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CODE responded to proposals for Open Communications - a Smart Data Scheme in the telecoms market.

The Coalition for Online Data Empowerment (CODE) submitted a response to the government’s consultation for Open Communications – a Smart Data Scheme for the telecoms sector.

As a member of the Smart Data Council, CODE is supportive of the government’s ambitions for rolling out schemes like Open Banking in as many sectors as possible, and is in principle supportive of the Open Communications proposals.

Beyond this high-level support, CODE’s response has highlighted the following issues:

  • The government needs to bring forward and publish a joined-up and ambitious pipeline of Smart Data Schemes for multiple sectors, which would enable us to review the proposals for Open Communications in the appropriate context.

  • Viewed as a standalone proposal, Open Communications does not appear to be the right sector for the government to prioritise, when alternatives such as Open Digital could offer much larger and wider range of benefits for the UK economy. CODE has produced an early-stage impact assessment for Open Digital to illustrate the scale of potential benefits available.

  • The data proposed to be included within the scheme is too narrow, appearing to exclude the range of user data that the mobile service providers aggregate and sell on themselves, such as location data. CODE recommends that Smart Data Schemes should seek to incorporate data that is an input, output, and a byproduct of a relevant service, and if a provider is profiting from the sale of data, it should as a matter of course be within scope.

  • Lighter-touch implementation options that would rely on consumers to do some of the heavy lifting should be discounted. The collective experience of CODE members suggests that these options will fail to have any meaningful impact on consumer engagement.

CODE’s response, including the illustrative impact assessment for Open Digital, are published below.

Get in touch if you would like to discuss this submission.

Open Communications - response from CODE
Download PDF • 218KB
Open Digital Impact Assessment
Download PDF • 472KB


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