Energy Systems Catapult welcomes the opportunity to respond to the Data Best Practice Guidance consultation.

The Catapult is supportive of the changes suggested by Ofgem, with additional comments to be found in direct response to each question set out in this document.

Additionally, we would like to make the case for an additional principle around Data Ethics. We have worked with the Open Data Institute to develop this new principle and have socialised that concept to the industry with posts that can be found on the websites of the ODI, Energy Systems Catapult, & Utility Week as well as a number of LinkedIn and Twitter posts by both the ODI and Energy Systems Catapult. The blog also appeared in the Utility week newsletter on Thursday April 13^th.

We believe that Data Ethics is an important consideration for data practitioners and including a principle will play a role in supporting a just transition of the energy sector. Our suggested new principle, written in the style of Data Best Practice guidance, is set out below:

[Definition] Data Ethics: A branch of ethics that evaluates data practices with the potential to adversely impact on people and society – in data collection, sharing and use.

Ensure that Data Assets, Metadata and Software Scripts are collected, used or shared with due consideration for Data Ethics.

Explanation

1. The licensee must ensure that where Data Assets, Metadata or Software Scripts are collected, used or shared by the licensee, ethical implications of their collection, use or sharing are assessed.
2. The licensee must document the ethical assessment, as well as any changes or mitigations made to the collection, use or sharing of Data Assets, Metadata and Software Scripts, as a result of the assessment.
3. The licensee’s supporting information regarding a Data Asset must include any relevant information for its ethical use or sharing by Data Users.

Intended Outcome

1. The licensee can demonstrate that Data Assets, Metadata and Software Scripts held by the organisation will be collected, used or shared ethically by the licensee.
2. The licensee provides sufficient information to Data Users to ensure they can use or share the Data Assets, Metadata and Software Scripts with due consideration of ethics.
3. Stakeholders trust that the licensee is collecting, using or sharing data in an ethical way.
4. Derived insights from Data Assets should be created and presented in such a way that ethical considerations of the Data Assets are understood by stakeholders.
5. Licensees use or develop ethical frameworks around the collection, use and sharing of Data Assets, Metadata and Software Scripts.

While not set out in the scope of the consultation itself, we believe if other respondents, particularly energy networks respond in support of this new principle, it should be included.