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Grouping

ID

Date

Requirement

Notes

Data and Data Integrity

D.1

5/23/22

Data contained in the carrier data store will conform to OpenIDL data model standards


Data and Data Integrity

D.2

6/1/22

OpenIDL data model standards shall exist for all Property & Casualty lines of business except Workers Compensation (List out lines of business). Domestic business for now. 


Data and Data Integrity

D.3

5/23/22

Minimal data attributes to be available in carrier data store shall consist of the "Day 1" OpenIDL data model fields, other attributes in the OpenIDL data model are populated at the option of the carrier


Data and Data Integrity

D.4

5/23/22

Data shall consist of policy and loss transactions over the course of the policy term and lifetime of any associated claims based on source system activity


Data and Data Integrity

D.5

5/23/22

Data shall be current to the Prior Month + 45 days


Data and Data Integrity

D.6

5/23/22

Companies shall maintain data in the carrier data store for 5 prior years plus current year


Data and Data Integrity

D.7

6/1/22

All data contained in the carrier data store is soley owned and controlled by that carrier 


Data and Data Integrity

D.8

6/1/22

Data shall remain accurate as of a point in time and may be corrected over time if errors in the transmission of data occurs with no obligation to restate prior uses of the data. Once data leaves the carrier node, that data is assumed to be published/accepted.


Data and Data Integrity

D.9

6/1/22

OpenIDL shall maintain (specification and implementation) an edit package to be available and used by carriers to test conformance to data model standards and data point interactions similar to the functioning of the AAIS SDMA portal. Implementation is part of HDS solution. OpenIDL will audit, certify and conformance of edit package implementation.


Data and Data Integrity

D.10

5/23/22

Data must pass through OpenIDL edit package and be within 5% error tolerance per line and state based similarly to acceptance by AAIS through SDMA portal


Data and Data Integrity

D.11

6/1/22

The OpenIDL data model standards will foster effective and efficient data extractions such that queries of data can be satisfied within 24 hours of commitment to participate in an information request  


Data and Data Integrity

D.12

6/1/22

Any changes NAIC required fields to the OpenIDL data model will require a minimum of 18 months notice for carriers to conform 


Information Requests

IR.1

6/1/22

Requests for information shall be specific in detail and communicated through a secured protocol


Information Requests

IR.2

6/1/22

Forum shall be established for carriers and regulators to discuss and agree to intent and interpretation of information request


Information Requests

IR.3

6/1/22

Request for information shall  be for aggregated information only, no individual policy, claim, or personally identified information shall be requested or honored

Need for info @ a policy level or vehicle, obfuscation of VIN

ways these requests are added to or validated?

KS: exceptions known when extrax is requested

JB: at policy level, info from policies CANT be extracted (they might be useful) or some level of aggregation. Data contributed from each carrier to prevent identification

DH: requests - none ask for policy or claim info up until today
JB: VIN & Insurance? Not just carrier only restrictions, address requirements across ecosystem

DH: straight to regulator? fine w/ providing info. Analytics node others have access to and can pull? NO

JB: only regulators would have access to information

DH: person or group making reports for reg? Concerned. Controls so they cant do anything with data

DR: blurring lines from compliance-style store to transaction processing, requires higher standards, conflating 2 systems, holding to other standard can make a lot of reqs messy

JB: not matter of timeliness or responsiveness, matter of scope and level of aggregation, level by which info is agg or identified, only collected for purpose of sending to regulator, covenants needed

DR: purely a regulator - not LE or Insurance Commissioners. Caveat - not bulk. PII should never be requested in Bulk. If a specific question, then yay/nay "coverage exists" but leery of "give me all VINs" just because

DH: dont want to open up our books

JB: PII in general not involved. ND is VIN not necessarily person involved. 
DR - policy effective date, VIN and address enough to correlate. Still protected by aggregation rules DH mentioned. 100k VINs "is someone in the state covered" not WHO. 

JB - another requirement applies to Data Requests

Information Requests

IR.4

6/1/22

information requests shall identify who has access to the private analytics node result data and interim data (anything coming out of the HDS)

DH - not naming people, data within the node. For specific info request

KS: To the analytics node or to the specific report? Doesn't change from request to request. Dont add new user to analytics node

DH: req from Reg, no interim body in between, just us and Reg have access to data. If AAIS has access to openIDL, and create extraction pattern, need to understand WHICH bodies will have access to that data - needs to be spelled out. Get to 3rd party: AAIS + Carpe Diem, wants to know ahead of time

JB: access to the data, the results, the report

DH: access to the data AND the report, outside of carrier node

KS: aggregated, extracted data

DH: Carrier, claim, policy, PII - I need to know who has access to it

KS: anything you say is OK to be in the results, you want to know who

JB - qual and credentialing

DR: need for simple data lifecycle, provenance. For this request, this all lives in the extraction request, for this request - this raw data - the result shall be X and visible to Y folks for Duration Z. No unfettered access to HDS, only with some purpose. Even analuytics node shoulfn't be used for other purposes without consent

KS: Definition of what data shoulf be used for 

JB: Categories: privileged, etc.

DR: a lot may not be funct. but when we get to approval of extraction patterns, might be more implementation

JB - term sheet of a request

DR - adapters can see these X raw elements, can turn them into Z elements for ABC. Routine if useing same data, but shouldf be explicit

KS: Nuance, part info request and part how it works. Who can see uncombined data should be part of system architecture. Refined results are what we are talking about. 
DR: System works well, only see results. Flaws, mistakes, exploits - what data at risk. Sanity check - looking at result data and asking for 20 fields of raw and only using 10, then spiking that request

KS: When a carrier consents their data is run thru extrax, their data is recognizable UNTIL it is processed

DR: 3 steps: RAW, Semi-Agg/not anonymized, Anonymized. Bake in now

Information Requests

IR.5

5/23/22

Information requests shall define timeframes for data to be included in the aggregation

JB: talkkng about lifetime use of info - historical or one purpose, number of uses, number of purposes

DH: when you make a req for info, request must be specific (time parameters, types, etc.) for the request of the data - query range


Information Requests

IR.6

5/23/22

Information requests shall define the attributes to be used in aggregation

JB: Nature of the data call request?

KS: shoudl be redundant - dont see people reading code

JB: query, results in aggregated things, 2 parts of a request-report. Req will identify the things selected and need to be accessed. If you did this via Wizard or screen, those criteria included at that level. Translated into extraction

KS: least big declarATIVE IS A HEAVY LIFT. Not sure short term target, right now map-reduce function

Peter - attaching meta data to the calls, human readable - will need that clarity

JB - not talking NLP, but request-translated-terms/types requested and accessed in raw data. 

KS: whats going over the wire a result of an agg routine. Will return written premium by x and y. 

DR: acceptance criteria - request, tells us XYZ, approve/reject - some plan lang explanation of what is being asked for. REG: these premiums these lines - should come out in the aggregate. Who writes the query? Analytics node? REGs? Here is what the output looks like, whats needed to gen output. Prob run test execution, these elements were accessed, accepted. 
KS: Added ability to test as a requirement

DH: also want to know if there is extraneous data requested thats a backwards way to get some data

PA: not quite sure what actor will write Extrax Pattern, will be run on certain analutivcs node, who owns that query

JB: if in fact, aggregating total premiums per zip, other criteria involved wouldn't show up in req. If you asked "give me total premium on house on Main street" - different thing. Providing info in aggregate 

JM: solutioning - req is clear, if you use elements, tell me what you want to use

DR: needs to be a req

JM: might be hard, implementation

JB - nature of query will specificy types of data

JM - by def, person capable of reading code will be able to answer question. Must be operable by human beings

PA: I will write an Extrax pattern to calc premium on X. Who will come in and validate that query is doing what it is supposed to be doing?
JM: risk someone chooses elements does something wrong. 

DR: solution prob for how to verify, on us to solution for, need to know what was supposed to be requested

PA: person running Analytics node needs to validate

JB: query request, what you can request, minimal set to expand, translates to extraction logic

DR: someone writing query should be responsible, result A and Inputs B - need to be able to verify only B was touched and ONLY A came out. what data pulled for what end - must be defined - shoudl be trivial for whoever is writing the query

JB - specificying the things the query is for and validating thats what it does

JM - saying you can block someone AND block/report. "I reject this request" vs "You said you needed 5 things and we see you requested 7 so..."

JB specifying what it is intended to do is a starting point

DR - then governance

JB - glossary

DR - not thousands of elements



Information Requests

IR.7

5/23/22

Information requests shall define the logic for extracting and aggregating data

DR: interpretation - doesn't need to be pseudocode level or extremely details but has some detail

JB - business justification request?

DH/JM - yes

JB - specifies purpose, what elements, who its for, how done - human understandable

JM - will be metadata page, very descriptive, processable by humans

JB - logical request

KS - human TRANSLATABLE (understandable)


Information Requests

IR.8

5/23/22

Information requests shall identify and define the calculations to be used in aggregations, analysis, and reporting

JB - similar to logic. Combine with IR.7

Information Requests

IR.9

5/23/22

Information requests shall define the specific use of the information

JB - use and access - REG only, single use?

JM - who in the sense of roles not names, will know what they want to do with it. Privacy +. Different than "WHO". 

KS - restriction/constraint. If you say you use it for that, thats all you can use it for. 

JB "specific purpose and not other things" - like licensing

JM - commercial vs personal all the time.

Information Requests

IR.10

6/1/22

Information requests shall define the permitted accessors to the information and users of data

JB: the WHO. Use declarative, WHO is a restriction

JM - redundant with IR.4

DH - who has access to final report

JB - other was access in transit. RELATED to IR.4. 

JM - lifecycle flow - who has access throughout

DR - implementation has that data in the same place, doesn't hurt to be explict with requirement

JB - tempted - come up with a draft of template of a term sheet for this

DR - few weeks ago - definition of that request template.

DH: beyond the smart contract - business level

Information Requests

IR.11

5/23/22

Information requests shall communicate the proportion of individual carrier information to the population of data in the extraction prior to final commitment to participate

JB - keep carriers protected from self-detection. Data can't be deidentified. Provided to each contributor. 
DH: Travelers is 25% of a pop, can decide if they want to be a part of it or not

JB - only know when you have the total

DR - requirement: maximum acceptable, sep req that says "no darta will be pulled or aggregated UNLESS it can be confirmed. Might have to do pseudo-extraction to get a rough size. 

JB - consent to request, what it is asking , data is contrib to the analytics node as "pending" but not approved for use until such time there is sufficient data to let the node say what the totals were

DR - maybe do with a lighter weight. Shallow (25% of WHAT)

JB - general metrics, so many policies outstanding

JM - language of "prior to final committment to participate"

DH - two step - what portion you will have (query all avail carriers, who will participate) then when there is a sense of what % of the total WILL we participate. Others face same thing

KS - time problem - bartering back and forth

JM - regardless of how we do it, data wont be seen until we meet the threshhold. We won't see data unless X%. Multi-stage scares me a lot. 

DR - once extracted have we lost control? Governance. In Analytics node. Lost effective technical control. Def recourse. Affirmative tech control is lost. 

Jm - governance level requirement. Whole solution requires not release data w/o reaching threshold. You pull one carrier then ouch

KS - micro-req - define participation threshold - then argue governance

DH - 2-step process, another requirement below, set at 15%?

KS - % of what? premium, loss?
DH - depends on whats being asked for

KS - reports just dont tell one thing, define that and then deal

JB - requires more thought

IMPORTANT ONE

Information Requests

IR.12

5/23/22

Information requests shall be for one time use only.  Additional uses for data will require a new request. 

JB - licensign of its use, one use, baseline, mayube beyond 1-time use. Use can be controlled or specified

JM - what if you know something is 1/4 or annual. Each submitted as a sep request

DH - 1 req per year or some timeframe sufficient

PA - some indication - has your org approved before? changed year to year?

JM - grand vision - if you did have something monthly, set as monthly recurring, could be useful

DH - specific req recurring, do it on a time period - this month X next month similar but not the same. Dont want scoppe of any req expanded beyond what was agreed to
DR - capability

JM - RECURRING important but maybe out of scope for now

JB - data not being used without consent, without apprvoal, who is using it

Information Requests

IR.13

6/1/22

Information requests shall identify the path information will flow from its raw form through final reporting  (e.g. carrier data store to private analytics node to Multi-Carrier aggregation node to Regulator)

PA - path: REG makes request, to analytics node, ANode requests data

DH - clear where info is flowing, no side trips the data goes to, not aware of as carrier

TE - openIDL will deploy everything from point you say OK, Data calls - fields that define purpose
DR - leave mongo, go to adapter, then aggregated then ANode, combined/anon, 

TE - combined and anonymized, presumptive
owner of ANode, has channels with each reporitng carrier, as each consents will be looking at pile of data from each carrier who said yes
KS - 2 things, one what system sis set to do archtirecturally, then what is in the agreement of the call (consent?)

TE - reqs on openIDL now, on reqs on carrier's perspective, on the ANode now, reqs for openIDL operating the analytics node for phase 2 obligations, committed to "what we do with data we got"

DR - contracts are the data calls themselves

TE -real world contracts

DR - blanket TOS, defines things like SLAs and counterparties

TE - carriers and openIDL

DR - can't imagine no TOS 

JZ - w/in openIDL there will be SLA for stat reporting

TE - SLA as part of the network, openIDL needs to become an agent

DR - same verbiage can hit both reqs

DH - concerned with deviating from normal path

BH - data leaves company, knwo what it is going to do/go to

PA - consider running ANode will be offering TOS
DR - if implementation doesnt hit these, make sure - imp to be explicit

JB

Information Requests

IR.14

6/1/22

Information requests shall identify the form information will flow from its raw form through final reportings (raw data; carrier summarized aggregated and anonymized data; reported data)

JB - similar to prev, relates to spec on anonymization, agg vs anon, abstrat detail identifiable. Text is one thing, code is another, some way to formalize/codify nature of call, what being requested, identifies things other than narrative statement (nature of req), analysis of metadata interface

DH - one is path this is form

KS - how much in the prose vs Extract Pattern, EP has gory details. When filling in req, fields req/fields output? right now data call, fill out, explain what trying, that form extended for deeper info - these are the items req, agg will happen, etc.?

JB - this req indicates

KS - loose prose and no form? 

PA - structured stuff, table to fill out

KS - asking struct questions, all the things you have to ask

JB - design, how to design metadata

DH - may not be part of initial, will be part of final ask before final approval is provided

KS - get the gist but before I approve this tell me why/what fields

DH - person doing extract pattern would be able to

JB - could be done in some form of survey of a page (heres what i want, looking for, data-specific not necc technical). anyone implementing call will need to know exactly what regulator wants anyway

Information Requests

IR.15

5/23/22

Information requests have an expiration date and time from which consent is needed, if applicable

DH - deadline for responding, no response = no (comes up later down pg)
KS - have to know who was able to respond and interact with other req, what % of the result is travelers, etc. If 20 people say they will respond and only 4 do and travelers is more than 25%

(addressed above)

JB - what is the time bracket, time bracket use of info. Basis of analyzing when new reqs made - can I do this? when can I do this? If I do this when? Stages of Consent (not single date/time)

PA - defining what % of the data you are submitting - raw #s? amount of cars? % total records?

DH - % of whatever is being requested

PA - explicit

JB - # of diff ways, not fully detailed

PA - by carrier, etc.

Information Requests

IR.16

6/1/22

All requests for information, its approval, the disposition of data from its raw form through final reporting shall be tracked, recorded and archived within OpenIDL

PA - where tracked and recorded? Private channels between carrier and analytiucs nodes? on chain?

KS - everything on-chain except raw data, every interaction, consent, etc.

PA - Eric in VA, makes data call for auto stuff

KS - eric creates data call, goes on ledger, uses UI, fills out form, data call on ledger, as diff orgs interact with that (like/dislike) recorded on ledger

PA - how will ind carriers know % of their data vs total data on a data call?

KS - TBD

TE - captured, outside of this goup

KS - extract pattern put into data call on the ledger, json file with map-reduce, consents registered and stored with the data call

PA - actors consenting or not: KS: Carriers
KS - they will have logins to the UI based on permissions, have people able to act on their behalf

PA sign in? JB Alerts and pushes. 


NEEDS BREAKDOWN OF REQUEST TYPES


Information Requests

IR.17

5/23/22

Carriers who participate in information requests shall receive a copy of the final information presented as well as their individual carrier results

PA - receipt + copy of the full payload

DH - whatever is shared with ANYONE I want a copy 

JB - inc Regulator?

DH - anonymized, should be able to see the whole thing, concerned about 25%, wants to see their OWN results

JB - every call? clear the benefit of anon agg data is benefit to carriers AND regs

PA - using openIDL creating any calls that would be bad for DH to see the whole pic

DH - aggregated data only, not detail

JZ - can't anticipate all, from beginning, agg data is made avail to carriers, state reports are public info, fund principals, value to carriers and they get to see reports. Can have Robin weigh in, everyone needs to know when states get info, one of the reasons why they use stat reporters in past, anything that goes to state entity can be given to anyone who requests. NOT private enterprise when discussing stat reporting

JB - how would that data be returned

JZ - data thru channel to analytics node where anonymized

TE - goal, from arch, make it so each. node can be a data owner node and analytics node so that transactions can be chained together. Chain req together from data source to delivery. Look at arch as an actors:data owner/info receiver/network governance. Can resp to EP, stat reporting network, agg data in analytics node needs to look at that like another data set. Anon-Agg-Test for final delivery (our of visibility of regulator). Should automate AAIS role, so timeliness much faster, so EP happens, is transparent, give the Regs. 

JB sharing of anon/agg data, one place could be shared is the PDC of the common channel

TE - which common channel? NOW - default channel and peer to peer channels. Idea - one default channel (openIDL) or another one (other networks). Default channel cant be everything to everyone unless super lightweight. 

JB - means for returing info to submitters and dedicated channel for that purpose (better in openIDL) - not the default channel (used for comms) but some channel dedicated for returning results

TE - stat agent, executing rules for annuyal stat report for ea state, combined data doesnt have value for submitting carriers today. How do we give more value back not just info reported and compliant acc rules, but all this data that could be used by the states (loss valuation, etc) should be best data product avail (benchmarking, trends in market, etc.). Giving data back to that reporting member. Carrier could have own analyutics node, have own EP that dug into field x


Information Requests

IR.18

6/1/22

Carriers decide in which information requests they will participate

JB - given with the disc around consent, summary of reqs
DH - up to the carriers to participate OR assumed to participate

Information Requests

IR.19

6/1/22

Carriers must provide an affirmative response prior to any information being extracted to the private analytics mode

JB - along with IR.18 (consent on record)

Information Requests

IR.20

5/23/22

Final reports shall be archived by OpenIDL for 3 years

JB - network of communication and collab, who is doing archiving (analytic node? carriers have their copy? cloud archive?) - identify is every member responsible for their own archiving. openIDL is the network.

DH do we need a data center?

PA - archive means a place for archiving

JB - ID how accomplished, more than one requester of info, what is a final report, mult requestors, people providing info to diff requestors, one of the issues - is private data collection used for things in transit, complexity

DH - is openIDL just a network or is it also an intermediary?

JB - resp for maintaining, monitoring is this something that becomes a cost factor, if it is archived does it need to be accessible? cheaper ways to do that if not on chain all the time. Need to look at who might provide archival process. Role question.

SB - risk and liability?

JB - if archiving is of interest, each. node archived each org could do that -WHY? what reasons for archiving. Needs more detail

JZ - diff conversation, idea of archiving beyond scope of openIDL, behind carriers holding data, disppears after the fact and hash - outside of scope of RR 

JB - outside of initial scope

PA - three years after time generated 

DH - published


Information RequestsIR.21

6/13/22

Information requests should be testable.  Should be able to execute a dry run and know exactly what would be returned if the data call executed

JB - seem to occur anyway if you have something to be run to begin with, ought to be able to do it in HDS and test

PA - setting up testnet for us to und cost to op network - talk about a POC HDS or generic HDS, test environment?

JB - intent of this item, a per req basis, request should be testable - talking about if you do get a data call or info request, test locally to see if it runs - looking for test facility for data calls and extracts? or verify executable?

DH - didn't add it

KS - consent to something, need to know what you will return before you consent

PA - dev/UAT/Prod looking to maintain in openIDL?

JB - sep subject - know what you return on a req by req basis

KS - fits a prev req - see just what they are returning, a dry run


Information RequestsIR.226/21/22NOTIFICATIONS: Carriers, Regulators: New Data Calls, Consents, etc. (*TBD)

what groups of actors would receive them, approve vs evaluate
push-pull subscribe

will generate more reqs

Access and Security

AS.1

5/23/22

Carrier's raw data will be "walled off" from other entities with access only through permissioned protocols


Access and Security

AS.2

6/1/22

Carriers raw data shall not leave its control - a secured limited access "private analytics node" may be established for processing information requests


Access and Security

AS.3

6/1/22

If multiple information requests are being processed at the same time, separate "private analytics nodes" with separate access shall be employed


Access and Security

AS.4

6/1/22

If multiple information requests are being processed at the same time, the data for each request will be segregated


Access and Security

AS.5

6/1/22

Carrier data may be transmitted to a private analytics node only as the result of an approved data request via a permissioned access protocol


Access and Security

AS.6

5/23/22

Carrier data may be transmitted to a private analystics node that has been aggregated and anonymizated through a secured protocol


Access and Security

AS.7

6/1/22

Carrier data in the private analytics node shall only be used for the purposes for which permissioned access has been granted


Access and Security

AS.8

6/1/22

Carrier data in the private analystics node shall be immediately purged upon completion of the processing for which permissioned access was granted


Access and Security

AS.9

5/23/22

No Personally identifiable information (PII) data shall be transmitted 


Access and Security

AS.10

5/23/22

No altering or embellishing data including appending outside data is permitted throughout the processing of the information request unless approved by carrier


Access and Security

AS.11

5/23/22

No changes to request, attributes used, extraction patterns, accessors, users, or specific use of the data is permitted post consent


Access and Security

AS.12

5/23/22

Only authorized approvers may commit carrier to a data request


Access and Security

AS.13

5/23/22

Data request communication shall be through a communications protocol within OpenIDL and archived within OpenIDL


Access and Security

AS.14

5/23/22

Individual carrier contribution to a data request will not exceed 15% of the population of premium, losses, exposures, etc. for a given information request


Access and Security

AS.15

6/1/22

OpenIDL is responsible for fulfilling multi-carrier information requests including extraction patterns, aggregations and formatting of final reports


Communication

C.1

6/1/22

All requests for information via OpenIDL will be through a secured communications portal within OpenIDL


Communication

C.2

6/1/22

All communications will be written (electronic) and be archived by OpenIDL for 10 years


Communication

C.3

6/1/22

A non-response to a request for information will  be considered a decline to participate


Communication

C.4

6/1/22

Requests for information must come from an authorized representative of the requesting body


Communication

C.5

6/1/22

Requests for information must state the regulatory authority for the information being sought


Communication

C.6

6/1/22

Agreement to participate in a request for information is conditioned on OpenIDL providing the carrier the proportion of data that carrier is providing to the population of data


Communication

C.7

6/1/22

Final agreement to participate in a request for information is valid once received by the OpenIDL communications portal


Communication

C.8

6/1/22

Final agreement to participate may be recinded up to an hour after final agreement is received by the communciations portal to affirm participation




Time

Item

Who

Notes









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