GPL & OTS Action Plan for Operators

3rd April 2023 is the deadline for Retail and Access Communications Providers to be implementing Gaining Provider-Led Switching and One Touch Switching. Remember, all Switching both Residential and Business must follow the GPL General Conditions. And all Residential Switching must use the One Touch Switching Hub.

In addition to our plan below, TOTSCo have created a high-level milestones plan and detailed OTS Checklist to  "Get Ready for OTS". You should review that plan as well  as check the below.

  1. Appoint your GPL / OTS senior lead (Board level or reporting to Board)
    1. ​Register them here with INCA and here with TOTSCo.
  2. Senior Lead should identify those responsible for business areas impacted by GPL / OTS (the "GPL Team")
    1. ​Regulatory / Compliance (Ofcom GCs, Code of Conduct)
    2. Legal (Contracts with customers, access providers, relevant suppliers)
    3. Network provision (is your ACP vertically integrated, shared with other RCPs, outsourced wholesale platform or a mix?)
      1. ​Will your ACP(s) support GPL / OTS or are you on your own?
      2. Will joining an OTS-compliant ACP / wholesale platform be better than developing your own systems?
    4. Customer Journey (Sales process, sign-up, onboarding, support, service cease)
      1. ​Is this a single team? In-house or outsourced?
      2. How do you train your customer contact function?
    5. Service ​Commissioning / De-commissioning (connection installation, CPE/ONT despatch, provisioning)
    6. ​Marketing (customer recruitment collateral, website, customer comms for onboarding, lifecycle, "STSYG")
    7. IT, OSS / BSS (CRM, order processing, customer & service provisioning)
      1. Integration with external systems (TPI, OTS Hub, ACPs)
      2. ​​including generating the correct "SI" (Switching Information) whether Gaining or Losing
    8. ​Finance (budget for necessary changes, TOTSCo charges, IT development, training, resource)
  3. Senior Lead must draw up your organization's GPL / OTS Action Plan
    1. ​allocate tasks / briefs to the GPL Team
    2. get individual, time-scaled Action Plans from each of the identified business areas
    3. you will need to decide if you will integrate with OTS Hub directly or via a new / existing ACP
  4. Senior Lead and GPL Team must familiarise themselves with the new Ofcom General Conditions which take effect 3rd April 2023
    1. in particular, GC C7 which governs GPL & OTS.
  5. Review Customer Journey / OSS/BSS against TOTSCo's OTS Industry Process Design to identify changes needed.
    1. keep abreast of future versions as issued by TOTSCo.
    2. ensure your IT / OSS / BSS, systems supplier have read this also
    3. while not part of GPL / OTS, check your onboarding / lifecycle is compliant to identify vulnerable customers and those qualifying for your social tariff - as required by Ofcom GCs
  6. ​Review your Technical & Systems Development requirements against TOTSCo's Developers' Guide & Technical Guide.
  7. Review the "constituencies" which make up TOTSCo
    1. ​(Large, Medium, Small Retailers, Business Retailer, New Infrastructure Provider)
    2. Decide which one your organization fits
    3. Identify your constituency's Director and engage with them
    4. Decide if you want to be a Member (can vote for Director) or User (can't vote)
    5. Decide which (if any) Working Groups you can support / engage with
  8. Create your Implementation Action Plan for required changes (GPL Team)
    1. with actions and timescales for
      1. planning
      2. development
      3. training
      4. testing
      5. implementation
    2. publish the Plan to those affected in-house and outsourced
    3. ​review progress regularly
  9. Document your Action Plan and Implement Action Plans so you can evidence you’ve been proactive (if needed)

Operator categories used in designing One Touch Switching documentation and process design:

  • Retail CPs: RCP, GRCP (gaining), LRCP (losing)
    • operators who retail Internet Access Services - i.e. broadband
  • Access CPs: ACP, GACP, LACP
    • operators who operate access networks which are used by RCPs
  • Voice CPs: VCP, GVCP, LVCP.
    • operators who retail a Number-Based International Communications Service - i.e. voice with a number (POTS or VOIP)

Vertically Integrated operators are considered to have responsibilities as RCP and as ACP and are expected to fulfil both.

Some ACPs are Wholesale only, some are Wholesale as well as serving their integrated RCP and some only serve their integrated RCP.