedback and inputs.

Useful links

Lessons learned from Gaia-X Data Spaces https://www.sitra.fi/en/articles/eight-lessons-from-building-data-spaces/

ODI on Data Institutions 
https://theodi.org/insights/projects/rd-data-institutions/

Icebreaker One on how it implements data sharing 
https://ib1.org/what-we-do

Open Banking (implementation entity)
https://openbanking.org.uk

Additional narrative on cities
https://agentgav.medium.com/the-porous-city-92ae986cd43c

Other opinions
https://agentgav.medium.com

Opening the OpenUK Open Technology for Sustainability day at COP26 yesterday, Lord Maude of Horsham said:

“Icebreaker One are developing our national data infrastructure. It’s as important as our roads, rail, water and broadband networks.”

Lord Maude of Horsham

Ofgem, BEIS and UKRI pledge support for Open Energy

Another highlight was the announcement of support from Ofgem, BEIS and UKRI as Icebreaker One’s Open Energy service enters pilot stage to prepare for public launch:

“UKRI, BEIS and Ofgem are supportive of energy data sharing solutions and we will work with industry over the coming months to ensure that these solutions can operate within the energy market.”

Ofgem, BEIS and UKRI statement

Read the full statement here.

Mission Innovation launches Joint Roadmap of Global Innovation Priorities

We celebrate the launch of the Mission Innovation Green Powered Future Mission’s Joint Roadmap of Global Innovation Priorities which took place at COP26. Mission Innovation is a global initiative convening international governments, public authorities, corporates, investors and academia to form new public-private innovation alliances – Missions – that catalyse clean energy solutions for all. The Green Powered Future Mission will demonstrate by 2030 that power systems in all geographies and climates can effectively integrate up to 100% variable renewable energy (VRE) in their generation mix while maintaining a cost-efficient, secure, and resilient system. The UK’s Department for Business, Energy & Industrial Strategy (BEIS) and Icebreaker One are leading a core pillar of the global Green Powered Future Mission which is ‘Data and Digitalisation for System Integration’: how to accelerate the digitalisation of energy systems through development of interoperable data exchange and effective system integration to unlock the full value of VRE.

The Joint Roadmap of Global Innovation Priorities has been developed by Mission members to achieve the goal. It has identified 17 Research & Innovation (R&I) themes and the top 100 innovation priorities in order that will guide investment and upcoming activity across 2022-2024, as projects are launched to demonstrate a range of innovative solutions that enable up to 100% integration to VRE.

For more information about the Green Powered Future Mission please read our summary here.

Icebreaker One founder helps launch automotive initiative aligned with IB1 principles

IB1 Founder Gavin Starks joined the World Business Council for Sustainable Development (WBCSD) to launch a partnership with the Catena-X Automotive Network, representing 62 automotive industry members as well as the Rocky Mountain Institute, to develop a shared approach to measuring and exchanging Scope 3 carbon emissions information in automotive supply chains.

You can watch the archive of our presentation and read more about this ground-breaking new partnership here.

Icebreaker One’s Green Zone event plays to a packed house

Our COP26 event ‘How can we decarbonise our built environment? Lessons from experiments around the world’ was a huge success. We enjoyed a lively debate with our global panel sharing their lessons from the frontline of decarbonisation innovation, and the role of net zero data in achieving it.

See the archive of our session here.

Icebreaker One wins OpenUK’s Sustainability award

Finally, it was wonderful to be announced as OpenUK’s Sustainability winner in the OpenUK Awards, Second Edition 2021, that recognise UK Leadership in Open Technology.

COP26 has been a fantastic event and we look forward to more openness, collaboration and innovation to come on the back of these important talks.

Figure 1 The SERI Shared Data Infrastructure, where API stands for the “application programming interface”, FAPI stands for the “Financial grade API”, and OAPI is  the “Open API”.

The SERI shared data governance framework is a Shared Data Infrastructure (SDI), built on Open Banking and Open Energy foundations and many open data sharing standards (e.g. preemptive licenses). The key components of the SERI SDI are Data Authorisation Service, Membership/customer relation management (CRM), Metadata Harvester and Database, and Datasets Search Engine. Data and data service providers are brought to the SERI SDI through membership agreements. Data providers publish their data descriptions and register their licensing options per type of use through preemptive licensing or open data licensing for data users to access at different levels. Data remains in data providers’ databases under their management, performing data cleansing, verification, updates and correction locally.  Data flows from member data providers to member data service providers through Application Programming Interfaces (APIs), where shared data flows through a secured financial grade API (FAPI), designed for industries (e.g. financial industry)  that require higher API security; open data flows through a public/open API (OAPI) that may incur security issues at circumstances. Data users can search data from the Datasets Search Engine and access them directly from data providers or data service providers by complying to their respective licensing requirements. Figure 1 illustrates the SERI SDI ecosystem and how data flows within the system. 

Within this infrastructure, collaboration with a wide range of stakeholders makes data discovery, aggregation, management, and sharing through federalised data services much easier and more efficient. Data governance within the infrastructure ensures a secure platform for many current Closed Data to be shared in confidence through preemptive licenses. This can potentially unlock a whole range of new data (e.g. financial, business and environmental data, especially mitigation data for climate change) for businesses to innovate and potentially incentivise net-zero behaviours.

The Phase 1 SERI SDI is currently conceptual, at its embryo development stage and needs well defined use cases to demonstrate its value and how it works. The SERI team has developed a Climate-Ready Building Passport (C-RBP) concept as a service from the framework, associated with an industrial verified insurance market use case from a broker’s perspective. This use case demonstrates what commercial values the framework can create and how it assists the insurance industry incentives net-zero behaviours. In this use case, a broker was helping an asset manager to insure their complex assets (with many old and not retrofitted). Although they received a list of data from the asset manager, there would still be a number of extra data needed due to various reasons such as missing data, errors, data not usable etc. They have to shop around for data to fill the gaps from various third party data providers in order to be in a good position to negotiate the best insurance outcome for their customers. Data is fragmented, scattered and hard to find, and data related to sustainability in general is not identifiable or available. It is very challenging to find all the data the broker needs. A new service is needed to resolve this problem.

Figure 2 SERI Shared Data Infrastructure – A Broker’s view from the Climate-Ready Building Passport Data Service (Where API stands for the “application programming interface”, FAPI stands for the “Financial grade API”, and OAPI is  the “Open API”).

Figure 2 maps the major components of the SERI SDI for the use case and demonstrates how the broker can access different types of data (either Open or Shared) through the C-RBP service. Through the service, the broker can easily discover various building information and building risk data (inc. both resilience and mitigation risks, either open or shared) from the C-RBP search engine on the framework from his computer. Once data is identified, the system will show him his eligibility to access and how to access the data, through open or preemptive licenses. Potentially he may only need to go through one of the data service providers of the framework to access all required data. He no longer has to ask around for data and go through many bilateral contracts/agreements. The datasets from C-RBP are all digital and machine readable, and are produced under structured data standards, making it easy to use and convert. This saves time, effort and money, and enables new datasets (e.g. operational data, emission data) to be discovered to give the broker insights to innovate.

Call for Support

We are currently seeking more input from stakeholders in the insurance value chain to develop the C-RBP and the SERI SDI further. If your work is in a related field and you’d like to be involved in this initiative we would love to hear from you, please get in touch by emailing us at seri@ib1.org.

Photo credit: Image by Pete Linforth from Pixabay

However, an even bigger challenge is to tackle the total GHG emissions used to produce a built asset, known as embodied (or capital) carbon. As urban growth continues and new buildings are erected, the contribution of embodied carbon is projected to double by 2050, making it urgent to address mitigation strategies in the design phase.

While some types of building passport exist, a climate-ready building passport could provide the means to capture and share data on a building’s life cycle (design, build, operation) and provide owners with a pathway to meet GHG reduction goals.

Various disparate tools exist that serve specific needs, but there is a wide gap between current data availability, its formats, discoverability and useability and a fully functioning, transparent, interoperable and scalable system that could capture the diverse requirements of potential users. In other words, there are many barriers that prevent stakeholders accessing the data they need that could help to reduce the GHG emissions of a building.  

The creation of a digital “building passport” could enable a variety of stakeholders to discover and share appropriate data in a secure environment, underpinned by robust standards for data sharing, allowing for real-time reporting to enhance risk analysis that would in turn incentivise climate-ready behaviours and allow for the development of innovative insurance products. There is an urgent need to collaboratively develop the shared data infrastructure where multiple use cases for digital building passports can help incentivise net-zero behaviours.

Icebreaker One is actively looking for feedback on the idea of climate-ready building passports. We’re currently consulting with industry, and building Advisory Groups to meet this Spring. The Advisory Groups will explore the idea and provide a forum for discussion to ensure this product meets user needs.

To share feedback or express your interest in joining the Advisory Groups, send us an email on seri@ib1.org

What is a building passport?

A building passport is a tool to capture appropriate data in a digital format that could be useful to building owners, occupiers and those that have responsibility for monitoring and reporting on a building’s performance. The idea of a building passport is not new. Indeed, the European Union through the European Commission’s Directorate-General for Energy is providing technical support to investigate the feasibility of introducing optional building renovation passports (BRP) in the EU. Following Article 19a of the Energy Performance of Buildings Directive (EPBD), the relevance, feasibility and potential impact of BRPs was studied and the results showed that there is low awareness of the benefits of energy renovation and insufficient knowledge of what measures to implement and in which order.

Existing building passports are able to store historical information about the design, construction and fitting out of a structure that could be made available on demand to restricted users, such as the fire services. The desire for safer built environments has been the impetus for the creation of organisations like Building Passport. For example, in the light of the Grenfell Tower tragedy and subsequent Inquiry and Phase 1 report, a vital use case for building passports is making floor plans and information that could exacerbate fire risk instantly available to rescue services. 

A climate-ready building passport could go further than providing specific information to rescue services. To enable the widest possible adoption, the concept needs to be enabled by a standards-based approach to data sharing. The Standard for Environment, Risk and Insurance (SERI) is looking to develop open standards to enable insurers to access shared environmental, financial and risk data across organisations and silos. Capturing additional environmental data will provide incentives that could support more meaningful actions to reduce GHG emissions and so underpin net-zero goals.

There are several other uses of the climate-ready building passport that could provide credible reasons for all stakeholders to collectively agree on a shared data infrastructure to support more comprehensive access to information about a building, in a secure environment with the appropriate governance structure in place. For example, the rich data captured in Building Information Modelling (BIM) does not get shared as exposure input data used in risk assessments or the catastrophe modelling process used in insurance pricing. Data standards could assist asset owners where there is no normalised process for capturing and reporting climate-related disclosures, which will soon become mandatory.

How would the data be used?

Creating a digital building passport would open up a wealth of opportunities, but it does pose an expanding hierarchy of questions depending on the user. To narrow the scope, key questions need to be answered from each stakeholder:

– What are you trying to do?
– What data are you using to do it?
– What data do you need?
– What data elements are missing?
– What data formats are missing?
– What data do you not have access to?
– Would a digital passport be the right tool to capture open / shared data?

For SERI, our goal is to encourage the development of innovative insurance products that incentivise carbon net-zero behaviours. Insurers use a wide range of data inputs to assist in pricing decisions and risk management. This data is captured from individual buildings and residential properties, through to massive schedules of information from corporate buyers (such as hotel or fast food chains). None of this data is currently structured to be captured and shared easily.

While third-party catastrophe model vendors are beginning to make their proprietary standards open, and open exposure data standards exist through the work of platforms like Oasis Loss Modelling Framework, the data that is captured is limited. Data on age, construction, number of stories together with primary modifiers like occupancy and location are supplemented by secondary modifiers such as construction quality and cladding. This data is mostly captured in spreadsheets, CSV formats or worse in PDF files. The industry is looking at new tools that could capture additional data elements leveraging more scalable software solutions such as JSON. This allows for a more powerful ability to capture hierarchical and relational data. For example, for buildings this could include:

–> Physical characteristics including its structure, orientation, materials, locations, neighbourhood
–> Use and building performance characteristics including occupancy, services & utilities, critical dependencies
–> Legal and financial characteristics – owners, portfolio relationships, leases

How to get involved!

We believe that there is an opportunity to leverage the work that was originally achieved for Open Banking, and now being used for Open Energy and help crystalise a “Shared Data Infrastructure” that could provide utility for many downstream activities.

Icebreaker One is looking for representatives from diverse organisations that are involved either in the supply or use of data to assist in developing a use case for creating a shared data infrastructure that is aligned with the goals of SERI.

We’re currently building Advisory Groups that will meet over the next few months to do this. Being part of an Advisory Group means meeting occasionally with other sector leaders, and providing insight and feedback on what Climate-Ready Building Passports could be most valuable.

To share feedback or express your interest in joining the Advisory Groups, fill out this short form. Alternatively, write to seri@ib1.org.

Meanwhile, join Icebreaker One here and help us deliver a net-zero future!

Photo credit: City of London Skyline by Trine Syvertsen CC by 2.0

A.     Introduction – Icebreaker One

Icebreaker One (IB1) is a global non-profit dedicated to making data-at-scale work harder to deliver innovative financing for a carbon-zero future. It is focussed on creating frameworks and open standards for robust and secure data sharing across environmental & financial data; understanding the use-cases, business models, policies, processes, principles and practice that will unlock value at scale; developing & sharing expertise to provide knowledge and insight that will enable climate-specific interventions across the financial ecosystem.

We’re working to help everyone understand how to instrument change: where there is scope for material, transformational, rapid change—and how to implement it—that will help us all address the greatest challenges of our time. In 2020 we will be designing and testing climate-ready financial products and helping take them to market with our Members. We are connecting policy, strategy, risk management and investment to real-world data to:

·       Enable climate-ready financial instruments

·       Enable climate-aware risk management

·       Enable climate-credible deployment of robust, long-term solutions

B.     Overall

We want to ensure that we produce a forward-looking strategy that takes into account public opinion and delivers real change. These questions will help to inform future work that the government will take in this space. They will provide evidence for the government to target areas for intervention in future policy.

Please find a diagram below of the NDS pillars, missions and opportunities for reference.

Q1. To what extent do you agree with the following statement: Taken as a whole, the missions and pillars of the National Data Strategy focus on the right priorities. Please explain your answer here, including any areas you think the government should explore in further depth.

IB1 Response:  Icebreaker One is somewhat in agreement that the missions and pillars of the National Data Strategy focus on the right priorities. Below are the areas which we think the government should explore in further depth:

1. Environment – Given the UK government’s stated commitment to tackling climate change, and in light of HM Treasury’s announcement, on 9th November 2020, of the intention to make position the UK at the forefront of green finance, and to mandate disclosures in line with the Taskforce on Climate-Related Financial Disclosures (TCFD) recommendations across the economy, we believe that there is a strong case for Environment and the Transition to a Net-Zero Economy to be added as an Opportunity for the NDS to address. 

1. Distributed data strategy – consistent, cost-effective mechanisms for sharing and accessing data are required, as a core component of any national data strategy. We therefore recommend that “Adoption of a consistent national distributed data strategy’ be added to the Missions of the NDS. This should encompass an agreed common approach to sharing data, whether business-to-business (B2B) or business-to-consumer (B2C).  Furthermore, we believe that Open Banking and the Open Banking Implementation Entity (OBIE) model and infrastructure provide a template and springboard for developing cross-sector national data infrastructure. 

Q2. We are interested in examples of how data was or should have been used to deliver public benefits during the coronavirus (COVID-19) pandemic, beyond its use directly in health and social care. Please give any examples that you can, including what, if anything, central government could do to build or develop them further.

For question two, we are only looking for examples outside health and social care data. Health and social care data will be covered in the upcoming Data Strategy for Health and Social Care.

IB1 Response:  Open Banking provides valuable examples that demonstrate how an effective data sharing ecosystem can respond to rapid market changes. The Fintech developer community – is characterised by agile working practices that continually test and learn as they meet customer needs. During the Covid-19 pandemic, this particular ecosystem proved to be highly collaborative and quickly developed a new tool to support self-employed people claiming financial relief from the government using transactional data to provide evidence of past earnings.

Good examples can be found through the Open Banking #powerofthenetwork page (https://www.openbanking.org.uk/insights/power-of-the-network/ ), as well as the clear pivot demonstrated by several of the participants in the Nesta Open Up 2020 Challenge: Explore the Apps — Open Up 2020 (https://openup2020.org/explore-the-open-banking-apps ) which helped consumers to build financial resilience, plan for the future, address problem debt, improve their credit score or access short term credit at fair rates. 

The key learning from this is that building new well functioning ecosystems that can respond to market needs quickly can provide very significant benefits, and generally respond much faster than incumbents. This, therefore, must be supported by forward-looking regulation and government policy decisions. 

Q3. If applicable, please provide any comments about the potential impact of the proposals outlined in this consultation may have on individuals with a protected characteristic under the Equality Act 2010?

IB1 Response: There is a need to ensure that individuals with a protected characteristic under the Equality Act 2010 – but also including vulnerable consumers – are effectively protected, with consideration of aspects such as data ethics and unintended consequences from algorithms etc. The NDS creates an opportunity to enhance consumer protections across the board, and to close regulatory gaps associated with data and its applications. 

The Open Banking Implementation Entity has taken a lead by including Customer Experience Guidelines, that includes a section on vulnerable customers (Customer Experience Principles | Open Banking Documentation – https://standards.openbanking.org.uk/customer-experience-guidelines/introduction/design-and-experience-principles/latest/ ) as well as Operational Guidelines for Third Party Providers which address data governance and ethics (Data Ethics – General | Open Banking Documentation – https://standards.openbanking.org.uk/tpp-operational-guidelines/data-ethics-gdpr/latest/ ) These are areas that should be consistently applied and included within the scope of cross-sector guidance through BEIS Smart Data Initiatives.

Q4. We welcome any comments about the potential impact of the proposals outlined in this consultation on the UK across all areas, and any steps the government should take to ensure that they take account of regional inequalities and support the whole of the UK?

IB1 Response: 

Government should encourage investment in data innovation and better data usage outside of London and the South-East, and should also build on existing opportunities and initiatives (for example, existing fintechs clusters in Manchester, Edinburgh etc.). This can be done through incentivisation towards investment in and development of data-driven businesses in the regions, and creation of regional clusters of data innovation. 

There is also a need to look more holistically at the skills base required to support a more data-driven economy, particularly and more immediately with respect to Covid-19 economic recovery planning. Government should incentivise higher education institutions such as universities and colleges to create more academic courses around areas of technology and data innovation, including but not limited to data engineering, data standards, and artificial intelligence and machine learning techniques (AI / ML). Firms should also be incentivised to offer traineeships and apprenticeships in these areas, enabling the UK to grow these skills domestically. There is a need to focus on the wider skill sets required to support a thriving data-driven industry base – going beyond technology, to encompass the soft skills and creativity aspects required to drive innovation.   

Initiatives such as the Global Open Finance Centre of Excellence (GOFCoE – https://ddi.ac.uk/case-studies/gofcoe/ ) provide a template and model for a holistic approach to skills and knowledge development and sharing, combining academic rigour and support with practical training and infrastructure in conjunction with industry, supported by government leaning in. We strongly encourage leverage of these models and replication in other regional contexts. 

C.     Mission one: Unlocking the value of data across the economy

Data is an incredibly valuable resource for businesses and other organisations, helping them to deliver better services and operations for their users and beneficiaries. However, there is increasing evidence to suggest that the full value of data is not being realised because vital information is not getting to where it needs to be.

Our first mission is to create an environment where data is appropriately usable, accessible and available across the economy – fuelling growth in organisations large and small. We will create a clearer policy framework to identify where greater data access and availability across and with the economy can and should support growth and innovation, in what form, and what government’s role should be, in the UK and globally.Data availability: For data to have the most effective impact, it needs to be appropriately accessible, mobile and re-usable. That means encouraging better coordination, access to and sharing of data of appropriate quality between organisations in the public sector, private sector and third sector, and ensuring appropriate protections for the flow of data internationally.

Q5. Which sectors have the most to gain from better data availability? Please select all relevant options listed below, which are drawn from the Standardised Industry Classification (SIC) codes.

·       Accommodation and Food Service Activities

·       Administrative and Support Service Activities

·       Agriculture, Forestry and Fishing

·       Arts, Entertainment and Recreation

·       Central/Local Government inc. Defence

·       Charity or Non Profit

·       Construction

·       Education

·       Electricity, Gas, Steam and Air Conditioning Supply

·       Financial and Insurance Activities

·       Human Health and Social Work Activities

·       Information and Communication

·       Manufacturing

·       Mining and Quarrying

·       Transportation and Storage

·       Water Supply; Sewerage, Waste Management and Remediation Activities

·       Wholesale and Retail Trade; Repair Of Motor Vehicles and Motorcycles

·       Professional, Scientific and Technical Activities

·       Real Estate Activities

·       Other

IB1 Response: In the context of Icebreaker One’s work in developing the shared data infrastructure required to drive a transition towards green finance and a green economy, we identify the following sectors which we believe stand to gain significantly from better data availability – nevertheless acknowledging that other sectors may also benefit to an equally significant extent when viewed through this or other lenses. There are many opportunities that can be leveraged from better data availability in these sectors, and we have specifically highlighted those that arise in relation to climate change, understanding and management of climate-related risks, and the transition to a net-zero economy:

• Agriculture, Forestry and Fishing
  • Data availability can support better understanding of the impacts of climate change at present and allow for better projection into the future. 
  • Can also allow more granular assessment of the impacts of policy changes and new technologies on the sector. 
• Construction
  • Better data, particularly through enhanced use of sensors and other capabilities, can enable creation of feedback-driven systems and buildings. 
• Electricity, Gas, Steam and Air Conditioning Supply
  • Icebreaker One is currently working on Open Energy – a project to introduce shared data infrastructure, in the style of Open Banking, to the energy sector. This will enable better understanding of energy sources and consumption across the sector and enable development of new and innovative applications. See https://energydata.org.uk for an overview of the Open Energy initiative and its benefits in opening up access to energy data. 
• Financial and Insurance Activities
  • Data availability is absolutely vital in order to assess the impact of climate change on firms, their activities and their asset and share prices, as well as in determining the climate-related risk associated with firms, which ultimately impacts factors such as creditworthiness and the cost and availability of capital finance and debt. 
  • Data from all sectors is required in order for firms to develop better models of climate-related risk and understand its future impacts on the financial system and economies.
  • Data inputs from all sectors are required in order for firms to assess their own climate-related risk in line with TCFD and other recommendations – and soon-to-be regulatory requirements. 
• Transportation and Storage
  • Better data can help develop an understanding of the costs and impacts of transitioning to hydrogen and electric-powered vehicles. 
• Water Supply
  • Data will help build a better understanding of water availability and quality. 

Q6. What role do you think central government should have in enabling better availability of data across the wider economy?

IB1 Response: Central government has a number of tools at its disposal to facilitate cross sectoral data sharing and sensible re-use of public sector data, be that via the creation of bodies to act as intermediaries in data sharing and assess requests for data access, or via the introduction of legislation which builds trust in the private sector for the sharing of industry or business data to reach common goals or for the greater good. It is key that the government uses these tools to ensure that data is shared appropriately and that interests in the data (whether that is personal data rights or ownership of intellectual property rights) are protected so that both individuals and businesses are incentivised to share quality data. With Brexit in mind, it is also key to ensure that the UK retains access to European data sources and the common EU data space so that the UK does not fall behind.

We highlight the following as specific recommended actions that could be taken by central government in promoting and enabling better availability of data across the wider economy:

• Creation of appropriate and well-funded central and sector-specific regulation, with clear oversight and supervision through leveraging existing regulatory bodies, or via the establishment of new regulatory bodies where appropriate. 
  • For example, cross-sector issues such as consent, digital identity and authentication, liability and redress etc should be looked after by a central regulatory body (either the CDEI or a new entity), whilst Ofgem, Ofcom, FCA etc. regulate for their specific sectors, managing regulatory authorisations and undertaking supervisory and enforcement activities.  

• Creation of a dedicated data standards and implementation body – building on the OBIE model – that has the ability to develop both cross-sector standards (e.g. for consent) and sector-specific standards (e.g. for sharing of transportation data, or agricultural data).

• Adoption of a distributed data strategy with appropriate governance, again building on the Open banking / OBIE model (which Icebreaker One is leveraging in developing the Open Energy initiative). 

• Ensuring that these regulatory, standards and governance bodies are adequately funded to drive successful outcomes, and have the necessary legislative mandate to operate effectively.
  • At present, the ICO appears to be under-resourced and under-funded when one considers the pace of change and rapid move towards a more data-driven economy. Strong regulatory strategy and oversight is required, with appropriate levels of supervision and powers of enforcement. In this context, we see the Financial Conduct Authority (FCA) as representing a more appropriate example for such an agency to be modelled upon.

Q6a. How should this role vary across sectors and applications?

IB1 Response: Government should take a more interventionist role in sectors where there is a key public interest. For example, where there is a key public benefit,  such as reaching the 2050 Net Zero target, Government may need to take more action in order to facilitate private sector data sharing or to make relevant public sector data available for re-use in order to reach the target (either by increasing requirements to share relevant data or to facilitate access requests). There are also some sectors in which data use and access should be more highly regulated, for example, where sensitive health data is involved.

Data foundations: The true value of data can only be fully realised when it is fit for purpose, recorded in standardised formats on modern, future-proof systems and held in a condition that means it is findable, accessible, interoperable and reusable. By improving the quality of the data we are using, we can use it more effectively, and drive better insights and outcomes from its use.

Q7. To what extent do you agree with the following statement: The government has a role in supporting data foundations in the wider economy. Please explain your answer. If applicable, please indicate what you think the government’s enhanced role should be.

IB1 Response: We strongly agree with this statement. 

We are also strongly in agreement with the NDS’ assertion that “The true value of data can only be fully realised when it is fit for purpose, recorded in standardised formats on modern, future-proof systems and held in a condition that means it is findable, accessible, interoperable and reusable. By improving the quality of the data we are using, we can use it more effectively, and drive better insights and outcomes from its use.” In this context, the UK Government clearly has a role to play in supporting data foundations in the wider economy, through supporting and promoting:

• Development and adoption of data standards, preferably through existing standards-setting bodies, but where these do not exist, through incentivisation and support for creation of standards-setting bodies. 

• Digitisation of data – storage of data in (preferably digital-native) formats that are both machine and human-readable, searchable, retrievable and electronically accessible.

• Shared data infrastructure – enabling data to be held and updated at source, but shared on an open and accessible basis, rather than creating centralised, privately or publicly held databases. In this context we are great supporters, again, of Open Banking and the OBIE as a model. 

• Trust – trust is at the core of a successful national data strategy and in building out the data-driven digital economy of the future. Government and regulatory oversight with clear objectives is required in order to support this trust. We have closely followed the work undertaken by the Smart Data Working Group (SDWG) around areas such as consent, liability, authentication and participant authorisation, which, taken together, are at the heart of creating trust in a data economy. We are strongly supportive of the SDWG’s ongoing work in this area.

Q8. What could central government do beyond existing schemes to tackle the particular barriers that small and medium-sized enterprises (SMEs) face in using data effectively?

IB1 Response: We would advocate for greater consistency of standards across sectors, so that SMEs are consistently using a familiar approach when dealing with and accessing service providers, be they banks, HMRC, energy providers or other entities. In this respect, we adopt a broad definition of the term “standards”, considering not only data specifications but also guidance around customer experience (with the SMEs being, in this context, the “customers”) and access to portals and infrastructure, which should be designed for familiarity and consistency across sectors. There is also a need to examine the shared services and infrastructure that underpin cross-sectoral and cross-functional multi-entity data access; for example, single sign-on mechanisms, and digital identities and identity management for SMEs, across platforms and sectors. 

In terms of the benefits to SMEs that can accrue from adoption of a shared data infrastructure, based on Open Banking principles, we are also heartened by Andy Haldane’s speech on 18th November (https://www.bankofengland.co.uk/-/media/boe/files/speech/2020/seizing-the-opportunities-from-digital-finance-speech-by-andy-haldane.pdf?la=en&hash=508F4972D17DE5A6DE3E0A1439A284BE904AC1C5). In this speech, the Bank of England’s Chief Economist stated that “Breaking down those well-entrenched barriers calls for a new infrastructure, one which expands the scale and scope of Open Banking – an Open Data platform for SMEs. The Bank set out some ideas on the design of such an open platform for SMEs earlier this year. This would provide a standardised means of permissioned sharing of data about businesses. In addition to data held by banks, this could include data from insurance and utilities companies, credit rating and social media data companies, and Government sources such as the Passport Office, DVLA, HMRC and Companies House.

The platform would run as a decentralised network of data providers using a standardised set of APIs. There would be no central data repository, physical credit file or central infrastructure. Instead, like the internet, the platform would be built around standard protocols that would enable interoperability between decentralised data providers and data users, with businesses having control of this process.At a practical level this would mean an SME could, at the touch of a button, permission an API call to a handful of data providers to instantly share specified data fields with a third-party, such as a lender. The data transfer would be close to real time and encrypted end-to-end. This would greatly expand the dataset, and shorten the application process, for SME loans.”

The Smart Data Review in 2019 consulted on ways to make evolving schemes more coordinated across banking, finance, telecoms and energy. The focus of Smart Data is citizens asking their providers to share information about them with third parties.

Q9. Beyond existing Smart Data plans, what, if any, further work do you think should be done to ensure that consumers’ data is put to work for them?

IB1 Response: Icebreaker One believes that there is significant scope for putting consumers’ data to work for their benefit. Consumer data can be used to gain a better understanding of, and to develop plans for addressing, a number of major societal challenges such as financial exclusion, digital exclusion, fuel poverty and others. We would advocate for the incentivisation of innovation in these areas through such measures as creation of funded (e.g. via UKRI) challenges and competitions, better R&D tax breaks for initiatives aimed at addressing such issues, and encouraging co-operation and partnerships between industry and charity sectors. At the same time, we would also advocate for greater transparency for consumers as to how their data is being used.

D.    Mission two: Maintaining a pro-growth and trusted data regime

Building on our status as a world leader in technological innovation and our robust data protection standards, we will maintain a data regime that supports the future objectives of the UK outside of the EU and promotes growth and innovation while maintaining public trust. This regime will not be overly burdensome for the average company, nor will it be unnecessarily complex or vague; it will help innovators and entrepreneurs use data legitimately to build and expand their businesses, without undue regulatory uncertainty or risk at both the domestic and international levels.

To encourage the widespread uptake of digital technologies, we will also work with regulators to provide advice and support to small- and medium-sized businesses to help them expand online, and develop sector specific guidance and co-regulatory tools to accelerate digitisation across the UK economy.

Q10. How can the UK’s data protection framework remain fit for purpose in an increasingly digital and data driven age?

IB1 Response: Problems that are shared across jurisdictions, such as Covid-19, require sharing and pooling of data resources across jurisdictions in order to identify common solutions. We agree that, in light of Brexit, the UK must seek to maintain access and interoperability with other data sharing regimes globally, particularly in light of the various data localisation rules that are emerging around the world. 

With respect to personal data, the UK will need to keep on top of developments in new uses for personal information as well as new tools and technologies used to process it in order to ensure that individuals remain protected and are provided with a degree of control and incentivisation to share their data. We would encourage and support the push at governmental level toward the regulation of non-personal data sharing, such that businesses may feel more comfortable sharing data which they had previously treated as confidential and proprietary for other uses, including both commercial and altruistic purposes. Only by doing this can we ensure that the UK market benefits from access to large datasets of a good quality to enable growth in the UK economy and to stay aligned with our peers on the global stage.

Through Icebreaker One’s sister organisation, Dgen, we authored two reports on Consent and Liability. Our core recommendation is that the government should develop additional consumer protections and enhanced rights for consumers through a Smart Data Right and a Smart Data Consumer Agreement. This will be essential in ensuring regulatory consistency for consent and liability, and their management, in smart data initiatives across sectors. The link to these reports is here: https://www.gov.uk/government/publications/smart-data-research-on-consent-liability-and-authentication

In section 7.1.2 we lay out the functions of the Centre for Data Ethics and Innovation (CDEI), set up in 2018 to advise the Government on the use of data-driven technologies and AI.

Q11. To what extent do you agree with the functions set out for the Centre for Data Ethics and Innovation (CDEI) – AI monitoring, partnership working and piloting and testing potential interventions in the tech landscape? Please explain your answer.

IB1 Response: Icebreaker One strongly agrees with the functions set out for the Centre for Data Ethics and Innovation (CDEI), including AI monitoring, partnership working and piloting and testing potential interventions in the tech landscape. We are strong advocates for the adoption of  data ethics principles on a more widespread basis, particularly with respect to the emerging and more widespread use of AI / ML techniques in combination with the opportunities afforded by Big Data. We would strongly recommend development and adoption of a set of UK AI Ethics guidelines, along the lines of the EU AI Ethics Guidelines ( https://ec.europa.eu/digital-single-market/en/news/ethics-guidelines-trustworthy-ai ). 

Specific areas for consideration with respect to an AI Ethics framework include, for a given proposed application of AI: what are the benefits of the application? What are the potential risks and detriments? How does it work – can it be explained? Is its application and implementation just and fair, and how are disputes handled? 

We are also supportive of the ODI’s proposal (http://theodi.org/wp-content/uploads/2020/11/Getting-data-rightperspectives-on-the-UK-National-Data-Strategy-2020.pdf)  to develop a professional framework for data scientists, with shared codes of practice and accreditation, as this will go some way as well to embedding ethical principles at the core of data science as an emergent field.

Q11a. How would a change to statutory status support the CDEI to deliver its remit?

IB1 Response: We believe that a change to the CDEI’s statutory status – for example, by giving it the status of a regulator with the ability to supervise and enforce regulations implemented with respect to data ethics – would be a welcome indication of the UK Government’s commitment to the development of an ethical base on which to build its foundations for a national data strategy. We would strongly advocate for the creation of a regulatory framework aimed at ethical governance of data and the firms that process them. This should, for example, encompass responsibilities on boards and directors to ensure that businesses are operating ethically. Additionally, if there is a role to be played by the CDEI in providing oversight of such firms, to hold them to account and to have enforcement capabilities, then it ought to have some registration requirements for organisations that are processing data, in order to ensure that they are not acting unethically, either consciously or unconsciously. 

It has been noted from work in Open Banking that unconscious bias can be introduced through algorithms that have not been fully tested. Testing for and elimination of such bias should be a prerequisite before market launch, particularly where financial or other sensitive data is being used. For example, sandbox testing of algorithms using sensitive data or having applications that might have outcomes affecting the rights of individuals (such as facial recognition algorithms) should be mandatory prior to the live usage of these algorithms, and standard facilities for such testing be made available to the development community, which does not currently have easy access to such facilities. This is particularly true of smaller developers operating within very tight budget constraints. This could be provided through organisations such as the Global Open Finance Centre of Excellence (GOFCoE) or similar establishments. 

E.     Mission three: Transforming government’s use of data to drive efficiency and improve public services

There is massive untapped potential in the way the government uses data. We will implement major and radical changes in the way that the government uses data to drive innovation and productivity across the UK. In doing so, we will improve the delivery of public services, as well as our ability to measure the impact of policies and programmes, and to ensure resources are used effectively.

To succeed, we need a whole-government approach led by a Government Chief Data Officer from the centre in strong partnership with organisations. We need to transform the way data is collected, managed, used and shared across government, including with the wider public sector, and create joined-up and interoperable data infrastructure. We need the right skills and leadership to understand and unlock the potential of data – and we need to do so in a way that both incentivises organisations to do the right thing, as well as build in the right controls to drive standardisation, consistency and appropriate data use.

The government is going to set an ambitious package of work in this space and wants to understand where we can have the biggest impact.

Q12. We have identified five broad areas of work as part of our mission for enabling better use of data across government:

·       Quality, availability and access

·       Standards and assurance

·       Capability, leadership and culture

·       Accountability and productivity

·       Ethics and public trust

We want to hear your views on any actions you think will have the biggest impact for transforming government’s use of data.

IB1 Response: We are supportive of the Government’s plans to take a whole-government approach to improving the use of data for innovation, service delivery and decision-making. In developing a data infrastructure that is fit for purpose for Government’s needs, it is essential that the process is led by real-life use cases, in order to avoid the pitfalls of developing infrastructure for theoretical use cases that do not reflect real-life usage of data. We would therefore recommend that the Government undertake a comprehensive analysis of its needs and identify the core use cases that apply, prior to embarking on the design and development of such data infrastructure. This is essential in order to ensure that the data sharing solution both meets the requirements of the users, but also is designed in a way that allows easy use of the data regardless of the technical capability of the user. 

We strongly recommend a trust framework, enabling participant management and data access control, as the basis for an effective data sharing solution. It is essential to enable users to find and access the data they require, and to enable a service layer to develop within this trusted environment. The core components for this are:

• Knowledge Graph – This allows users to search for datasets according to parameters that they set. It works by crawling metadata and understands the meaning and relationships between data sets, so that users can understand the full spectrum of information available to them.
• Decentralised architecture – The architecture should have only the minimum required centralised components, removing a single point of failure and allowing rapid and low-cost system evolution. This approach has the major benefit that the data is maintained only by the relevant departmental holder, so requires no additional curation and is always up to date.
• Directory – This is the critical enabler for the decentralised architecture as it provides a secure, trusted environment with strong governance. It enables data providers to verify the identity of the party requesting the data, ensuring that access control for authorised users can be effectively managed. It is used to signpost the API endpoints for data, and enables granular control over the specific data that is being accessed. 
• Standards – Once adopted a standardised approach reduces the effort, time and cost of integration. A metadata standard enables better data search and discovery used in a Knowledge Graph approach. 

We believe that adopting this approach will ensure security, access control, scalability, flexibility to meet government needs as they develop.  

We would also advocate for the creation of a separate vehicle that can sit between data regulators and industry, with a focus on unlocking leadership, capability and a culture of responsible and innovative data usage whilst also facilitating an effective feedback loop between regulators and industry, given the emergent nature of much innovation in this space.

Q13. The Data Standards Authority is working with a range of public sector and external organisations to create a pipeline of data standards and standard practices that should be adopted. We welcome your views on standards that should be prioritised, building on the standards which have already been recommended.

IB1 Response: We believe that the development of Open Standards is of paramount importance and represents the foundation of data infrastructure in the UK. Icebreaker One’s founders were also involved in developing the Open Banking Standard, and the organisation is now building an Open Energy Standard based on the same principles. 

Such development must be done collaboratively, with broad stakeholder engagement. They must encompass, at a minimum and based on user needs, frameworks for licensing, operations, policy and technology.

F.     Mission four: Ensuring the security and resilience of the infrastructure on which data relies

In the UK, the government already imposes safeguards and enforcement regimes to ensure that our data is handled responsibly. But we will also take a greater responsibility for ensuring that data is sufficiently protected when in transit, or when stored in external data centres.

The government will determine the scale and nature of risks and the appropriate response, accounting for emerging trends in the market landscape. We will also determine whether current arrangements for managing data security risks are sufficient to protect the UK from threats that counter our missions for data to be a force for good. And we will consider the sustainability of data use, exploring inefficiencies in stored and processed data, and other carbon-inefficient processes.

The infrastructure on which data relies is the virtual or physical data infrastructure, systems and services that store, process and transfer data . This includes data centres (that provide the physical space to store data), peering and transit infrastructure (that enable the exchange of data), and cloud computing that provides virtualised computing resources (for example servers, software, databases, data analytics) that are accessed remotely.

Q14. What responsibilities and requirements should be placed on virtual or physical data infrastructure service providers to provide data security, continuity and resilience of service supply?

IB1 Response: No response.

Q14a. How do clients assess the robustness of security protocols when choosing data infrastructure services? How do they ensure that providers are keeping up with those protocols during their contract?

IB1 Response: No response.

Q15. Demand for external data storage and processing services is growing. In order to maintain high standards of security and resilience for the infrastructure on which data use relies, what should be the respective roles of government, data service providers, their supply chain and their clients?

IB1 Response: No response.

Q16. What are the most important risk factors in managing the security and resilience of the infrastructure on which data use relies? For example, the physical security of sites, the geographic location where data is stored, the diversity and actors in the market and supply chains, or other factors.

IB1 Response: No response.

Q17. Do you agree that the government should play a greater role in ensuring that data does not negatively contribute to carbon usage? Please explain your answer. If applicable, please indicate how the government can effectively ensure that data does not negatively contribute to carbon usage.

IB1 Response: The Government should make all endeavours to ensure that new data infrastructure and standards around data storage and use are designed with the Net-Zero Target in mind, and, where possible, encourage and motivate industry participants and businesses to make net zero-enabling choices in their selection of data storage and processing solutions and outsourcing providers. There is also scope for Government to go a step further with respect to its own data storage, usage and infrastructure – to ensure that all future procurement decisions have a net-zero requirement to fulfil. 

G.     Mission five: Championing the international flow of data

In our hyper-connected world, the ability to exchange data securely across borders is essential.

As the UK leaves the EU, we have the opportunity to develop a new UK capability that delivers new and innovative mechanisms for international data transfers.

Using our reputation as a world leader in digital, a champion of free trade and the rules-based international system, and an engaged, rule-abiding member of the global community, we will build trust in data’s use, creating the regimes, approaches and tools to ensure personal data is appropriately safeguarded as it moves across borders. We will also facilitate cross-border data flows by removing unnecessary barriers to international data transfers that promote growth and innovation. And we will seek to promote data standards, data interoperability, and UK values internationally.

Q18. How can the UK improve on current international transfer mechanisms, while ensuring that the personal data of UK citizens is appropriately safeguarded?

IB1 Response: Increasing numbers of international governments are putting in place localisation measures; measures which either mandate data to be kept locally or measures which impose conditions on the cross-borders transfer of data.  There is an urgent need for the Government to work with other governments and international institutions to seek to reverse these trends and to foster trust in the sharing of data across borders.  We repeat that problems that are shared across jurisdictions, such as Covid-19, require sharing and pooling of data resources across jurisdictions in order to identify common solutions. 

Many of the ideas we have noted above aimed at encouraging the increased flow of data would be applicable to data sharing across borders. Additional safeguards may be necessary to ensure intellectual property rights are protected in accordance with international agreements and national security is maintained. In addition, uniform licensing frameworks should be designed and adopted.

As a first step, however, we urge the Government to ensure EU ‘data adequacy’ to maintain free flow of personal data from the EEA. The UK should also engage with the EU in relation to its recent proposals for the sharing and re-use of non-personal data, ensuring access for UK businesses and institutions to the resources that foster innovation and enable digital services. For information see http://europeanmemoranda.cabinetoffice.gov.uk/files/2020/11/ST_13351_2020_INIT_en.pdf

We will seek EU ‘data adequacy’ to maintain the free flow of personal data from the EEA and we will pursue UK ‘data adequacy’ with global partners to promote the free flow of data to and from the UK and ensure it will be properly protected.

Q19. What are your views on future UK data adequacy arrangements (e.g. which countries are priorities) and how can the UK work with stakeholders to ensure the best possible outcome for the UK?

IB1 Response: We are aware, anecdotally, of informal conversations between various data initiatives in the UK and other jurisdictions, such as Australia and New Zealand, around some of the issues raised around post-Brexit data adequacy, continuation of data access and accessibility / interoperability of data. These conversations cover topics such as the development of data consent mechanisms, which are crucial for data sharing and interoperability in a cross-border context. There is a need for these types of conversations to take place via more formal, Government-sponsored channels, if we are to truly collaborate with international partners in development of more robust common frameworks and open up opportunities for businesses, fintechs, and technology providers. 

There is also a need, when considering post-Brexit trade agreements, to understand the full impact of their provisions on the UK’s data security and on data sharing, and the challenges for data adequacy and consent. For example, concerns exist that the recent UK-Japan free trade agreement (FTA) could create a back door for UK data to flow to third countries via Japan. 

In this respect, we are in agreement with the ODI’s view that “Furthermore, on the future of adequacy regime after Brexit, injecting free data flows in trade law is a questionable way forward, because this tends to crowd out other efforts around multi stakeholder governance that aspire towards a more rights-preserving and inclusive approach to safeguarding human rights. Instead, a more viable strategy would be, as mentioned above, to create a digital rights scaffolding, together with liberalising cross-border data flows while respecting data protection.” (http://theodi.org/wp-content/uploads/2020/11/Getting-data-rightperspectives-on-the-UK-National-Data-Strategy-2020.pdf , p29)

Photo by NASA on Unsplash

Introduced by the EU in 2007, EPCs provide information on a property’s energy usage, using a ranking system of A – (the most energy efficient) to G – (the least energy efficient) as well as suggesting methods to improve energy efficiency. To paint a picture of the task at hand, 71 percent of UK homes do not meet EPC standard C, the minimum requirement to bring buildings in line with net zero.

Open data and accuracy

While EPC data could prove to be a useful instrument in framing policy ideas centred around a green economic recovery, we should first assess the potential flaws in this data. According to a report by Spec, around 2.5 million EPCs could be wrong because of errors in measurement standards and practices. What’s more, the Property Technology solution states that 90 percent of EPCs lodged use simple averages or standardised values rather than actual measurements.

Another seemingly glaring error is the depth of inspection. If an assessor is unable to see the use of energy efficient measures, such as loft insulation, then the software used assumes an insulation level in line with when the property was built. Meaning, that for a house built over 100 years ago, zero insulation will be assumed, providing an inaccurate portrayal of housing efficiency.

EPC data is publicly available in England and Wales under a UK Open Government license v3.0 with the exception of address data which is provided under a Royal Mail Copyright Notice. Open data access to real-time EPC datasets can improve functionality and enable interoperability between other government owned databases as well as providing value to academia and businesses. The UK government’s ‘Action Plan’ released in September 2020, lays out plans for the creation of a new EPC register by the end of 2020, addressing issues of accuracy and openness while also moving towards EPC ratings that are more reflective of actual household energy use, an important move given the increased number of people working remotely.

A tool for framing policy

Across Europe, EPC data is being utilised for policy making and monitoring. Bulgaria, for example, set its national recovery strategy using EPC data. And, in a pilot scheme run by the Energy Efficient Mortgages Initiative, lenders will be offering lower interest rates on mortgages for both new build homes and renovations based on EPCs. KfW’s Environmental and Energy Efficiency Programme provides subsidies to building owners, including long-term loans with low interest rates and grants. The German development bank uses EPCs to determine the efficiency level of a household, rewarding higher efficiency levels with higher funding.

EPC data can be a critical metric in forming policy and shaping green initiatives. And, with domestic homes alone accounting for around 15 percent of UK’s greenhouse gas emissions, the data provides both public and private owners and tenants with vital information, legal certainty and incentives to improve their household energy efficiency. But, in order for the government to meet its commitment to net-zero by 2050, EPC data needs to be more accurate, reliable and open. 

Find out more

On Monday 16 November 2020, our team will be hosting a session to discuss how policy interventions can help local governments, cities and regions accelerate innovation and drive toward a net-zero economic recovery from Covid-19 at London Climate Action Week 2020. Their remarks will draw on the preliminary findings of our net-zero Covid-19 recovery programme, Project Cygnus. To find out more about the findings which will touch on some of the content elaborated above, sign up for free here.