Accurate and Up-to-date – Irish Water and changing data

So, via Twitter I’ve learned that Irish Water don’t have a process defined yet for people moving house. Well, they have one defined but its “not signed off on yet”. This is a pretty basic process that exists in all utilities, satellite TV companies, and fixed line phone companies. Its the one you rely on to ensure that the bills are correct at the point of hand over.

Given that Irish Water are billing quarterly, that means that people are inevitably moving in or out of a property during a billing period. This will lead to what is known as “broken period billing” in utilities. When I worked in telco, it was the handling of these scenarios that gave rise most often to billing errors, particularly where the broken period for billing crossed a VAT period or where the preparation of a final bill involved the calculation of and application of credits on final bills etc.

This is tricky stuff, which is why it is good they are taking their time about it. However, if true, the absence of such a process or procedure NOW means that:

  1. Irish Water is in breach of the Data Protection Acts which requires Data Controllers to keep data “accurate and up to date” , at least accurate enough and up to date enough for their purposes. Having the wrong name associated as bill payer on a property is inaccurate for their purposes. They don’t need to ensure accuracy per se, but they need to have a defined process where by changes to data can be made. That’s the kernel of the obligation in the DPA and, let’s not forget it, a fundamental right under EU law under Article 8 of the Charter on Fundamental Rights.
  2. Bills will inevitably be sent to the wrong people, potentially in the the wrong amounts, which will potentially affect collections processes.

It looks more and more like the data design here and attention to data changes in customer life cycle is appallingly bad. I do hope that the tweeter got the wrong end of the stick when they were talking to Irish Water, but my optimism is rapidly going down the outflow pipe.

This stuff is really, really basic. However it means having to think about your data as more than just “stuff that lives in the database” and treat it as an asset that is subject to certain fundamental governance requirements.

We’ll be touching on a lot of these topics at IGQIE2014 on the 7th of November, and I’m teaching about it at conferences in Belgium and the UK in the mean time. I was struggling for examples….

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