Transparència algorithmic: Automation of the energy poverty report (or IRER)

Transparència algorithmic: Automation of the energy poverty report (or IRER)

Overview 

It is a cloud service that automates the social reporting of energy vulnerability, both the management process and the preparation of the report.

use case 

Social reports of energy vulnerability, also known as energy poverty reports, are prepared monthly by the Basic Areas of Social Services (ABSS) in compliance with the Law 24/2015, on urgent measures to deal with the emergency in the field of housing and energy poverty. The aim is to prove the economic vulnerability of people or family units at risk of residential exclusion in the face of possible electricity, gas and potable water supply cuts due to non-payment.

These reports are generated at the request of the supply companies (more than 50 different companies), following the precautionary principle established by law.

Currently, the data verification process is manual and lacks standardization. Given this situation and considering that much of the data necessary for the preparation of reports can be consulted through the interoperability services of Via Oberta, the AOC has developed a cloud solution to automate this process, improving interoperability between companies, municipalities and other administrations to verify data. The solution is a complex process automation system, which uses robotic process automation (RPA) and business process modeling (BPM) technologies. In addition, it is based on a cloud service provided by a private company, does not require installation, but does integrate with many other AOC information systems, such as interoperability services. Via Oberta and the social services information system Hèstia.

AI system risk level (according to the criteria of the European Artificial Intelligence Regulation (RIA))

Although this it is not an AI system —it is an RPA based on predefined rules and totally deterministic decisions, without machine learning or statistical inference—, its use is considered high risk in terms of social impact, because it operates in a particularly sensitive area (energy poverty) and can influence the issuance of a report with relevant legal and social effects (for example, an electricity cut).

For this reason, even if the RIA is not formally applicable to it, it has been decided to apply reinforced guarantees of transparència, supervision and accountability, comparable to those that would be required in high-risk systems, given that:

  • automates part of an administrative action that can have important consequences for people,
  • processes data of people in vulnerable situations,
  • and is inserted into a procedure that requires maximum guarantee and control.

Status

pilot The service is being tested in 20 municipalities. Pilot municipalities:

  • El Prat de Llobregat (65.030 inhabitants), Amposta (21.807 inhabitants), Granollers (61.983 inhabitants), Sant Boi de Llobregat (83.371 inhabitants), Palau Solità i Plegamans (14.911 inhabitants), Salou (30.087 inhabitants), Reus (108.535 inhabitants), Manlleu (21.182 inhabitants), Esparreguera (22.392 inhabitants), Esplugues de Llobregat (46.968 inhabitants), Badalona (226.219 inhabitants), Canovelles (17.264 inhabitants), Cardedeu (19.091 inhabitants), La Llagosta (13.070 inhabitants), La Roca del Vallès (10.956 inhabitants), Montornès del Vallès (817.039 inhabitants), Olesa de Montserrat (24.703 inhabitants), Sant Joan de Vilatorrada (10.972 inhabitants), Vila-seca (24.061 inhabitants) and Vilanova i la Geltrú (70.293 inhabitants)

The first pilot that was launched was that of Prat de Llobregat, in April 2023.

Main benefits of the service

 Benefits for citizens:

  • Better service and agility in attention: The automation and standardization of the process allows a faster and more accurate response to cases of energy vulnerability, improving the quality of social services and attention to people at risk.
  • Ensure access to basic supplies: Through this system, the determination of the vulnerability situation is expedited, ensuring that people and family units at risk receive the attention and basic supplies they need.
  • Reduction of bureaucracy and improvement of the user experience: The automated process avoids unnecessary procedures and simplifies interaction with the Administration, reducing bureaucracy and improving the experience of citizens in vulnerable situations.

Benefits for the administration:

  • Saving time and resources: Significant reduction of the time and administrative tasks required to generate the energy poverty reports, allowing better management of the Administration's human and economic resources and optimizing its performance.
  • Standardization and improvement in data management: Through the integration of multiple data sources and their automation, a more precise and standardized view of the energy vulnerability situation is achieved, improving decision-making and facilitating communication between companies, municipalities and other administrations.
  • Support for municipalities with limited resources: The cloud service offers the possibility of access to advanced technology without the need for large investments in infrastructure or internal resources.

Contact information 

Responsible body
Open Administration of Catalonia 

Contact team for inquiries
Sub-directorate of Strategy and Innovation

Team email
innovacio@aoc.cat  

External supplier
BPM Consultants

Supplier email
jordiburgas@consultorsbpm.com

More detailed information about the service 

Familiarize yourself with the information used by the RPA system, its operating logic, and its governance. 

Data sets 

Input data 

Two main sources of input data are used:

1) Data from the structured .xls files sent by the energy supply companies

  • ID
  • INE code of the municipality
  • Postal address of the holder

2) Data that feeds the algorithm for calculating the coefficient of the energy poverty report

A. Data from Via Oberta

Via Oberta is an interoperability service offered by the AOC to facilitate the electronic exchange of data and documents between administrations and public entities within the framework of an administrative procedure and with the aim of making effective the right of citizens not to contribute documents that are already in the possession of public administrations.

Through the services of Via Oberta The necessary data is consulted to perform the automated calculation of the coefficient that will determine whether the person or family unit is in a situation of vulnerability.

Specifically, the following data is consulted:

  • Register data. This query allows:
    • Check that the person holding the supply contract is registered at the address that appears in the file that the energy suppliers send to the different ABSS where the affected contracts are recorded. Method of consultation: Registration data of an owner.
    • Obtain the total number of cohabitants over the age of 16 and their data. Query method: Coexistence data of a holder.

Below are 4 services consulted: Via Oberta which return economic results that add up to each other.

  • Income data. Method of consultation: C4 – Income for social benefits of the AEAT, if the person has submitted the declaration of personal income tax; Imputation certificate, when the taxpayer is not required to present it.
  • Public pensions exempt from AEAT. This query returns the number of existing records and the total amount (field: remuneration) which is added to the general amount.
  • SEPE unemployment benefits. From this query, the amount obtained per period certificate is obtained (field: gross amount) and added to the general amount.
  • Public social benefits of the INSS. Type: current pensions. The number of payments and the monthly gross amount are obtained from this query.

Also consulted are 2 services: Via Oberta which do not return amounts but will affect the reference threshold:

  • SISPAP disability. Query mode: Basic data. Information on whether or not recognition of disability exists is extracted from this query.
  • Department of the IMSERSO. Consultation method: Level and degree of dependence. From this query it is extracted whether the person has a grade III - level 1 or 2 (high dependency).

All these consultations are repeated for each member of the cohabitation unit over the age of 16. Once these amounts have been added up, the income of the cohabitation unit is obtained. These incomes will have to be compared with the reference tables, taking into consideration what the regulations specify to define if they are in a situation of energy vulnerability.

B. Data fromHèstia or own social information system

Hèstia is an information system for social services used by more than 800 councils (91 ABSS users according to 2023 data). It allows to have the files of social services of the citizens in electronic format.

The following data can be obtained by consulting the social services file of the holder:

  • Energy dependence. (article 5.13 of Law 24/20115)
  • Imminent risk of losing the home
Output data

Data and documents generated by the service:

  • Vulnerability reports
  • Evidence of the process

❗ Considerations about the processing of input data and the preservation of vulnerability reports and evidence:

  • The data that is managed during the generation process of the energy poverty report is owned by the councils that participate in the pilot. The pilot councils sign an order for the processing of personal data with the company awarded the service contract for the implementation of the solution (ConsultorsBPM). The AOC does not access any personal data in the process of automating the report.
  • The processing of input data involves:
    • Processing Manager (pilot municipality)
    • Processing Manager (ConsultorsBPM)
  • Vulnerability reports are saved in a Microsoft Sharepoint instance of ConsultorsBPM to which authorized persons in the pilot municipalities have access with a username and password.
  • Evidence and related files are kept for one month. Positive vulnerability reports are valid for one year and are currently all retained.

Data processing 

The operational logic of automatic data processing and the reasoning carried out by the system is based on the following model and methodology: 

Step by step of the process
The AI ​​system allows the BPM AgilePoint platform to upload the .xls files that the energy suppliers send to the different ABSS where the affected contracts are recorded. The initial screen includes the functionality to ask for the password of the files since some companies protect them.
Once the file is uploaded, the first step is to perform a series of checks such as whether the company provided is correct, whether or not the file is password protected and provided, etc.
The system then processes the data and starts the process for each of the records. First of all, it checks that the holders are registered in the municipality and verifies if they have a file registered with theHèstia, which authorizes subsequent consultation of the data.
From here, the system calculates in parallel the coefficients of both the holder and the beneficiaries, making the corresponding calls to Via ObertaOnce the query calls for all documents have been completed, the system calculates the coefficient, automatically generates the vulnerability report model and the signa.

The last step is the communication to the supply companies (this last step is not yet automated, it is being redefined and in the development phase).

  • Process flow diagram:

Service architecture

The solution runs on a cloud platform provided by the private company ComsultorsBPM. The platform is AgilePoint and is where the RPA processes are executed. It is a multi-user, multi-platform and multi-device execution environment, and allows controlled access to data.

The generated reports are stored in a Microsoft Sharepoint repository hosted on Microsoft Azure servers, within the European Community.

Integrations with Via Oberta are carried out through web services. The queries in Via Oberta are carried out with the CDA electronic seal (application device certificate) of the city council, which transfers it to the company ConsultorsBPM.

The company ConsultorsBPM makes the calls to Via Oberta from a centralized public IP.

  • Technological diagram:

System performance 

A success rate of 90% is currently achieved. With legal and organizational changes, this figure could reach almost 100%.

Human supervision 

The system acts directly, but requires the supervision of a person who validates the results before sending them to the supplying companies. Human supervision is essential to ensure the accuracy and consistency of the reports generated and to avoid possible errors in specific cases that may escape the logic of the system.

Regulatory compliance of the system

El Responsible for Treatment (pilot municipality), theIn charge of the Treatment (ConsultorsBPM) and all its staff are subject to data protection regulations, in particular Organic Law 3/2018, of December 5, on the protection of personal data and guarantee of digital rights (hereinafter LOPDGDD) and Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, relating to the protection of natural persons and the free movement of such data and which repeals Directive 95/46/CE (General data protection regulation, published in the Official Journal of the European Union -DOUE of 4-05-2016-, hereinafter RGPD).

Regarding the RGPD, we highlight the application of the following principles:

  • Data minimization principle: only the necessary data is collected to fulfill the purpose of the service (generate the energy poverty report that is regulated by the Llei 24 / 2015)
  • GDPR purpose limitation principle: the data collected is only used for the purpose communicated to the individual.eresnow.

Regarding the consent of the person concernederesregarding the issuance of the energy poverty report: According to the Statute of Autonomy and the Catalan Law on Social Services 12/2007, which determine that every person has the right to decide whether or not to receive a social benefit, The person musteressada gives consent for the preparation of this report.

The information systems associated with this service also comply with current regulations.

  • Regarding interoperability (consultations at Via Oberta):
    • Comply with the Law 39/2015, of 1 October, on the common administrative procedure of public administrations (art. 28.2) i Law 26/2010, of August 3, on the regime and procedure of the public administrations of Catalonia (art 25.4)
    • The data obtained through Via Oberta they have an administrative file behind them and can only be consulted within the framework of the procedures authorized by the data providers.
    • According to article 1.1 of the seventh final provision of Law 2/2014 on fiscal, administrative, financial measureseres and the public sector, modified by Law 5/2020 (article 163), the inquiries to Via Oberta are carried out without the consent of the person concernederesset or the people in their living unit. However, although consent is not required, it is the person must be informederessada so that you can oppose the consultation of data by the administration (article 28, law 39/2015). In this case, if the person objects, they should provide the documentation themselves.

This is a Automated Administrative Action (AAA)? Yes.

In this, the pilot Council is subject to the legal obligation to publish the AAA linked to the service at the e-headquarters, accompanied by a technical file (See article 11, letter i, of Royal Decree 203/2021, which approves the Regulation on the action and operation of the public sector by electronic means; which implements Law 40/2015 on the Legal Regime of the Public Sector)

Risk management 

Know the most likely risks in relation to the fundamental principles and rights that need to be protected, and the measures applied in each case to ensure compliance with these rights and mitigate the risks.

A. Equality and non-discrimination
  • Identified risks: possible biases derived from the administrative data consulted or the rules defined in the process; inconsistent application in particular cases; unequal impact on people or family units in vulnerable situations.
  • Measures applied
    • The system is deterministic and follows predefined rules, which avoids biases derived from training or machine learning processes.
    • The rules and calculation criteria have been defined in accordance with current regulations (Law 24/2015) and are reviewed with the pilot municipalities to ensure fair and consistent application.
    • The data used comes from official and verified sources (Via Oberta, census, income, benefits...), minimizing risks of errors or unequal treatment.
    • To promote the digital inclusion, special attention has been paid to the user experience so that the process is simple, guided and easy to use for the social services teams of the municipalities.
    • La mandatory human supervision before sending the reports guarantees the detection of specific errors and corrections in sensitive cases or situations not foreseen by the system logic
B. Data protection and privacy
  • Identified risks: possible misuse of personal data by third parties, unauthorized access, or impact on the privacy of people in vulnerable situations.
  • Measures applied
    • Since the system processes data from vulnerable people, can generate automated decisions with significant effects and uses advanced automation technology, each pilot municipality must carry out a data protection impact assessment (DPIA) before putting it into operation.
    • The service provider company acts as the data controller. and has signed the corresponding treatment order.
    • All data is processed and stored within the European Union, complying with the requirements of the GDPR.
    • The Data Controller (each pilot municipality) guarantees the exercise of ARCO rights (Access, Rectification, Cancellation and Opposition)) of the affected people.
    • In the social care model, it is necessary to obtain the consent of the person insideeresestablished for the issuance of the report, in accordance with Law 12/2007 and Law 24/2015.
    • Consent and cookies associated with the information systems involved in the service are adequately managed.
C. Safety and robustness
  • Identified risks: unavailability of the service, unauthorized access, data leakage, errors in the generation of reports or inconsistencies in the result.
  • Measures applied
    • Before implantation, it is necessary to perform a service security analysis to identify the main risks and categorize the system according to the criticality of data treated. This analysis guarantees the adequacy to the requirements of theNational Security Scheme (ENS) for the corresponding security level.
    • The contract with the supplier establishes Service Level Agreements (SLAs) which define the minimum parameters of availability, performance and response time. These SLA are reviewed periodically to ensure compliance.
    • Access to the data and generated reports is restricted to authorized persons from the pilot municipalities through user credentials.
    • Reports and evidence are stored in a secure cloud environment (Microsoft SharePoint, hosted in the EU), with controlled access mechanisms.
    • Calls to interoperability services Via Oberta are carried out with the application device certificate (ADC) from the city council and from a centralized public IP, reinforcing traceability and security.
D. Transparència and explainability
  • Identified risks: opacity, distrust, disinformation.
  • Measures applied
    • To reduce risks of opacity and ensure understanding of how the service works, this has been published. sheet of transparència algorithmic on the AOC website. The document clearly explains the data used, the rules applied, the automated process and the role of human supervision.
    • Although the system is deterministic, as it works with predefined rules and does not incorporate inference or machine learning processes, this sheet has been prepared due to the sensitive nature of the use case and its direct impact on people. This decision follows the criteria applied to other complex automation systems, where it is considered relevant to guarantee the maximum transparència, understanding and trust in algorithmic performance, whether or not based on AI.
E. Retention of accounts and auditability
  • Identified risks: legal uncertainty, lack of system quality
  • Measures applied
    • To guarantee the retention of accounts and the quality of the service, several mechanisms have been established:
      • Mandatory human supervision: Before sending the vulnerability report to the supply companies, a social services professional reviews and validates the result generated by the system. This supervision ensures consistency and avoids errors that could have legal or social consequences.
      • Regulatory compliance: Both the pilot city council (data controller) and ConsultorsBPM (data processor) and their staff comply with current data protection regulations (RGPD and LOPDGDD), as well as interoperability and administrative procedure regulations (Law 39/2015, Law 26/2010 and applicable regulations). Via Oberta).
      • Obligation to publish as Automated Administrative Action (AAA): The pilot municipalities must publish the AAA associated with the service in the electronic office, along with the corresponding technical sheet, in accordance with Royal Decree 203/2021. This requirement reinforces the transparència and the traceability of the automated procedure.
      • Risk analysis and continuous improvement: It is planned that the pilot municipalities will carry out a Data Protection Impact Assessment (DPIA) given the sensitivity of the use case. In addition, the quality of the system is assessed based on its performance (currently 90% success rate) and legal and organizational adjustments are foreseen that could further increase this accuracy.
    • This set of measures facilitates the audit of the operation of the system and guarantees a solid framework of responsibility, quality and legal certainty in the use of the automated service.

More information

2024.07.03-33rd-DIBA-Summer-School-Pilot-Energy-Poverty-v2Low

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