How can data sharing support customers in vulnerable situations?

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At Ofwat, we put customers at the heart of everything we do. It’s our job protect the interests of customers, especially those who may find themselves in a situation of vulnerability.

Affordability and vulnerability are two fundamental challenges facing the water sector, and they show no sign of abating. We have published two reports on this, our Affordability and Debt Report and, building on that, our Vulnerability Focus Report, to help water companies understand the pressures being faced by their customers. In both those reports we’ve recommended how companies could respond and how we as the regulator, and customers themselves, should evaluate companies’ behaviour.

Our Vulnerability Focus Report identified the transient nature of vulnerability and the subsequent importance of companies having accurate, good quality information about their customers’ circumstances in order to understand their needs and be able to support them effectively. Our Report also noted that data sharing may help companies to recognise affordability issues much earlier – it is usually the case that if a customer is struggling to pay their water bill, they will likely have trouble paying other bills.

And we’re not the only ones thinking this way.

That’s why we have joined forces with Ofgem and the UK Regulators Network (UKRN) to identify the potential benefits, opportunities and challenges that may arise from data sharing across water and energy. In our open letter to our stakeholders, published on the UKRN website, we have updated on our progress so far.

As part of that work, we are exploring how vulnerability information is currently processed in the water sector and what the benefits, opportunities and challenges of sharing that data in a targeted, proportionate and appropriate manner would be.

So far, we have engaged with a number of stakeholders such as Water UK, the Citizens Advice Bureau and The Information Commissioners Office (ICO), to get a wider perspective on the developments in this space. We have found that data sharing could lead to benefits for customers, save them time and improve their overall experience by reducing the number of potentially stressful interactions they need to have with their utility companies to inform them of their circumstances. It could also lead to cost savings for companies, for example, there may be less need for companies to run awareness campaigns to identify consumers in vulnerable circumstances.

Targeted and proportionate data sharing could enable and improve cross-sector collaborative working between companies in the water and energy sector and better equip companies with the information they need to anticipate and respond quickly to the needs of consumers in vulnerable and crisis situations.

Our engagement has also identified some challenges. There are data security implications associated with the exchange and distribution of sensitive consumer information and this will need careful management. The rules and regulations that govern data handling and protection are complex and changing rapidly. Companies need the expertise and flexibility to adapt to this evolving framework. Customers want to be reassured about data security and it is important that they know why their data is being collected and how it will be used, who it could be shared with and why it will be shared.

Although our work is focused on data sharing between the energy and water sectors but we recognise there may be benefits to information being shared across other ‘essential services’ sectors and other members of the UKRN such as Ofcom have a keen interest in this work. We’re now planning further engagement and we’re aiming to publish our findings in Spring 2017. At that stage we’ll consider whether more work should be done, and which parties are best placed to take it forward.

If you are interested in this work or in engaging with us further, please contact Gurpreet Sahota or Dannii Leivers by emailing [email protected]

Dannii Leivers
Strategic Advisor to the Senior Leadership Team