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Date

23 May 2022

Antitrust Policy

Attendees

• Sean Bohan (openIDL)
• Joan Zerkovich (AAIS)
• Ken Sayers (AAIS)
• Eric Lowe (VA)
• Nathan Southern (openIDL)
• Jeff Braswell (openIDL)_
• Satish Kasala (The Hartford)
• David Reale (Travelers)
• Brian Hoffman (Travelers)
• Greg Williams (AAIS)
• Peter Antley (AAIS)
• Rajesh Sanjeevi (Chainyard)

Agenda:

1. Architecture WG Harmonized Data Store Task Force

• Host: Peter Antley, AAIS (for now)
• Tuesdays 9am (for now)
• Invites to go out (contact sbohan@linuxfoundation.org )

1. openIDL - Architecture - Member Requirements Files
2. Regulatory Reporting Requirements from Dale H (Travelers)
3. Requirements Table

Action items

Notes: 

• JeffB
• DaleH's document
• great input on aspects of arch requirements
• High level way of looking at the work that might be going forward
• Trad process: network stack, 1 party talking to another at different levels
• division between parties
• division between horizons (business and data)
• below the line - infrastructure implementing this
• definitions and stipulations (matrix)
• looking at requirements on the contributing side
• carrier node
• influence, impact on lower levels
• take a look, great contribution
• when Dale discussed last week, concept of granting consent to a data call
• orchestrated workflow transactions
• might be over the course of days
• data call req announced, on carrier side can it be provided, consent, other data? in aggregate not just one carriers business dominating the data
• business orchestration transacting at app level
• impact on how we implement in fabric
• good example, kind of req that will impact arch
• making sure on this call, work contributed
• KenS
• worth going thru it
• give folks a sense of what was contributed, see the value of it, restate what is not clear
• can walk thru it
• Dale - organized it - what are the diff things that need to happen for stat reporting on openIDL
• Reading column D
• D4
• DavidR - transactions will be determined by source system
• any changes to this source will be reflected in HDS
• Ken - can we clarify it? 
• Satish - are we saying HDS will maintain time series on the policy AND the claim?
• Ken - yes, changes as they happen based on what source system says
• diff - if there is an error moving from source system to HDS, will not correct errors will replace (no onset-offset)
• Satish - only incremental or delta change?
• Ken - cant do snapshots, don't know what time period request is asked for
• need history as unfolded
• Satish - snapshot - point in time of a policy, if you take a point in time copy of the policy at 3pm on 5/23, take a copy of that same policy tomorrow there could be changes in between, question - are we capturing just changes or complete copy
• Jeff - data submitted in format of the data standard reqs, would reflect things that have and haven't changed - record format
• Ken -snapshot on pull, source data must have every possible snapshot, doesn't keep at snapshot
• David - HDS will be accurate rep of source systems in correct format at any time
• not incremental
• will look at entirety of period of relevance
• David - req captures that "these will be the records"
• Ken - policy and loss transactions
• D5 - data freshness
• D6 - 5 prior years + current in HDS
• Peter - strawman - need a decision on how long we retain data
• Ken
• D7 - data in the HDS will remain within 5% error tolerance per line and state based on openIDL edit package
• what? Data requested, data loaded? do we need to reevaluate every time we load data?
• Peter - would like someone to correct - NAIC handbook talking annual reporting
• Ken - constraining ourselves to annual reporting
• Jeff - mark for clarification from dale
• Brian - 5% consistent with AAIS stat plan
• Ken - we do it on load, 
• Peter - individual load
• Ken - unclear of math / thresholds
• Jeff - biz requirement for arch
• D8 - access is permissioned
• Jeff - diff categories
• David - what Dale wants, any new use is consented to on a use by use basis
• if there for stat reporting, data not accessible without specific approval
• Ken
• permission on extraction
• David - you could be permissioned party for one use (annual report) not permissioned to pull data for another purposed - granular permission based on use
• Ken - use = extraction
• ask for another extraction
• Jeff - for the staged data, in extract data - single defined use - once you have the data cant use for another purpose (Column F ROW 2)
• David - nuance - cant extract data, you can only use for cert purpose - yes - use must be approved
• Satish - internal access? d0 we need to worry about internal access, from a carrier standpoint
• if you put data into HDS - can we see who put data into HDS from carrier standpoint
• Jeff - carrier would approve requests
• Ken - out of openIDL's hands - you own HDS< you control however you want
• David - HDS is carrier-owned asset they do with as they see fit
• Ken 
• E2 - DATA shall be aggregated during extraction, E3 anonymized
• these two cells are related
• should we change from during?
• aggregated ON analytics node
• Jeff - not every detailed record supplied, some form as part of extraction query
• David - instead of on extraction - raw data doesn't leave carrier node in its raw form
• maybe cleaner to write - raw data doesn't leave carrier node
• Satish - original intent of request data, add requirements: consent, when, time period valid
• data shall be aggregated should be moved to extract
• David - columns are confusing stuff
• Ken - ignore columns for now
• David - raw data (no extraction pattern that pulls all data out)
• Carrier node to analytics node
• Ken
• E3 - anonymization happens on analytics node
• Jeff - does this also mean some of it does get transmitted for specific policies without unique identifiers
• David - where this goes - defining how specific extract patterns might behave
• don't want a lump travelers dataset sitting on analytics node indefinitely
• if pulled for purpose - would like to occur immediately, not stored as Travelers data in perpetuity
• Ken - carrier is the identifier
• Satish - not about PII but just carrier
• data source shall be anonymized
• David - PII should not be stored, etc. 
• Eric - one of the things, having DL #s in HDS, VA wont get it but if not in the store - other things for useful research doesn't happen
• PII in and of itself
• Ken - DURING extraction
• Eric - not give me permission to get it
• confusing data request from smart contract that gives me permission 
• Satish - clarification
• anonymized
• do we ever need to know from RR standpoint that this data is from Hartford, Travelers?
• Eric - either a data call or building HDS and go into other areas, if I call a market conduct of Hartford for this year send me all your info on your policies, you may pull from HDS
• smart contract negotiated - here is the data you have permission to pull it in this form
• option there going forward
• not limiting to what we see today but could happen in the future
• Jeff - stat report does not need to ID, in aggregate
• Eric - now stat rep, could be used for other reporting requirements, devil in this detail is the extraction
• David - lot of reqs driven by extraction pattern
• is EP says "combine x carriers by y carriers" will be stored that way
• specific use cases will define that
• concerned - storage of data will be determined by extraction pattern terms
• Eric - right now only for member companies, and right now AAIS gets it not totally anonymized
• you don't give me who carrier is, but AAIS has defined business need
• Jeff - combined at service but not available or reported
• Eric - AAIS not get or not reported (have it not reported)
• David - making sure data used for what it was requested for
• Eric -c ant envision every use case but if we have raw data and extraction patterns, no free reign for me (or other regulations)
• David - if intended data call says "all data aggregated with other carriers, noting from AAIS 
• would have to approve at the time
• Eric - group needs to figure out min # of carriers to prevent regulators from de-identify who submitted it
• Ken - E4 - only aggregated and anonymous shall move past analytics node
• E5 no PII data transmitted beyond private analytics node
• Satish - do we ever need PII data published in stat reporting?
• other reporting?
• BrianH - not as part of stat reporting
• Satish - other data calls?
• Jeff - don't need actual PII
• David - one of the cores - if there is every a use case requiring PII, would want connection to be made prior to transfer out
• major benefits of this topology
• doesn't leave carrier node
• GDPR, CCPA makes it messy if it ever leaves
• Ken - didn't quite match 
• could leave the carrier and be used for reporting but it never leaves analytics node
• David - major Arch req, in former design had to, this winter thought maybe we move it into the carrier node
• imp requirement - where is that line
• Jeff - req still stands
• not analytics node and not carrier
• Satish - example - age range of drive, sometimes requested, individual elements like date range - is that PII
• David - fact aggregated would obscure identifying things
• game is messy to play
• Ken - how do we from openIDL perspective meet this req
• Carriers not framework
• David - messy, say there is a req to put some sort of info considered PII in HDS, obfuscated and de-identified by extraction pattern, would set rule EP do not hold PII - nonfunctional req, needs to exist
• based on some use cases, will be necessity
• thinking
• Satish - in some cases, one of more PII elements, even if not contribute to constructing full ID of a person
• Jeff - what constitutes PII?
• David - safeguard req - PII doesn't leave carrier node (for now)
• Jeff - simplest approach
• most systems have the audit trail for this kind of data, don't want to create compliance problems
• David - ideally, don't wand PII in HDS to begin with, some abstraction preferable
• Travelers haven't considered all components of PII in HDS
• E6 - timeframes for aggregation need to be defined (when recorded, when extracted,)
• Jeff - full month?
• Ken - could be a day - need to know when
• Satish - start and end data mandatory as part of extraction pattern?
• Ken - are they all?
• David - getting into new realm of reqs here about extraction pattern requirements
• maybe higher level - extraction patterns shall have relevant parameters clearly defined - point to extract pattern document
• own thing, decouple EP reqs from overall requirements
• Jeff - int in active policies, but may reach back to prior years
• Ken - data calls tell you what you are asking for
• David - defined as its own document
• this should point to that
• E7 attributes used in aggregation shall be identified
• E8 logic for extracting data shall be defined
• E9 Calculations to be used for aggregation, analysis, reporting shall be defined
• E10 Specific use of info shall be defined
• Ken - when you create data call - what and why you want data
• David - define requirements of a data call (inc reason for it)
• reason sep - VERY granular - as to what those requirements could be
• data, retention policies, could get long
• concerned about data call and the EP is the implementation of data call reqs
• E11 permitted accessors to the info and users of the data shall be defined
• Ken - is there anything technical we expect to do to constrain
• Satish - do we need governance "I will used this data for this purpose"
• David - might be tech or governance - hold as req and progress which one it is
• Satish - part of the color coding?
• Ken part of the data call
• E12 proportion of carrier info to be used
• Ken - thing that kicked off what Jeff mentioned
• "I consented to it" but if you don't get 3 other carriers I don't consent
• if then - 2 phase
• David - starting to get into actual contracts and agreements
• language that needs to be agreed upon
• "use of the data shall conform to agreements"
• don't know the form of these things
• Brian - guess on Dales part
• bit of a swag estimate (25%)
• Ken put a place where you can say "this call i cant do x $"
• if you cant meet it, cancel the call
• Jeff - how would the arch come up with that answer
• David - messy part, smart contracts can do on the fly, most will be parsing of every call in language
• looking for req - the use and retention and access of all this data shall conform to the terms and conditions of this data call
• go back once arch more formalized "do it the way you promised"
• Ken - written down - spidey sense
• Jeff - not a smart contract, synchronous transact, 
• may take longer to decide if some things can be consented to
• David - smart contract is short hand in my mind for extraction pattern
• E12 - only auth approvers may commit to a carrier data request
• ken - for all carriers?
• David - there needs to be granular permissions for different functions on the platform
• dont know all those tasks or user types
• need ability to have granular permissions
• Satish - is this openIDL or carrier can implement they way they feel
• David - openIDL side on the adapter at the least
• Ken - interacting with UI and credential, cred associated with roles, when you define creds in openIDL have to roles and perms
• Satish - should extend into HDS?
• Ken - federated
• David
• Ken takeaway
• connect and document the flow of a data call maps to things moving around to clarify
• David - nice if some docs uploaded, NAIC docs  - nice if those could be parsed out as requirements

Recording: