Balancing and Settlement Code
Process for requesting BSC data
Process for requesting BSC data
1. Reference is made to the Balancing and Settlement Code for the Electricity Industry in Great Britain and in particular, BSC Sections B, H, and V
2. This is Version 1.0 of the process for requesting BSC data
3. This document is effective from 24 June 2021.
4. This document has been approved by the Panel.
Intellectual Property Rights, Copyright and Disclaimer
The copyright and other intellectual property rights in this document are vested in Elexon or appear with the consent of the copyright owner. These materials are made available for you for the purposes of your participation in the electricity industry. If you have an interest in the electricity industry, you may view, download, copy, distribute, modify, transmit, publish, sell or create derivative works (in whatever format) from this document or in other cases use for personal academic or other non-commercial purposes. All copyright and other proprietary notices contained in the document must be retained on any copy you make.
All other rights of the copyright owner not expressly dealt with above are reserved.
No representation, warranty or guarantee is made that the information in this document is accurate or complete. While care is taken in the collection and provision of this information, Elexon Limited shall not be liable for any errors, omissions, misstatements or mistakes in any information or damages resulting from the use of this information or action taken in reliance on it.
Description of Changes
Scope and Purpose of the Process for Requesting BSC data
The Main Users of the Process for requesting BSC data are:
All BSC Parties
All BSC Agents
All BSC Party Agents
BSC Company (BSCCo)
BMRS Change Board (BCB)
Review Procedure and Change Process
For the purposes of BSC Procedure BSCP40 (Change Management) this document is a Category 3 BSC Configurable item, meaning that it is not subject to the Modification Procedures in Section F ‘Modification Procedures’ of the BSC, or the Change Proposal process described in BSCP40. The Panel has agreed the following process for amendments to this document:
It is the Panel, or its delegated authority’s, decision whether to review or change the process but, BSCCo, BSC Parties or the NETSO can request them to do so;
The Panel, or its delegated authority, may request assistance from the BSCCo e.g. in analysing whether a change is needed;
The Panel, or its delegated authority, can agree a change to the process based on recommendations by the BSCCo or the NETSO. It does not need to consult with BSC Parties to introduce a change but may choose to do so; and
This document is owned by BSCCo. Changes to this document will be drafted by BSCCo following Panel, or its delegated authority, agreeing a change to the process or to any other part of this document.
Reviewing data release arrangements
The BCB will periodically review the contents of this document. The first review will be no later than 24 June 2022, with subsequent reviews no longer than 24 months apart.
This document may be changed as required, and a review can be called for at any time. A review may be called for by the BSC Panel, BCB or BSCCo.
For clarity, the review periodicity will be the maximum period between reviews. In determining the periodicity of reviews, the following shall be considered:
Time since last review
Number of requests received since last review and impact on BSCCo resources
Number of appeals raised since last review
Complexity of requests since last review
Best practice adopted by third parties
Any risks that have been identified with the existing process
Input from the BSC Panel or BSC Panel sub-committees
In particular input from the PAB in relation to Settlement Risks
The above list is not exhaustive and is intended for guidance.
In November 2017 the Secretary of State
for Department for Business, Energy and Industrial Strategy (BEIS) presented the UK’s Industrial Strategy. The Strategy pledged to ‘set Grand Challenges to put the United Kingdom at the forefront of the industries of the future’. The first four Grand Challenges
are intended to focus ‘on the global trends which will transform our future’. One of the Grand Challenges is concerned with Artificial Intelligence and Data; this Modification is concerned with the data aspect of that Great Challenge.
BEIS and Ofgem published a joint policy paper in July 2017: ‘upgrading our energy system: smart systems and flexibility plan’
. In October 2018, they published a progress update to their policy paper and within this; they established the Energy Data Taskforce (EDTF)
. The purpose of the EDTF was to ‘look across the energy sector, identify gaps where data can be used more efficiently and make clear, actionable, recommendations for Government, Ofgem and industry.’ In June 2019, the EDTF published their report ‘A Strategy for a Modern Digitalised Energy System
’ with five recommendations:
Digitalisation of the Energy system – ‘Government and Ofgem should direct the sector to adopt the principle of Digitalisation of the Energy System in the consumers’ interest’
Maximising the value of data – ‘Government and Ofgem should direct the sector to adopt the principle that Energy System Data should be Presumed Open’
Visibility of data – ‘A Data Catalogue should be established to provide visibility through standardised metadata of Energy System Datasets across Government, the regulator and industry.’
Co-ordination of Asset registration – ‘An Asset Registration Strategy should be established to coordinate registration of energy assets, simplifying the experience for consumers
Visibility of Infrastructure and Assets – ‘A unified Digital System Map of the Energy System should be established’
In order to implement recommendation two, the BSC Panel raised BSC Modification P398 on 12 December 2019. P398 was approved by the Authority on 3 February 2021 and implemented on 24 June 2021. This document sets out the process by which data can be requested.
BSC data can be requested by anybody – there is no requirement to be a BSC Party, Party Agent, BSC agent or connected with the BSC or wider energy industry in anyway.
The BSC Panel has delegated responsibility for data requests to the BCB other than where mentioned in this document.
SECTION 2 – REQUESTING DATA
BSC Section H defines data in the following way:
‘data or information held by, or on behalf of, BSCCo and which is received, produced or sent by or on behalf of Parties under the Code (including, for the avoidance of doubt, by BSC Agents and Party Agents) for the purposes of Settlement but excluding any data or information that the Code explicitly identifies as confidential’
Prior to BSCCo making any recommendations to the BCB, they shall ensure that they have ‘ownership’ of any data passed to them by a third party and, if required, they shall consult with the third party as to consent to publish as part of a wider data set (and ensure any legal arrangements are in place if required).
To be explicitly clear this means any data held by BSCCo or BSC Agents that relates to BSCCo’s activities under the BSC. Any data that is held by Elexon pertaining to non-BSC matters is not subject to the process laid out in this document. Examples of this may include staff salaries or activities pertaining to its business activities or its subsidiaries that is separate to its role as BSCCo.
The data request form on the BSC Website must be used when requesting data. Submitters should follow the instructions on the form as to what is required in each of the form’s fields. The request form will contain the following fields:
Requester’s Company/organisation (if applicable)*
Requester’s contact details*
A description of what data is being requested*
When the data is required by*
Reason for request, including (where applicable) the perceived industry benefit for making the data publically available*
If data being requested is third party data
*Indicates mandatory field
Once completed, the request form should be submitted digitally, or e-mailed to email@example.com
. The BSCCo
will acknowledge receipt and carry out a ‘critical-friend’ review before providing feedback to the submitter, including potential changes to make the request easier to comply with, and an indication of timelines.
While the BSCCo has access to an abundance of data, occasionally it may need to call on a BSC Agent to provide data they hold in relation to BSC activities. The BSC Agent may be asked to provide an impact assessment in relation to time and cost. This in turn will inform whether a request should be processed.
The BSCCo will indicate to the submitter if this is required and build this in to the predicted timescale for processing the request.
Data requests will be triaged to determine the ‘openness’ of the data requested if the data were to be released in its existing format. BSCCo do this to consider whether the data set could cause issues. The triage categories are:
Consumer Privacy – A person who can be identified from the information requested – either directly or indirectly in combination with other information
Negative Consumer Impact – Likely to drive actions that will negatively impact consumers
Security – Creates incremental, or exacerbates existing, security issues which cannot be mitigated via sensible security protocols such as physical site security, robust cyber security or buffer databases
Commercial – Relates to the private administration of a business or, data not collected as part of an obligation by a regulated monopoly and would not have been originated or captured without the activity of the organisation
These are the categories recommended by the EDTF and represent industry best practice.
Once triaging has taken place, the data requested will be classified into one of the following categories:
Open – Available for all to use, modify and distribute subject to the conditions in the open data licence
Public – Publicly available but with some restrictions on usage
Shared – Available to a limited group, possibly with some restrictions on usage
Closed – Only available within a single organisation
These are the classifications recommended by the EDTF and represent industry best practice.
In order to make data accessible, BSCCo will attempt to apply mitigating actions to the data so that it can be released. Mitigation methods may include, but are not limited to:
Redaction - Removal of sensitive data
Anonymisation - Removal of personal data
Aggregation - Combine data sets so the collective sum is less sensitive
Limitation - Only share with specific individuals or group
Noise - Combine original data with dummy data to confuse readers
Delay - Wait until data is less sensitive before sharing
Differential privacy - Obscuring the data in such a way as to mask identities
Shift/rotate - Altering the position or orientation of spatial or time series data
Randomisation - Making random changes to data
Normalisation - Modifying data to reduce the difference between individual subjects
These are mitigations recommended by the EDTF and represent industry best practice.
Once mitigation has been applied, it will be re-classified and, if necessary, further mitigation may be considered. Mitigation will not be applied until the BCB has determined that the requested data can be released.
It may be necessary to mitigate data for publication to reduce the classification, but an unmitigated dataset may be provided to the requester confidentially in order for the requester to make use of the data set – it is envisaged that this would be a rare exception and the BCB should consider this in their determination.
SECTION 3 – DATA RELEASE CONSULTATION
Prior to the BCB making a determination on whether to release requested data, the BSCCo shall issue a consultation to industry for no more than 15 Working Days (WD). The consultation will follow a standard format and shall include, but not be limited to:
Initial triage and classification – BSCCo’s initial assessment of the requested data set
Proposed mitigation – How BSCCo proposes to mitigate the data to make it more open (if applicable) and what the subsequent triage and classification shall be
Benefits – What will be the benefits to BSC Parties, wider industry, and/or requester should the requested data be released
Impacts – What will be the impacts to BSC Parties, wider industry, and/or requester should the requested data be released
Duplication – Whether BSCCo is aware of similar data sets produced by themselves or other organisations
Coupling – Whether the data set could be coupled with other data sets (published by BSCCo or others) for commercial, nefarious or other purposes
Risk – What (if any) will be the risk to Settlement, BSCCo and Industry members as applicable
Costs – What will be the cost for the BSCCo in terms of time and money to create the data set. This will include BSC agent costs as well as any ongoing costs if applicable.
Periodicity – Whether the data set is proposed to be re-published at given intervals, or as a one-off
Review period – How often the BCB should review whether the data set remains extant or whether it will be published in perpetuity to be reviewed by exception
Additional information – Anything else that the BSCCo feels pertinent to allow respondents to make an informed decision
Recommendation – BSCCo’s initial recommendation to BCB
Ofgem are developing a central data base of data available in the industry. This will be consulted in relation to duplication and coupling once available.
Responding to a consultation
The consultation shall be run as a ‘negative response’ consultation. That is, it will be assumed that there are no objections if a response is not received.
Responses will be accepted in any format. While a template will be provided, a response as a free text e-mail, or other means of communication will be accepted. Responses to consultations should be sent to firstname.lastname@example.org,
please ensure it is clear which data request consultation you are responding to.
SECTION 4 - OPENNESS AND TRANSPARENCY
All requests for data will be published on the BSC Website, however the requester’s details and reasons may be subject to triage, classification and mitigation. This is because a company may not wish for their peers to know they are requesting data and/or why they are requesting data as it may be indicative of wider commercial activity.
Submitters of data requests should indicate to BSCCo whether they wish to be anonymous.
All consultation responses will be published, but will be subject to triage, classification, and mitigation will be applied to responses at the request of the respondent if, for example, the respondent requires some of their response to remain confidential.
Determinations (regardless of outcome) will be published on the BSC Website, including the reason for the BCB’s determination. Again, triaging etc. will be applied to this notification if deemed applicable based on the data requester’s wishes and/or BCB’s determination. For example, if has been determined that the notice should not name the requester (Triaged as commercial in confidence) then their name can be removed (anonymisation mitigation), but the full notification, without anonymisation may be shared with Ofgem if requested (shared classification).
The BCB shall determine whether a requested data set shall be released and whether any mitigating action shall be applied. The BCB will be presented with BSCCo’s recommendation and consultation responses (if any) to assist with their determination. When making its determination the BCB shall consider each of the items listed in the bullet points above pertaining to the consultation.
Where approval to publish is not granted, the BCB will normally recommend actions to achieve approval, and the request may return for consideration at a subsequent meeting. If further changes are suggested by the BCB, the default position will be that another consultation will be issued; unless the change is deemed by the BCB to be of minor or inconsequential nature such that it would not be in industry’s interest to re-consult.
Cost threshold for making determinations
The BCB is required to defer decisions to the BSC Panel where the cost to produce the data set will be £150,000 or more. This is commensurate with thresholds established for other BSC Panel sub-committees.
The BCB’s terms of reference are published on the BSC Website – these include its responsibilities regarding the release of BSC data and align with this document.
SECTION 6 - SECURITY CONCERNS
Where there is a belief that releasing certain data, or even acknowledgement of the existence of that data, could cause security concerns, BSCCo and/or the BCB will not hesitate to refuse the request outright.
We do not envisage any scenario where this could happen, but if, at some point in the future this should change, Ofgem and/or the National Cyber Security Centre (via Ofgem or direct) will be consulted for advice.
SECTION 7 - BCB DIRECTED DATA RELEASE
In addition to determining whether requests for data should be granted, the BCB may direct BSCCo to prepare data sets for release. Reasons for making such a direction may include, but not be limited to:
Carrying out of direction from the BSC Panel;
Following request from another BSC Committee;
Following a request from BSCCo; and
At their own discretion if they feel it will better facilitate the BSC’s operation and/or the Applicable BSC Objectives
Any directed data releases will follow the procedures elsewhere in this document, specifically:
SECTION 8 - APPEALS PROCESS
All BCB determinations (regardless of the determination) shall be subject to appeal.
Any BSC Party, or non-BSC Party may appeal. The window to appeal is 15 Working Days. This means that the earliest any data set may be published is 16 WD after the BCB’s determination.
An appeal may be lodged by anybody by communicating to the BSCCo that they wish to appeal, and in doing so provide a reason for their appeal.
Following receipt of an appeal, the data set will not be published until the BSC Panel has considered the appeal. The BSC Panel will consider the appeal at its next meeting following the appeal being submitted provided the appeal is received by the Panel 5 Working Days before the next scheduled meeting (otherwise it will be considered in the meeting after). The BSC Panel may also consider the appeal at a later meeting if there are reasonable circumstances to delay such review (this shall be agreed between the appellant and the BSC Panel Secretary – or suitable deputy).
BSCCo will publish a notice on the BSC Website that an appeal has been lodged and will notify relevant interested Parties. The notice of appeal will include the details of the appeal and reason for appeal. The notice of appeal will also include the next steps, including the date of the BSC Panel meeting to consider the appeal.
The appellant may attend the BSC Panel meeting at which their appeal is considered (subject to BSC Panel attendance rules), and the BSC Panel may invite them to attend, and they may oblige anyone subject to compliance with the BSC to attend if they feel it is appropriate.
SECTION 9 - REVIEW OF DATA SETS
The BCB will be able to review and amend data classifications and mitigations for data sets that have already been published. This should occur as required and/or at the Panel or BCB’s discretion. It may be instigated as the result of condition of publishing or if requested by a connected person or group e.g. BSCCo, a BSC Party or the BSC Panel.
Publishing and rescinding of data
Following the BCB’s determination that a requested data set may be published, BSCCo will prepare the data set and apply the mitigations directed by the BCB as part of its determination.
Data sets shall be named in such a way that their content, origin and purpose is readily apparent; meta data shall amplify this, as well as making the data set as discoverable as possible on internet search engines.
Within one WD of the BCB’s determination, BSCCo shall publish a notification of the determination, and that the appeals window is open. This shall include information on how to appeal (see above) and when the appeals window will close – this notification shall be based on the notification made by BSCCo in relation to Self-Governance Modifications.
At the end of appeal window (i.e. 16WD after the BCB’s approval), BSCCo shall publish a notification that the appeals window is closed and that the data set will be published as per the report submitted to the BCB.
Where it is brought to the attention of the BCB that a data set’s publication should be discontinued, a determination shall be made at the next BCB meeting. However, should BSCCo consider that publication should desist before then, they shall carry out the required actions and report such to the BCB at its next meeting. The BCB shall then either affirm BSCCo’s actions or give direction otherwise to either re-publish in entirety or carry out mitigating actions prior to re-publishing.
SECTION 10 - RECORD KEEPING
BSCCo maintains a log of all data requests, which is published on the BSC Website quarterly as a routine report i.e. a single snapshot of all requests and their outcomes.
SECTION 11 - COSTS FOR PUBLISHING DATA
The decision to approve publication where the costs exceed £150,000 will rest with the BSC Panel and the BCB will pass such decision, with a recommendation on whether to approve publication to the BSC Panel. This threshold is based on the threshold for other BSC Panel committees to pass approval to the BSC Panel when considering BSC Change Proposals.
The BSC Panel will consider whether the benefit for the industry as a whole (and not just BSC Parties) outweighs the cost of publication. As with any other data decision, refusal to publish based on cost is subject to appeal, albeit the appellant will be asking the BSC Panel to re-consider their own decision.
BSC Section H retains the right for the BSC Panel to charge for the release of data should they feel this should become required at some point in the future. Should the BCB wish to exercise the BSC Section H option, they will need to change this document and seek approval to change their terms of reference too.