Contents

Foreword
Chapter one Introduction
Chapter two Background to the revised scheme
Chapter three Operators
Chapter four Approval bodies
Chapter five Scope of approvals
Chapter six Assessment and compliance
Chapter seven Approval and certification
Chapter eight Transition period for approvals under OTR003: 1993
Chapter nine Scheme review
Chapter ten Categorisation of observations and non compliant matters
Chapter eleven Publications
Chapter twelve Guidance for the use of OTR003: 2001
Glossary

Annex A PTO Licence Condition 11 Metering Arrangement
Annex B PTO Licence Condition 12 Billing Arrangements
Annex C PTO Licence Condition 13 Itemised Bills
Annex D Good practice guide for actions when dealing with upheld complaints
Annex E Examples of application to a multi-Operator TMBS
Annex F Approval Body Forum Terms of Reference

Foreword

This Scheme Guide has been written for the United Kingdom Telecommunications Metering Systems and Billing Systems Approval Scheme. It provides details of the operational framework and rules for the administration of the Scheme together with guidance on the interpretation of the technical requirements contained in the Standard, OTR003: 2001.

Title Case is used to highlight words where definitions and abbreviations are contained in OTR003: 2001. References to Clauses are to Clauses of OTR003: 2001

Chapter one

Introduction

1.1 The purpose of this Scheme is to appraise and where compliant approve the Metering systems & Billing systems used by Operators and service providers to ensure that they meet defined levels of accuracy.

1.2 This Scheme is operated by the Director General of Oftel (DG Oftel) and will apply to all Operators with an annual relevant (ie telecommunications sector) turnover of £1 million or more.

1.3 Operators will be required to enter into a contract with an Approval Body for the assessment of their metering and billing systems. Approval Bodies are appointed by the Secretary of State at the Department of Trade and Industry (DTI). The term "Operator(s)" is described in section three of this document.

1.4 The Approval Body will assess an Operator’s Total Metering and Billing System (TMBS) for each product and service that meets the materiality rules described in the Standard. Approval Bodies will approve systems that are compliant with the Technical Requirement.

1.5 This Scheme has been designed to apply to a wide range of network services and applications. The overriding principle is that customers should be charged neither more nor less for the services they use than is specified in the tariff to which they subscribe.

1.6 The Scheme documentation consists of, but is not limited to:

The Scheme Guide

OTR003: 2001, the Standard

Approval Bodies’ proprietary documentation and certificates

Operators' documented metering & billing systems, including Service Usage Specifications (SUS), Service Level Agreements (SLA) and Quality Management Systems (QMS)

Operators’ published and agreed tariffs.

Chapter two

Background to the Revised Scheme

2.1 The Telecommunications Act 1984 provides that meters used to measure the usage of telecommunications services may be subject to approval. Since 1984, the telecommunications industry has deployed new technologies and offered customers new forms of service. Customers purchase services and products that they believe will address their requirements, but they may lack detailed knowledge of how these services work.

2.2 In consequence Oftel published a consultation document in March 1998, entitled "Meeting Customer Needs For Accurate Telephone Bills", which led in turn to the publication in February 2000 of a policy statement, "Ensuring Telephone Bills Are Accurate". The revised Scheme has been developed with the industry to satisfy those stated principles of policy.

2.3 There has been a long-standing recognition that a Bill for Telecommunications Services can be regarded as a product in its own right; because it has significant cost implications for Operators and their customers.

2.4 In a rapidly changing environment, it is ultimately for customers to choose between competing Operators’ service offerings. Operators may claim that their billing product is superior to rival products; but this claim is difficult for customers to verify.

2.5 The DG Oftel has decided to afford greater protection to customers by extending the approval Scheme previously operated with the standard OTR003: 1993. 2.6 The following steps have been taken in order to establish the framework for a revised Scheme:

revision of the Metering Standard OTR 003 : 1993 to encompass the TMBS in use at present and to include service provision fixed charges (eg line/access rentals) as well as service usage (eg telephone call) charges;

widening the scope to include additional providers of telecommunications as described in the Operators’ section of this document;

increasing the number of Approval Bodies authorised to offer assessment, approval and certification services to Operators.

2.8 The DG Oftel acknowledges the participation of industry representatives in developing the Scheme revisions and thanks all those concerned for their contributions.

Chapter three

Operators

3.1 An Operator in the context of the Scheme is an undertaking providing public telecommunications networks or publicly available Telecommunications Services. It includes but is not limited to Public Telecommunications Operators (PTO) and service providers.

3.2 Normally, the Operator issues a Bill to a customer for services arising from the operation of a telecommunications network of any description.

3.3 An Operator is likely to offer a range of services and would have difficulty in submitting all his different services and their associated TMBSs for approval at once. Having determined with his Approval Body which aspects are Material in the sense of the Standard, an Operator can then agree a programme with his Approval Body for phasing assessment and approval over a period of time. Such phasing should mainly be based on the importance of different services (their "global" materiality to the Operator’s customers both wholesale and retail or core nature to the Operator’s business) but may also take account of the ease with which each aspect of approval may be gained.

3.4 Situations can arise where the records of a number of chargeable events are quarantined and cannot be allocated to any valid Bill. Operators may identify areas of operation in which they deviate from the norm but remain compliant by generating a SUS and / or SLA. A SLA generally forms part of the customer supply contract for services, including contracts between Operators, but a SUS can remain confidential between an Operator and his chosen Approval Body to avoid potential for fraud, save for the purposes of review by the Approval Body Forum. Any such SUS or SLA will need to be assessed and agreed by the chosen Approval Body.

3.5 Operators may wish to present an existing documented and certified QMS as evidence towards compliance with this Metering Systems & Billing Systems Approval Scheme. In any event the QMS is to be assessed with respect to an associated TMBS by the Approval Body.

3.6 It follows from Clause 8 that in accordance with normal practice under a QMS, a senior executive will be nominated by an Operator to ensure the following:

• budgetary resources;
• human and other resources;
• full accessibility by the Approval Body to all component parts of a TMBS operated by the organisation.

It is expected that the person nominated will have an awareness of the following aspects of the metering and billing operations:

• performance against the Standard;
• assessment activity;
• recovery plan status of Category 1, 2 and 3 matters.

3.7 A PTO operates under the PTO licence and the relevant conditions in respect of metering and billing are reproduced at Annexes A to C for information. Subject to the caveats contained herein, a PTO is therefore obliged to seek approval under this Scheme.

3.8 A service provider or similar undertaking typically operates under a Class Licence such as the Telecommunication Services Licence (TSL) and is therefore subject to a licence condition concerning metering and billing accuracy which reads as follows:

"The licensee shall take all reasonable steps to ensure the accuracy and reliability of any metering system used in conjunction with the Applicable Systems and shall, in relation to any metering system, keep such records as the director has specified and notified to the licensee"

Obtaining approval of his TMBS under this Scheme is considered by Oftel to be best practice in fulfilment of this licence condition and is expected to become an industry benchmark for the leading service providers as well as PTOs. The Scheme is therefore open to applications for approval from all such undertakings that fulfil the description of Operator contained herein.

Chapter four

Approval Bodies

4.2 The Approval Body, its Director and the staff responsible for carrying out the tasks for which the Approval Body has been appointed must not be a designer, manufacturer, supplier or installer of telecommunications networks or of telecommunications metering and/or billing solutions. They must be independent of network Operators and service providers and avoid direct involvement in the design, construction, operation or maintenance of telecommunications networks or telecommunications metering and/or billing solutions. They shall not represent parties engaged in these activities. These restrictions do not, however, preclude the possibility of exchanges of technical information, including discussion of the means of meeting the requirements, between such organisations and the Approval Body.

4.3 The Approval Body and its staff must carry out the tasks for which the Approval Body has been appointed with the highest degree of professional integrity and technical competence. They must be free from all pressures and inducements, particularly financial, which might influence their judgement or the results of any assessment, especially from persons or groups of persons with an interest in such results.

4.4 The Approval Body must have at its disposal the necessary staff and facilities to enable it to perform properly the administrative and technical work associated with the tasks for which it has been appointed.

4.5 The staff responsible for assessments must have:

• sound professional and technical qualifications;
• A satisfactory knowledge of the evaluations required to be carried out and adequate experience of such assessments.
• The ability to draw up the certificates, records and reports required to authenticate the performance of the assessments.

4.6 The impartiality of inspection staff must be guaranteed. Their remuneration must not depend on the number of assessments carried out or on the results of such assessments.

4.7 The staff of the Approval Body are bound to observe professional secrecy with regard to all information gained in carrying out its tasks, although this does not preclude proportionate information-sharing with Oftel.

4.8 Approval Bodies will submit details of their implementation plans for joining the Scheme to Oftel, including reference copies of proprietary Scheme documentation and any revised versions thereof.

4.9 Approval Bodies will be expected to contribute information for, and participate in, an Approval Body forum constituted by Oftel to strive for fair and consistent application of the approval Scheme to Operators. The forum will employ electronic communication and meet as appropriate.

4.10 Approval Bodies appointed under this Scheme are expected to recognise each other’s approval activities and to co-operate in the approval of TMBSs spanning multiple Operators. Inter-operator dependencies may result in one Approval Body finding evidence to suggest non-compliance or similar of an Operator approved by another Approval Body. This should be brought to the attention of the latter Approval Body for investigation and if unresolved, referred to the Approval Body Forum for peer review.

4.11 In particular, where the TMBS for a particular service involves multiple Operators, then it is expected that an Approval Body already assessing a second party Operator’s systems will also assess those parts on which other third party Operators are dependant. Each Operator is expected to be responsible for the costs of his Approval Body.

Section 5.4 of this Guide also refers.

Chapter five

Scope of Approvals

5.1 Background

5.1.1 Any Bill received by a customer should meet the same Standard, whether one or many parties have been involved in its preparation.

5.1.2 If a Telecommunications Service is purchased from an Operator within the Approval Scheme, it is not relevant who carries out the metering and billing or if data or signals are accepted from overseas sources. That Operator needs to have contracts, SLAs and similar arrangements in place to ensure that the data, on the basis of which the Bill is drawn up, will enable compliance with the obligations of the Approval Scheme to be met.

5.1.3 Where an Operator is unable to establish best practice as described in paragraph 5.1.2, then he should agree a suitable statement with his Approval Body to put in Published Tariffs. An example is where there is recognised risk that late or poor signalling from an overseas operator may result in mistimed and thus overcharged calls.

In this situation Operators operate in a manner that readily allows an end to end metering and billing process to be examined and, if appropriate, approved. All the components that could have an effect on accuracy are managed directly by one organisation. Additionally, the platform(s) supporting individual services are readily distinguishable. In these cases, accuracy can be assessed on an end to end basis for each service for which approval is sought. An approval can then be granted listing the services found to be compliant. This might cover, for example, "All customer-dialled telephone calls, excluding those made using a ‘calling card’ and those involving operator assistance".

5.3 Operators using sub-contractors and evaluation of TMBS components in isolation

This Scheme recognises that sub-contracting may take place, while not allowing any compromises to the accuracy of the Bill received by the customer. This has several consequences:

• It is not sensible to "approve" an individual part of a TMBS, such as a switch, or a rating, billing or mediation system at its manufacturer’s premises. Experience suggests that only a minority of problems arise from hardware or software deficiencies. The majority normally arises from human error, e.g. inadequate data management and audit techniques or inadequate management of the interface between modules or between main and sub-contractors.
• It may be possible to assess certain features of the individual building blocks of a TMBS. No numerical standard is relevant to this assessment, nor can one conveniently be written, because the "share of inaccuracy" appropriate to each part will change as the TMBS develops over a period of time. Although no approval is feasible, an Approval Body may desire to give an opinion as to whether or not the item in question is considered to be fit-for-purpose.
• Each part of the TMBS will need to be evaluated for fitness for purpose using headings such as, but not limited to:
  

1. Capacity
2. Scalability
3. Management Information Outputs
4. Security
5. Traceability and ownership
6. Data management and audit
7. Clarity and completeness of configuration and operating instructions
8. SLAs
9. Contracts.
   

• In practice each Operator and Approval Body will agree a different balance between the information garnered from reviews of controls and operations and that taken from substantive measures of performance. One Operator may provide sufficient substantive data to obviate the need for an evaluation of individual controls and operations. In contrast, another Operator may opt to minimise the substantive evidence required by maximising the evidence taken from controls and operations reviews.
• Crucial to overall accuracy is the management of the interfaces between the separate parts of a TMBS. It follows that the ownership and management of these interfaces are key items for assessment, measurement and audit of the TMBS.
• Where the TMBS includes sub-contracted processes, the Operator should have appropriate contract terms, reporting arrangements, management controls and SLAs in place to ensure that he can demonstrate compliance with the requirements of the Standard to the satisfaction of his Approval Body.
• Circumstances may arise where an Operator may be regarded as a sub-contractor, for example if contracted to maintain a system that he does not use for his own customers. Such sub-contractors, who are also Operators in their own right, may be audited for the sub-contract functions as appropriate by their own Approval Body rather than the one associated with the contract holding Operator. The scope of such audit activity will need to be agreed between the two Approval Bodies.

5.4 A TMBS Operated by more than one Operator

A single TMBS may be operated by more than one Operator. For example a service provider applying for approval may rely on CDRs received from a PTO, which he then prices in his billing system. Where the PTO is a U.K. PTO licence holder within the scope of this Scheme in his own right, then the production of CDRs for the service provider shall be included in the PTO’s approval and be assessed by the PTO’s Approval Body. The service provider’s approval will reference this dependency. The service provider’s Approval Body should confine its assessment to the service provider’s billing system and the communication between service provider and PTO to check incoming CDRs for gross error and duplication etc. Each Approval Body will be expected to assess the arrangements for ensuring that all CDRs are correctly transferred and the associated measures at the receiving or sending Operator respectively. For the avoidance of doubt neither Approval Body is expected to visit both the PTO and service provider and each Operator is expected to be responsible for his own Approval Body’s costs.

5.5 Other Standards

An Operator may submit data or assessments used by other Standards or Codes of Practice for consideration by his Approval Body when they are assessing the TMBS. However such data or assessments shall not be used as the substantive basis, or be solely relied on, for issuing an approval certificate or for the use of any approval mark under this Scheme. An example of such information would be where an Operator has a QMS which encompasses the TMBS and/or associated aspects defined in OTR003: 2001 and is certified to the appropriate ISO9000 standard by an accredited provider.

Chapter six

Assessment and Compliance

6.1 The methods agreed with an Approval Body by different Operators and used to demonstrate compliance with the requirements of the Scheme may vary depending on the nature of the technology and size of the network under consideration.

6.2 The chosen Approval Body will make both the initial and full assessment.

6.3 The initial assessment is an evaluation by the Approval Body with the Operator to discover the scope and construction of the TMBS. It allows the Approval Body to set such requirements for the demonstration of compliance that it considers appropriate, as permitted under Section 24(2) of the Telecommunications Act 1984. These requirements will be defined as an output from the initial assessment.

6.4 Following the initial assessment, compliance with the Standard shall be assessed and monitored by that Approval Body for a sufficient period to enable it to come to an appropriate conclusion as regards approving a TMBS and granting a certificate. Experience has shown that such a period is unlikely to be less than 6 months and more typically extends up to 12 months.

6.5 It follows from Clause 8 of the Standard that any changes (e.g. hardware modifications, changed management processes or software up-grades) to the approved TMBS shall be addressed in accordance with the Operator’s documented change control process. As well as the necessary change management aspects, this will require the Operator to inform their Approval Body of any changes to a TMBS, which may have the potential to affect its continued compliance with the Standard. The Approval Body will acknowledge such changes, assess their effects and inform the Operator of any resulting requirements for continuation of approval. The change control process and associated records will be subject to audit by the Approval Body.

Chapter seven

7.1 Only the Secretary of State for Trade and Industry, Oftel, or other bodies exercising delegated powers (e.g. Approval Bodies appointed under this Scheme) may grant approvals to Operators. In practice Approval Bodies will directly issue approval to an Operator for those aspects of TMBSs for which the Operator is directly responsible.

7.2 Both Operator and Approval Body will advise Oftel that they are beginning the approval process (on a service by service basis) to enable tracking of the Scheme.

7.3 Approval and certification duration can be ascertained from the Approval Body chosen, as the Scheme does not dictate a standard period.

7.4 Re-approval time scales can be obtained from the Approval Body chosen. Typically it is expected that a 12-month cycle will be used.

7.5 In any event the Approval Body granting an approval shall regularly review approved Operators' TMBS(s) to confirm continued compliance (typically by a systematic, often monthly, inspection of measurement results and such other activities as the Approval Body shall deem appropriate to the circumstances).

7.6 The Approval Body shall maintain procedures covering the issue, variation, suspension, or withdrawal of approval and any certification.

7.7 An Approval Body is required by EN 45011 to make an appeal process available.

7.8 The DG Oftel will be responsible for resolving unresolved disputes, which have been considered under an Approval Body’s appeal process. The DG Oftel may consult other Approval Bodies where he considers it appropriate.

7.9 The DG Oftel will be responsible for sanctioning transfers by an Operator between Approval Bodies.

7.10 Operators will be required to inform a new Approval Body of any other Approval Bodies used before and of any categorised non-compliance matters in force.

7.11 Details of Operators holding an approval certificate will be posted on the relevant Approval Body’s web-site. Operators seeking approval are also encouraged to agree to posting of their application by the Approval Body. The web-site of an appointed Approval Body will be accessible via a link from the Oftel web-site.

Transition Period for Approvals under OTR003: 1993

8.1 The DG Oftel will consult with each Operator approved under OTR 003: 1993 to establish an individual migration timetable and plan for gaining approval under the revised Standard OTR003: 2001.

8.3 Associated with the transition arrangements will be a review of the application of the Telecommunication Meters (Approval Fees) (BABT) (Amendment) Order 2001 (SI 2001 / 2606).

Chapter nine

Scheme Review

9.4 An annual metering and billing forum will be held for all interested parties to discuss the operation of the Scheme and identify areas of innovation, difficulty or new development for further consideration. Approval Bodies and Operators may advise agenda items for inclusion in advance to Oftel and it is hoped that a full, frank exchange of information will be forthcoming from all parties. Participants should however be clear that in the interests of continuity and consistency, this forum is not convened to revise and rework the underlying Standard on an annual basis. Attendance will be by invitation.

Categorisation of Observations and Non Compliant Matters

10.1 Areas of concern identified by an Approval Body during the assessment of an Operator's TMBS against OTR003: 2001 may come to light in the form of:

• A Non Compliance - an instance of failure to comply with an established requirement. The nature of the failure and the requirement in question need to be made explicit in documenting non-compliance
• A Discrepancy - an instance of a difference or inconsistency. Often synonymous with Non Compliance
• A Deficiency - An instance of a lack of adequacy in the object of audit for which it is not readily possible to attach a unique clause of a requirement to the problem. An example might be where a Billing system has no facility to detect duplication of records for the same Service Usage. This would be likely to lead eventually to a breach of Table 1 in the Standard, but the absence of a detection facility only causes a problem when such duplication occurs
• An Issue - a point in question. This term can be confusing if taken out of context
• An Observation
• Any other matter.

10.2 These will result in matters being raised, which will be categorised in three categories as described below.

• An important matter preventing the issue or continuance of approval for which corrective action must be undertaken urgently. In view of the grave consequences of a Category 1 matter, it is expected that an Operator will resolve it as a matter of the utmost importance, without need for a maximum resolution period to be specified in this guide
• In any event a detailed corrective action plan must be agreed and put into effect within four months
• As a Category 1 matter has the potential to constitute a licence breach, the DG Oftel reserves the right at his own discretion to provide guidance when a resolution is sought. One resolution would be to amend the scope of approval for a determined period
• Withdrawal of a certificate will only take place after consultation between Oftel, the Approval Body and the approval holder
• All Category 1 matters for an existing approval are to be reported by the Approval Body to the DG Oftel.

• A matter of concern, which features as a condition of approval that is to be resolved within a period, agreed with the Approval Body but not exceeding 24 months
• In any event a detailed corrective action plan must be agreed and put into effect within four months.

• A matter worthy of consideration by the Operator, possibly leading to corrective action, but not of sufficient importance to warrant Category 1 or 2 status
• Observations are an example of this category.

10.3 Re-categorisation

The Approval Body can re-categorise a previously categorised matter, (e.g. a Non Compliance or Deficiency) dependent on the Operator’s response and / or the implementation and progress of his corrective action plan. For example a Category 2 matter that has not been acted upon to the satisfaction of the Approval Body can be raised to Category 1 status. Similarly an accumulation of matters which individually would only warrant Category 3 status might in aggregate be deemed Category 2 or a residual matter from a large Category 2 be reduced to a Category 3.

10.4 Appeals

10.4.1 Operators may appeal against the categorisation of any matter by following the Approval Body's documented Appeal Process (provision of such a process is required by EN 45011).

10.4.2 DG Oftel will be responsible for mediating unresolved disputes, which have been considered under an Approval Body’s Appeal Process.

Chapter eleven

Publications

11.1 Oftel will maintain a web-site containing public documents, information about Approval Bodies, compliant Operators and those seeking approval and links to related sites and other relevant items.

Documents forming part of the Scheme are available in .PDF format from www.oftel.gov.uk

The following documents are downloadable:

This Guide

Oftel Technical Recommendation OTR003: 2001, the Standard.

11.2 Not all documentation will be placed in the public domain, for example Approval Bodies’ proprietary documentation, Operators’ confidential information, confidential records of the Approval Body forum and records relating to comparability review of Approval Bodies.

Chapter twelve

Guidance for the use of OTR 003 : 2001

12.1.1 This Standard has been intentionally drafted to cover a wide range of users and applications. The overriding principle is that customers should be charged neither more nor less for the services they use than is specified in the tariff to which they subscribe.

12.1.2 This guidance explains how the Standard may be interpreted in various situations. The Standard makes use of three major concepts, defined formally in Clause 2:

• Operator
• TMBS
• Chargeable Event.

• demonstrate the accuracy and reliability of his TMBS against defined parameters using an appropriate test, measurement and reporting regime
• operate the TMBS under systematic management processes which will encompass any sub-contractors used
• handle billing Complaints under a systematic management process
• systematically analyse the root causes of errors in Bills that were the subject of upheld Complaint and implement improvements to the TMBS to eliminate such matters
• feed upheld matters into test and measurement programmes.

12.2 Operator

An Operator in the context of the Scheme is an undertaking providing public telecommunications networks or publicly available Telecommunications Services. It includes for example:

• PTOs
• Traditional fixed networks
• Mobile networks
• Cable Operators.

• Other Operators and Service Providers

• Switchless fixed or mobile network resellers
• Those using BT Calls and Access
• Those offering indirect access including Carrier Pre Selection (CPS)
• Those offering personal numbering
• Those offering International Simple Voice Resale (ISVR).

12.3 TMBS

12.3.1 The use of TMBS overcomes the practical difficulties of applying the Standard to current designs of switch and billing systems. It encompasses the totality of all Equipment, procedures and activities used to determine the charges to be applied for service provision and Service Usage, and the presentation of those charges on customers’ Bills.

12.3.2 The term meter means any system or apparatus constructed or adapted for use in ascertaining the extent of Telecommunications Services provided by means of a telecommunications system. It therefore follows that metering includes not only measurement of time, but also logging and counting where charges are determined by the number recorded.

12.3.3 An Operator may be deemed to operate more than one TMBS even if they share common components; for example, mobile network pre-pay and post-pay platforms may share the same switches but be approved as separate TMBSs. The requirements of the Standard can be applied end to end to each TMBS.

12.3.4 A TMBS covers an "end-to-end" process. It begins with the recording of the event being charged. It ends with that event being in a format suitable for inclusion in a Bill, other than for superficial changes for the purpose of presentation only. In testing the end product of the TMBS, it is possible to test:

either

• the data output as Bill-inclusion-ready, excepting presentational changes only, or
• the data as finally presented on the Bill.

This choice exists because it is reasonable to assume that the content of data is unaffected by the superficial presentational changes alluded to. If there is reason to believe that the content of data will be altered by such changes, then these cannot be considered to be of a presentational nature only

12.4 Chargeable Events

12.4.1 The rapid development of new services makes for difficulties in setting requirements for traditional, individual billing items, such as rentals, supplementary services and time related usage charges. Indeed, no Bills are issued for pre-pay services. Instead, the Standard uses the concept of a Chargeable Event, encompassing all items for which the customer will be charged. This allows for the introduction of new services, such as data provision by a per packet charge.

12.4.2 Chargeable Events can be sub-divided into service provision (e.g. rental and supplementary services) and individual, effective items of Service Usage (e.g. telephone calls). Such items are identifiable from records of duration (or count) and time of initiation or completion.

12.4.3 In general, where non-Telecommunications Services or other goods are included on a Bill it is expected that, although not subject to audit under this Scheme, the calculation of the relevant charges and their presentation on a Bill by the Operator will be accurate and will not be detrimental to this approval Scheme by association. Where such charges are directly determined by a customer’s usage of a specific Telecommunications Service, then such a Telecommunications Service shall be deemed to be within the scope of this Scheme, subject to the materiality criteria. An example of this would be dialling a special number, which triggered charges, without further intervention, to the customer’s Bill in respect of the anticipated supply of a non-telecommunications item. The correct charge for calling that special number must appear on the Bill and will be subject to this Scheme.

12.4.4 Similarly, it is expected that third party data in respect of non-Telecommunications services and other goods will be accurately processed by the TMBS and so presented so that it is not detrimental to this approval Scheme by association. As above, there are no audit requirements associated with this Operator responsibility.

12.4.5 For the avoidance of doubt, this Scheme does not concern itself with any aspects of the supply and quality of non-Telecommunications Services or other goods, which are subject to the normal laws concerning the supply of goods and services.

12.4.6 It should be noted that this Scheme is specific to the telecommunications sector as regulated by Oftel. Whilst widening the scope of the Scheme beyond VFSTS it is not intended to extend beyond network services, which are considered to be any of the following:

12.4.7 An appraisal of the factors affecting or effecting accurate Bill generation should be introduced. For Operators currently approved to OTR003: 1993 this will mean additional work to extend existing appraisal to capture Bill event creation other than call event records.

12.4.8 Within the switch environment it is not practical to ensure that all call events correctly create CDRs. However, there are audit tools and control processes that can provide the necessary confidence in this stage of the call generation process. A similar methodology should be used for other types of event generation where it is not practical to perform active reconciliation or measurement.

12.4.9 The appraisal of the processes and systems which generate non-Service Usage (i.e. "non-call") billing events will identify the key controls that will give the necessary confidence for event generation and billing accuracy. The Operator should ensure that system design and manual procedures are developed which will assure the accurate generation and billing of these non-call billing events and agree a compliance reporting structure with the Approval Body.

12.5 Measurement of TMBS Accuracy and Reliability (Clause 3)

12.6 Individual Bill Accuracy (Clause 4)

12.6.1This aspect of the Standard requires the implementation of a quality circle that continually reduces risks to Bill accuracy by causal identification and remedial action.

12.6.2 Operators will be expected to use additional, appropriate safeguards against conspicuously wrong errors being allowed to be included in individual customers’ Bills. For example, a Bill for £10,000 should receive special scrutiny before dispatch if the customer normally receives Bills of the order of £2,000. Approval Bodies are expected to audit such arrangements and form an opinion as to their fitness for purpose. It is expected that Operators will improve such safeguards over time, employing increasing sophistication and narrower capture windows as customer management systems develop.

12.6.3 An Operator’s customer Complaint handling process may remain unchanged but must be subject to documented process control procedures. Upheld billing Complaints include those that have been investigated by Oftel or, in future, by the Telecommunications Ombudsman, as well as those upheld by the Operator. In general an upheld billing Complaint may be considered to be one which has resulted in an adjustment to the customer’s account.

12.6.4 The concept of proportionate remedial action suggests that where only a single customer is affected then only actions arising in normal business practice need be taken, but where multiple accounts are affected then special remedial action should be undertaken. So, for example, changes to manual procedures are readily made, but issues of software change or hardware modification are often better grouped together for implementation. An example of good practice for the steps in dealing with upheld Complaints is contained in Annex D.

12.6.5 It will be incumbent on the Approval Body to ensure that the incoming Complaints handling process operates equitably and that the upheld Complaints process, root cause analysis and the resultant remedial action and recovery programmes are operated in the spirit of the Standard. In assessing these aspects the Approval Body may take account of the Operator’s internal audit and self-appraisal records. The Operator and Approval Body may wish to consider trends in sub-sets of upheld Complaint statistics to check the effectiveness of Due Process in resolution of problems.

12.6.6 Given that the requirement in Clause 4.4 to include affected Bills in a recovery programme arises via upheld billing Complaints, it is most likely to be concerned with refunds or credits to customers. It is not to be misconstrued as a mandatory requirement for undercharged customers to be subsequently billed for any shortfall. In any event the Operator should advise and agree with his Approval Body when he considers it "not practicable" to include Bills in a recovery programme. An example might be where the cost of administering a large number of very small credits is disproportionate and a charitable donation to the total refundable value is made in lieu of individual refunds.

12.7 Timeliness of Post Pay Billing (Clause 5)

CDR	Call Detail Record (also known as Call Data Record)
DG Oftel	Director General of the Office of Telecommunications
DTI	Department of Trade and Industry
EA	European Accreditation Body
OTR	Oftel Technical Requirement
Oftel	Office of Telecommunications
PBX	Private Branch Exchange
PTO	Public Telecommunications Operator
QMS	Quality Management System
SLA	Service Level Agreement
SUS	Service Usage Specification
TMBS	Total Metering and Billing System
ISVR	International Simple Voice Resale
VFSTS	Voice Frequency Switched Telecommunications Services