Response to open letter on Market Intelligence Service (MIS) development
In principle we support the development of a MIS, which should help deliver more reliable switching, in concert with Ofgem’s switching programme. We welcome the proposal that the MIS should be flexible and developed incrementally. This will enable functions to be added and developed to meet changing needs and priorities of users and consumers. In our view there are three main areas which the Joint MIS Development Group (JMDG) should consider in their vision and development of the MIS.
1. Minimising costs and maximising benefits
The costs of developing the MIS will ultimately fall on consumers. In Ofgem’s cost-benefit analysis, the development of a new MIS added £48m in costs to the switching programme over the 18 year period assessed, while not delivering significant benefits. Ofgem’s assessment was that this ‘does not therefore appear offer good value’. The main driver of these costs was supplier costs for setting up and operating new arrangements to interface with the MIS.
The JMDG should set out how their proposals will reduce costs, and maximise benefits, compared to the MIS option that was considered and rejected by Ofgem. We would expect that the Group will further assess costs and benefits of proposed changes of each release as the MIS is developed.
2. Alignment with Ofgem’s switching programme
It is essential that development of a MIS is closely aligned with Ofgem’s switching programme in order to minimise the programme’s delivery risk.
On the technical side, the Central Switching Service (CSS) is required to interface with the existing enquiry services, and so any changes resulting from the MIS development will need to be taken into account. On the regulatory side we agree with the JMDG that there is a role for the Retail Energy Code (REC) with regard to MIS functions. The REC is due to be developed over 2018/19, so close working will be required between the JMDG and Ofgem to determine areas where the REC will need to accommodate the new MIS (or where it may need to be amended in the future as the MIS develops).
3. Data protection
The Information Commissioner’s Office (ICO) has previously set out that information connected to MPxNs is classed as personal data. The new MIS could manage more data than the current systems, and widen the pool of users who are able to access this data (perhaps even allowing consumers to directly access and amend records). Data privacy and security should therefore be a priority. We welcome the JMDG’s recognition of this issue, and the intention to produce Privacy Impact Assessments and engage with the ICO as necessary.