ECC(16)026 Annex Feasibility StudyStudy An ECO-hosted database to facilitate communications in Europe (PSAP-DB) 9 February 2016 inter-PSAP Draft ECC REPORT <No> - Page 2 TABLE OF CONTENTS 0 Introduction .............................................................................................................................................. 5 1 Scope and terms of reference ................................................................................................................ 7 2 Evidence of Support from European Emergency Services Stakeholders ......................................... 8 2.1 Evidence of support for PSAP-DB ................................................................................................... 8 3 Current EENA Database ........................................................................................................................ 10 3.1 History ............................................................................................................................................ 10 3.2 Responsibility and Liability............................................................................................................. 10 4 Scope of the ECO's Operational Activities .......................................................................................... 11 4.1 The CEPT Portal ............................................................................................................................ 11 4.1.1 ECO Documentation Database (DocDB).......................................................................... 11 4.1.2 ECC Work Programme Database (WP-DB) ..................................................................... 11 4.1.3 CEPT Messaging/Chat system ......................................................................................... 12 4.1.4 SEAMCAT ......................................................................................................................... 12 4.1.5 700 MHz coordination information repository ................................................................... 12 4.1.6 ECO Frequency Information System (EFIS)..................................................................... 12 4.2 ECO competence .......................................................................................................................... 12 5 Framework .............................................................................................................................................. 14 5.1 WG NAN vision for its future involvement in Emergency Services communications .................... 14 5.2 ECC Strategic Plan 2015-2020 ..................................................................................................... 14 5.3 WG NaN Terms of Reference........................................................................................................ 14 5.4 Purpose of an ECC Decision ......................................................................................................... 15 5.5 Approval Procedure ....................................................................................................................... 15 6 Technical specifications and Resource Commitment ....................................................................... 16 6.1 Requirements and Technical Specifications .................................................................................. 16 6.1.1 PSAP-DB Development Costs .......................................................................................... 16 6.1.2 PSAP-DB Participation ..................................................................................................... 16 6.1.3 Fields/Columns in PSAP-DB ............................................................................................ 17 6.1.4 Data Entry and Maintenance ............................................................................................ 18 6.1.5 Protocol for Use and Contingency Plans .......................................................................... 18 6.1.6 Membership Management - Designated Focal PSAP Contact Points ............................. 19 6.1.7 Membership Management - PSAP operatives ................................................................. 19 6.2 Resource Commitment .................................................................................................................. 20 6.2.1 Financial Commitment ...................................................................................................... 20 6.2.2 Human Resource Commitment by ECO ........................................................................... 20 7 Legal Issues............................................................................................................................................ 22 7.1 Legal Framework ........................................................................................................................... 22 7.2 The Role of the Steering Group ..................................................................................................... 22 7.3 Dispute Resolution Process........................................................................................................... 22 7.4 Potential scenarios where legal issues could arise ....................................................................... 23 7.4.1 Unauthorised Access to PSAP-DB Data .......................................................................... 23 7.4.1.1 Responsible Party ............................................................................................. 23 7.4.1.2 Probability and Impact ....................................................................................... 23 7.4.1.3 Risk of Conflicts arising from Unauthorised Access .......................................... 23 7.4.2 Corruption, Loss or Unavailability of PSAP-DB ................................................................ 24 7.4.2.1 Responsible Party ............................................................................................. 24 Draft ECC REPORT <No> - Page 3 7.4.3 7.4.2.2 Probability and Impact ....................................................................................... 24 Unauthorised Access to an Offline Version of PSAP-DB ................................................. 24 7.4.3.1 Responsible party .............................................................................................. 24 7.4.3.2 Probability and Impact ....................................................................................... 24 8 IMPACT ASSESSMENT ......................................................................................................................... 26 8.1 Impact on CEPT administrations (national NRAs/Ministries) ........................................................ 26 8.2 Impact on ECC/WG NaN ............................................................................................................... 26 8.3 Impact on the ECO ........................................................................................................................ 27 8.4 Impact on PSAPs ........................................................................................................................... 27 8.5 Impact on the provision of emergency services in Europe ............................................................ 27 9 Conclusions............................................................................................................................................ 28 10 Decision of WG NaN Based on the Conclusions of the Feasibility study ....................................... 29 ANNEX 1: EENA LETTER .............................................................................................................................. 30 ANNEX 2: Draft ECC Framework Decision.................................................................................................. 32 INTRODUCTION...................................................................................................................................... 32 BACKGROUND ....................................................................................................................................... 32 REQUIREMENT FOR AN ECC DECISION ............................................................................................. 32 ANNEX 3: Draft Agreement between ECO and participating focal psap ................................................. 34 Draft ECC REPORT <No> - Page 4 LIST OF ABBREVIATIONS Abbreviation Explanation (style: ECC Table Header red font) CEPT European Conference of Postal and Telecommunications Administrations ECC Electronic Communications Committee PSAP Public Safety Answering Point PT ES Project Team Emergency Services WG NaN Working Group Numbering and Networks EENA European Emergency Number Association a Brussels-based NGO dedicated to promoting high-quality emergency services reached by the number 112 throughout the EU <abbrev> <explanation – edit the table as necessary> Draft ECC REPORT <No> - Page 5 0 INTRODUCTION The European Emergency Number Association (EENA)a Brussels-based NGO established a database for transnational emergency calls which currently has 15 participating countries1. Despite some countries pledging support for the concept, they were reluctant to participate because EENA, as the database host, is a non-governmental organisation and these countries expressed a preference for the database to be hosted by an appropriate public European body with relevant expertise and experience to provide the service. On that basis, and with a view to improving the service, EENA contacted the ECO in July 2014 to discuss the possibility of CEPT/ECC taking over responsibility for hosting and maintaining the database. The ECO made a presentation on the subject at the 10th meeting of WG NaN (Oslo on 22-23 October 2014). The minutes recorded the following summary of the discussion: "WG NaN is in principle supportive of the initiative but advises to proceed with caution. PT ES will study the matter and report back to WG NaN on the legal and practical issues (e.g. liability) of hosting such a database including providing clarity on the expected impact (responsibility) on NRAs, Ministries and PSAPs and ECO." In 2013, WG NaN established Project Team Emergency Services (PT ES) with the sole objective of developing ECC Report 225 on Establishing Criteria for the Accuracy and Reliability of the Caller Location Information in support of Emergency Services. The Report identified other aspects of emergency services communications that required further study and the remit of PT ES was continued and the scope broadened. The ECC's role in the field of emergency services communications was made explicit in the revised ECC Strategic Plan for 2015-2020 which set an action for WG NaN to "study relevant aspects of emergency services communications and provide support and advice to European emergency services stakeholders where appropriate". PT ES, at its 9th meeting in Copenhagen (16-17 March 2015) considered that it was necessary for EENA to formalise its request to CEPT/ECC explaining the need and rationale for the database to be hosted by an alternative entity. The EENA letter, dated 10th April 2015, is contained in Annex 1 of this document. Until now, EENA has managed this database but it considers that the time has come to place it on a more formal footing. This Feasibility Study examines all of the issues, responsibilities and requirements associated with the European Communications Office (ECO), as the permanent office of CEPT/ECC, taking over from EENA the responsibility of maintaining the database under a framework established by the ECC that would provide invaluable support to European PSAPs. "PSAP-DB" is the term used throughout this document to describe an ECO-hosted database to facilitate inter-PSAP communications in Europe. 1 Belgium, Bulgaria, Croatia, Czech Republic, Estonia, Finland, Hungary, Iceland, Ireland, Latvia, Lithuania, Romania, Slovak Republic, Sweden, UK Draft ECC REPORT <No> - Page 6 1 BACKGROUND Calls to emergency services are originated and terminated nationally . For European citizens travelling in Europe, this means that a call made to emergency services will be answered in the country from which the call was made. This is not always the most appropriate arrangement to cover every call scenario and there is no legal basis for emergency calls to be handled internationally. For example, a caller to emergency services could be requesting assistance for a relative in another country. Furthermore, the PSAPs may have a need to communicate with a PSAP in the caller's home country in order to assist, e.g. with translation. An emergency caller may, in border areas or at sea, inadvertently roam onto a foreign network leaving the call to be answered in a country other than where emergency assistance is required. Calls from IP-based networks, corporate networks and smart phone applications could also end up being answered in the wrong country by the wrong Public Safety Answering Point (PSAP). It should be noted that work is ongoing within ETSI to improve caller location information for emergency calls originating on IPbased networks, the consequence of which, will ensure that such calls are routed to the correct PSAP. Therefore a gap may continue to remain that needs to be addressed so that coverage and access to emergency services is universal throughout Europe in terms of its effectiveness in protecting the welfare and personal safety of all European citizens and travellers. This gap can be bridged quite easily by providing a facility to European PSAPs that would allow them to communicate with each other when cross-border assistance is required. This facility could be provided in the form of a database that contains contact information for a focal PSAP in each European country. Access to the database could be granted to all European PSAP operatives, under certain terms and conditions, and the database could be interrogated to find the correct contact information in order to deal with a cross-border call in an expeditious manner. Independently of an emergency call, an efficient system for distribution of contact details between PSAPs might be beneficial to the overall readiness and crisis management in a country as it improves the capacity to transmit early warning information between PSAPs, e.g. with thunderstorms or other crises. Draft ECC REPORT <No> - Page 7 2 SCOPE AND TERMS OF REFERENCE The purpose of this Feasibility Study is to investigate all of the issues associated with the ECO, as the permanent office of the CEPT/ECC, taking over responsibility for PSAP-DB in order to inform WG NaN's decision on whether or not to proceed. The following chapters analyse in detail the various issues. Chapter 2 aims to determine the level of support that exists in CEPT countries for PSAP-DB which would justify the resource commitment by the ECC/ECO. This chapter also looks at some preliminary suggestions from relevant stakeholders regarding how PSAP-DB could be used and is based on a recent survey of European PSAPs carried out by PT ES. Chapter 3 describes the current database hosted by EENA and identifies improvements that could be made in order to increase security, reliability and participation by PSAPs from all countries in Europe. Chapter 4 describes some of the tools and services provided by the ECO and aims to demonstrate its competence in developing and maintaining leading edge IT systems. Chapter 5 examines whether the proposal to develop and host PSAP-DB falls within the remit of the ECC and describes a proposal for an ECC Decision to provide a framework under which the ECO could host PSAP-DB. Chapter 6 provides a high level technical description of the PSAP-DB architecture and how it could work. This chapter also deals with budgetary issues such as the cost of development and maintenance as well as the human resource commitment that would be required from the ECO on an annual basis. Chapter 7 examines the legal issues associated with PSAP-DB and describes the roles and responsibilities of all parties involved. Chapter 8 examines the potential impact of assuming responsibility for PSAP-DB on the various stakeholders including CEPT administrations, the national PSAPs and the ECO. Chapter 9 draws conclusions based on the analyses contained in the Report which will be used to inform WG NaN's decision on whether or not to proceed. Draft ECC REPORT <No> - Page 8 3 EXPECTED SUPPORT FROM EUROPEAN EMERGENCY SERVICES STAKEHOLDERS PT ES, at its 9th meeting in Copenhagen on 16-17 March 2015, decided that it would be worthwhile, as a first step in the feasibility process, to carry out a survey to gauge support from the CEPT administrations and the emergency services community for PSAP-DB. PT ES also considered the survey as an opportunity to consult with the PSAPs in order to determine the impact of using PSAP-DB and what that impact could mean for the PSAPs' day-to-day operations. The questionnaire was formulated at the 10th meeting of PT ES in Bucharest on 2-3 June 2015 and was finalised at a web meeting on the 19 June 2015. The WG NaN chairman circulated the questionnaire on 24 June 2015 for response by 14 August 2015. 32 responses in total from organisations in 23 CEPT countries were received including responses from 13 of the 15 countries currently participating in the EENA database. The results of the questionnaire were presented at the 11th meeting of PT ES in Stockholm (29-30 September 2015) and at the 11th meeting of WG NaN in Vienna (29-30 October 2015). A full summary of the responses is available Annex 4. This Chapter discusses the main results of the survey. 3.1 EXPECTED SUPPORT FOR PSAP-DB 28 respondents (including x respondents from y CEPT countries) to the questionnaire are supportive of PSAP-DB. Denmark and one regional PSAP operator from Amgevicesa (Spain), which is responsible for Spain's North African emergency operations, answered "No" to the question. Denmark raised concerns about the ECO maintaining such information while Amgevicesa (Spain) did not give a reason. Germany, although supportive in principle in its response, set some compulsory conditions for its support which will probably not be met so this response has to be considered as not supportive as well. Some of the respondents considered that this type of solution was becoming more important in a globalised world and that PSAP-DB would provide an improved service for citizens which would lead to more lives saved. Others stated that it may encourage other countries to join the database also. Two respondents preferred (with one of them (Germany) setting this as a compulsory condition for participation) that a solution be mandated by the European Union for the 28 CEPT countries that are also EU member states. CEPT has 48 member countries. 31 respondents to the questionnaire considered that PSAP-DB would help them to carry out their work more effectively and gave examples of how the database could be useful such as: Caller in one country calling for help for a relative in another country Effective information management between PSAPs internationally Incorrectly routed emergency calls originating on VoIP and corporate networks To allow PSAPs to contact each other for translation services when needed Accidents at sea Indicate origination information (A-number) and forward to country B Transmit early warning information/emergency/crisis situations status between PSAPs. Example provided by Sweden of thunderstorm in Latvia which spread to Estonia and Finland. Deal with calls from tourists Some respondents noted that bilateral agreements are already in place with neighbouring countries to deal with inadvertent roaming calls. These bilateral agreements may extend to include arrangements for resource sharing and it should be clear that PSAP-DB would complement, rather than replace, any existing bilateral agreements. The survey contained a question describing WG NaN's initial view that PSAP-DB could be provided with a secure interface to allow a primary PSAP in each country to insert and maintain its own database entry. 29 respondents to the questionnaire agreed with this approach and a suggestion from one respondent to notify all PSAP operators when an entry is updated has been noted and will be discussed further in Chapter 6. Draft ECC REPORT <No> - Page 9 17 of the respondents considered that there should only be an entry in PSAP-DB for one focal PSAP per country. The main reason given for this approach is that a PSAP operative in another country would not have the local knowledge to select the correct PSAP to which the call should be routed if there were more than one PSAP per country. It might be useful to provide contact details for one additional backup PSAP and this can be discussed further with the PSAP stakeholders. Another key question asked in the survey was if the respondents considered that the ECC/ECO’s role in providing the database could interfere in a negative way with day-to-day PSAP operations. The overwhelming response from 28 respondents was that it would not and on a positive note, 18 respondents expressed their willingness to participate in drafting the terms and conditions for access and use of PSAPDB. The results of the questionnaire indicate a positive and supportive response from the PSAP community in Europe. Draft ECC REPORT <No> - Page 10 4 4.1 CURRENT EENA DATABASE HISTORY In 2009, EENA was contacted by several emergency services representatives in Europe requesting a database containing long form E.164 telephone numbers to facilitate contact between European PSAPs when a need arises. EENA gathered the information together to form the database and, in 2012, it published an operational document entitled "Transnational Emergency Calls" which provides the framework for: the content of the database its consolidation the secured access to the database This document also intends to: define a basic set of protocols for the PSAPs using the database define the validation and verification methods The table below describes the database structure and the nature of the information stored. The database is currently in the form of an MS Excel spreadsheet containing relevant contact information for a single focal PSAP in each participating country. Table 1 below provides a snapshot of the information contained in the EENA database. Table 1: Example of information stored in current EENA Database As the information contained in the database is confidential in nature, the spreadsheet is password protected and updates are communicated to EENA who then issue a revised version to each focal PSAP. As use of the database has become more widespread, the relevant national authorities have raised concerns about the security and reliability of having different versions of the spreadsheet in circulation and have expressed to EENA that they would be more comfortable if the database was hosted in a different format and by an appropriate public European body. After discussions with the European Commission, EENA approached the ECC/WG NaN to see if it was in a position to assist. The EENA letter is contained in Annex 1. 4.2 RESPONSIBILITY AND LIABILITY Section 10 of the EENA document on transnational emergency calls states that "the EENA cannot be held responsible or liable for any misuse of the EENA PSAPs Database nor any damage caused. The EENA and the PSAPs accessing the database commit not to share the database with any third parties. EENA and the PSAP accessing the database reserve the right to take legal action." WG NaN / PT ES considers that the ECO would also need to seek to protect itself against any responsibility or liability arising from the misuse or breach of confidentiality regarding the database and it considers that these issues can be addressed through system design and an appropriate agreement between the parties. These issues are discussed further in Chapter 7. Draft ECC REPORT <No> - Page 11 5 SCOPE OF THE ECO'S OPERATIONAL ACTIVITIES The ECC, one of three business committees of the CEPT, develops policies in the areas of spectrum management, numbering and networks. As a policy committee, executing operational functions, such as hosting PSAP-DB, would be outside of its scope of activities. However, the ECO, as the permanent office of the CEPT, does have operational activities as part of its mandate to provide administrative and expert support to the work of the CEPT business committees. This Chapter describes some of the operational activities that the ECO has responsibility for. The information contained in this chapter aims to demonstrate the ECO's competence and expertise in developing, hosting and maintaining leading edge IT platforms and tools. 5.1 THE CEPT PORTAL The main CEPT website, available at www.cept.org, is a central portal providing tools and information that support the work of the CEPT's three business committees. The portal, developed and maintained by the ECO, is integral to the efficiency and effectiveness of the ECC in achieving its objectives through providing a platform for membership management, document hosting/sharing and meeting coordination. At the end of 2014, the portal's document server hosted over 30,000 documents. From an ECC perspective, the portal facilitates collaboration across its membership while ensuring its communications are open, consistent and effective. The website was completely revamped in 2011 and provides a central resource where many different tools and services can be accessed by CEPT administrations and the general public. In 2014, the CEPT portal had over 1.1 million visitors. The following sections describe some of the tools and services developed and provided by the ECO through the CEPT portal. 5.1.1 ECO Documentation Database (DocDB) This database contains a library of ECC Deliverables approved by the ECC. Relevant EC Decisions are also provided for information purposes. DocDB provides a facility to track the most popular (downloaded) documents in each category. DocDB is available via the CEPT website or directly at www.ecodocdb.dk. During 2014, 960 new deliverables were added to DocDB and it received 520,000 visits. 5.1.2 700 MHz coordination information repository The ECO has been asked by the ECC to develop, under the authority of the ECC SG, an information repository related to the 700 MHz coordination within CEPT. The purpose of this repository is to provide CEPT administrations with an overview of 700MHz coordination for a finite time covering the main phase of evolution of the 700 MHz band according to national requirements. Use of the system by administrations will be entirely voluntary and the ECO will set up the system in such a way that only the administrations would be able to enter data and take responsibility for the accuracy of that data. 5.1.3 ECO Frequency Information System (EFIS) On 31 January 2002 the ECO launched a frequency information database which was developed in cooperation with the ECC, called EFIS. Access to EFIS is publicly available and can be interrogated by any interested party to search for and compare spectrum utilisation across Europe. EFIS also provides related information on CEPT/ECC activities, radio interface specifications (according to the R&TTE Directive) and other national or international regulations. EFIS is available via the CEPT portal or directly at www.efis.dk. ECC Decision (01)03 provides the framework for EFIS and defines inter-alia the ECO's role and responsibilities and the information that administrations must provide. With this tool the ECO aims to provide a valuable service to all parties with an interest in spectrum utilisation. EFIS also contributes to the CEPT/ECC policy objectives of harmonisation and transparency regarding spectrum use. Draft ECC REPORT <No> - Page 12 In 2005, the European Commission issued a mandate to CEPT on the feasibility for EFIS to develop into a recognised European portal for spectrum information. Article 5 of the Radio Spectrum Decision 676/2002/EC generally requires Member States to “ensure that their national radio frequency allocation table and information on rights, conditions, procedures, charges and fees concerning the use of radio spectrum, shall be published if relevant in order to meet the aim set out in Article 1. They shall keep this information up to date and shall take measures to develop appropriate databases in order to make such information available to the public, where applicable in accordance with the relevant harmonisation measures taken under Article 4.” The EC mandate recognised that a single entry point for storing this information is desirable for easy access and user-friendly presentation of spectrum information. Most administrations and industry participants regarded EFIS to be the best choice for a European spectrum information portal. Following completion of the feasibility study an EC Decision (2007/344/EC) was published on the 16th of May 2007 specifying EFIS as the tool to fulfil the requirements of the Radio Spectrum Decision. 5.1.4 ECC Work Programme Database (WP-DB) The purpose of the WP-DB is to provide the ECC and its constituent bodies with an online facility to maintain and update their respective work programmes on a regular basis. The WP-DB is publicly available and provides a central repository of information to any party interested in the work of the ECC. The WP-DB contains a number of individual work items, categorised by working group and project team. The ECO developed and maintains the WP-DB. 5.1.5 CEPT Messaging/Chat system Prior to the World Radio Communications Conference in 2012 (WRC-12) the ECO took the initiative to develop a communications tool to facilitate communications and coordination of CEPT positions during the conference. The messaging system was designed to dispatch short messages and e-mails with attachments, sent by CEPT coordinators to their corresponding contact persons in administrations in order to keep CEPT members briefed of latest developments. The tool was subsequently used by CEPT members at WCIT-12, WTSA-12, WTDC-14, PP-14, CPG-15 and WRC-15. During WRC-15, 3161 subscriptions were registered to 41 chat groups and 21,744 emails and SMS were sent from the system during the course of WRC-15. Based on feedback received from delegates, the ECO has implemented improvements and enhancements to the tool such as integration with CEPT member profiles and an improved notifications system. 5.1.6 SEAMCAT SEAMCAT (Spectrum Engineering Advanced Monte Carlo Analysis Tool) is a software tool based on the Monte-Carlo simulation method which allows statistical modelling of different radio interference situations. It has been developed to deal with a diversity of complex spectrum engineering and radio compatibility problems. It is developed and enhanced by the ECO, in cooperation with the SEAMCAT Technical Group (STG) an entity of the ECC Working Group Spectrum Engineering (WG SE). The tool is designed for systems, in particular terrestrial systems that operate in shared or adjacent frequency bands. It can also evaluate radio equipment parameters (e.g. transmitter emission masks, receiver sensitivity and density of interfering transmitters) where all interference mechanisms can be taken into account. The tool is updated on a regular basis by the ECO based on feedback from its user community and is downloadable free of charge at: www.seamcat.org. 5.2 ECO COMPETENCE The tools and services described in the previous section clearly demonstrate that the ECO has the competence and capability to develop and maintain PSAP-DB. The ECO is also confident that it can provide Draft ECC REPORT <No> - Page 13 PSAP-DB at very reasonable costs given the synergies it can leverage from existing IT investments and experience. For example, the technical structure of the 700 MHz coordination information repository described in section 4.1.5 provides a template for the development of PSAP-DB which means that the costs of initial database design and IT development can be minimised. Furthermore, the framework for EFIS in particular is an excellent precedent and reference model for the development of a framework for PSAP-DB. The next chapter explains in detail a proposal for how this framework could be implemented. Draft ECC REPORT <No> - Page 14 6 FRAMEWORK It is necessary for the ECO to have support from the ECC in order to justify the resource commitment to develop and maintain PSAP-DB. This chapter examines whether this activity would fall within the remit of ECC/WG NaN according to the ECC Strategic Plan and WG NaN's Terms of Reference and describes a procedure leading to a proposal for an ECC Decision to provide a formal framework under which the ECC could support the ECO to develop and host PSAP-DB for use by European PSAPs on a voluntary basis. Overall it has to be considered that the members of ECC as part of CEPT are administrations or regulators, so ECC deals with regulatory and related matters. This leads to the important question: Is the provision of the planned Database fall within the scope of regulatory and related matters? The ECC considers and develops policies on electronic communications activities in European context, taking account of European and international legislations and regulations. The sub clause 5.x will address the European and international legislations and regulations regarding the planned database project. 6.1 WG NAN'SINVOLVEMENT IN EMERGENCY SERVICES COMMUNICATIONS Since the establishment in 2013 of PT ES and the significant resource commitment it made to deliver ECC Report 225, as well as in identifying and setting up the activities covering 4 new work items in the area emergency services communications WG NaN has developed significant expertise in this important area. Its work, particularly on ECC Report 225, was publicly recognized by the European Commission in last year's "112 Day" public relations material. In the future, given its role, as part of ECC, of issuing European policies and providing guidance to the CEPT membership on its fields of competence, WG NaN sees emergency services communications as an area where it can add significant value for its members. 6.2 ECC STRATEGIC PLAN 2015-2020 The ECC Strategic Plan for the period 2015-2020 was adopted at the 38th ECC Plenary in Montreux, Switzerland on 28 November 2014. The ECC's role in the field of emergency services communications is clearly stated in the revised plan which sets an action for WG NaN to "study relevant aspects of emergency services communications and provide support and advice to European emergency services stakeholders where appropriate". 6.3 WG NAN TERMS OF REFERENCE The last review of WG NaN’s terms of reference was carried out in 2010 when WG NNA (Numbering, Naming and Addressing) became WG NaN (Numbering and Networks) to recognise its broader scope when TRIS (Technical Regulatory Issues) became a constituent project team of the working group's structure. Since 2013, the scope of its activities has broadened further with the establishment of PT ES and that has already been reflected in the updated ECC Strategic Plan described in the previous section. At the 11th meeting of WG NaN in Vienna (29-30 October 2015) a revised terms of reference was discussed which proposes to formalise this broader scope and bring the WG NaN Terms of Reference in to line with the ECC Strategic Plan. The revised terms of reference were adopted by consensus by WG NaN with one country reserving its position (Portugal). Several countries pointed out that the terms of reference must be consistent with the ECC Strategic Plan. It was agreed that the revised WG NaN Terms of Reference will be sent to the next ECC Plenary meeting (Ghent, Belgium, 1-4- March 2016) for approval in accordance with the ECC Rules of Procedure. Draft ECC REPORT <No> - Page 15 An ECO-hosted database to facilitate inter-PSAP communications would appear to be within the remit of the ECC/WG NaN given the actions assigned to WG NaN by the ECC in the strategic plan, WG NaN's draft revised terms of reference and WG NaN/PT ES's intentions for future work in the area of emergency services. 6.4 PURPOSE OF AN ECC DECISION ECC deliverables “decide” or “recommend” that CEPT administrations take some action or implement some measure. However, not all CEPT administrations have competence in the field of emergency services communications at the national level or their respective levels of legal competence differ from one administration to another. Some administrations have a central role regarding policy, others have a limited role, such as monitoring the quality of the emergency call answering service and others have no formal role whatsoever. Therefore the applicability of emergency services-related ECC deliverables which propose regulatory measures may be different in the different countries (or not relevant at all) and this proposal for an ECC Decision does not propose to mandate any policy to provide contact information for PSAP-DB or to use it. It is envisaged that participation in, and use of, PSAP-DB will be entirely on a voluntary basis. The purpose of an ECC Decision in this case is to formalise support by CEPT administrations for the ECO, and the ECO Council to commit resources, to develop and maintain PSAP-DB and to provide it as a service to European PSAPs. There is little or no impact on CEPT administrations regarding the ongoing provision of the service. The impact on the various stakeholders is discussed in detail in Chapter 7. 6.5 APPROVAL PROCEDURE Figure 1: Process for PSAP-DB Framework Development Figure 1 above illustrates the steps involved in developing a framework for PSAP-DB. This Feasibility Study is an integral part of the process as it will ultimately inform WG NaN's decision on whether or not to proceed. If WG NaN does decide to proceed it will need to inform the ECC Plenary and request permission to develop an ECC Decision which will provide a formal basis for the ECO to proceed with the project. A preliminary draft ECC Decision is contained in Annex 2 of this document. It should be noted that the December 2015 meeting of ECO Council approved the budget for development costs anticipated to arise in 2016 pending WG NaN's decision to proceed with the project. Draft ECC REPORT <No> - Page 16 7 TECHNICAL SPECIFICATIONS AND RESOURCE COMMITMENT 7.1 REQUIREMENTS AND TECHNICAL SPECIFICATIONS WG NAN / PT ES considers that it will be necessary to establish a steering group to define detailed requirements for PSAP-DB. This should be quite straightforward to implement as 18 respondents to the PT ES questionnaire expressed their willingness to participate in drafting the terms and conditions for access and use of PSAP-DB. The steering group should contain no more than x members and be made up of representatives from the WG NaN / PT ES, ECO, and representatives from the European PSAP community. EENA could be involved at the transition phase. It is envisaged that the steering group would have one physical meeting per year and 2 or 3 web meetings. This essentially means one meeting every quarter. At the outset, when defining requirements, there may be a need for additional meetings which can take via web meeting. The following non-exhaustive list contains some of the functions that the Steering Group would have responsibility for: Providing an initial set of requirements for PSAP-DB Establishing protocols for access and use of PSAP-DB Reviewing, if necessary, the scope of use (use cases) Reviewing, if necessary, the scope of participation (eligible users) Refining the wording of the user agreements Discussing and solving any issues raised by the users, CEPT Administrations or ECO related to the functioning of the PSAP-DB Identifying training requirements for users Consultation will be required with the relevant stakeholders, as described above, to establish a requirements specification for PSAP-DB. Nevertheless, the ECO has already considered some of the main design specification issues and these are provided in the following sections in this chapter in order to fully inform the feasibility study. 7.1.1 PSAP-DB Development Costs The ECO has informed WG NaN/PT ES that it could use an existing template for the development of PSAPDB based on the "700MHz coordination information repository" described in section 4.1.5 which is currently being developed. This will help keep initial development costs at a minimum. The data would be stored in an encrypted format on the server for added security and decrypted prior to presentation to users. 7.1.2 PSAP-DB Participation There are currently 15 countries participating in the EENA database and this could, in theory, rise to 48 countries if relevant PSAP administrations in all CEPT countries decided to participate in PSAP-DB. Furthermore, there has been a proposal to have an entry for one designated focal PSAP in each country and, potentially, one designated back-up PSAP. Therefore it is possible that PSAP-DB could, in theory, contain an entry for 96 different entities if the focal PSAP and back-up PSAPs were defined as separate entities for each country. Otherwise there would only be 48 entries in total. Therefore the database structure is quite simple and straightforward and there is no need for using advanced database development tools such as MS SQL Server, Oracle etc. Figure 2 below provides an overview of how PSAP-DB could work: Draft ECC REPORT <No> - Page 17 Figure 2 - PSAP-DB Structure 7.1.3 Fields/Columns in PSAP-DB The fields contained in PSAP-DB would need to be defined and agreed with the users PSAP-DB intends to serve in the Steering Comittee but the following table provides a preliminary list of potential database fields. Field Description Country Country providing contact information for a designated focal PSAP PSAP name The name of the designated focal PSAP (to be agreed at national level) PSAP address The address of the designated focal PSAP 24 hour Contact telephone number A long form E.164 telephone number in the format + <country code> <area code> <subscriber number>. This is the number that other PSAPs would use to contact the designated focal PSAP in a particular country. The number needs to be available 24 hours per day. Contact e-mail address A dedicated email address based on a standardised naming convention to allow other PSAPs to send information, documents, attachments etc. relating to an emergency incident. The format could be <country>112@<localdomain> Website Address A website address for the focal PSAP if available. This may be useful for the provision of background information. Languages spoken A list of languages spoken by operatives working in the focal PSAP Type of PSAP This field provides information on the type of calls that can be handled e.g. police, fire, emergency medical services, coast guard etc. Region covered Scope of the geographic area covered by the focal PSAP Area covered by other services that emergency calls can be passed to This information could be useful for countries where a stage 1 or filtering PSAP is not implemented. Primary contact point Click here for details (Link to name, address, email, telephone no, position) Secondary contact point Click here for details (Link to name, address, email, telephone no, position) Joining date The date a particular country designated a focal PSAP and joined PSAP-DB Draft ECC REPORT <No> - Page 18 Field Last update Description The time and date of the last update including details of the person who made the update Other/Future Use Note: Users of the PSAP-DB will have a membership profile, similar to the membership profile that ECC group members have today. Some members, such as designated contact points, will have greater access privileges to allow them to update contact information for their respective PSAP, to approve membership requests or to download offline versions. If it is decided to include information on a designated back-up PSAP then this can be stored as a separate entry for each country in the format above or the details can be included in a single database entry with a greater number of fields. This has yet to be agreed. 7.1.4 Data Entry and Maintenance WG NAN / PT ES proposes that each designated contact point would nominate a focal point and, if agreed, a backup PSAP. The designated contact point would have responsibility for the initial database entry and ongoing updates as required. The ECO would not accept any responsibility or liability for the accuracy of the information contained in PSAP-DB and this would be stipulated in the conditions of use. Each time the database is updated, every user of the database will receive an update notification as follows: "Dear <salutation><Firstname><Lastname>, Please be advised that the information contained in PSAP-DB for <country> has been updated by <designated contact point>. If you use an offline version of PSAP-DB for day-to-day operations then please update it now or at your earliest convenience. The ECO, as PSAP-DB host, does not accept any responsibility or liability for the accuracy of the information contained in PSAP-DB. The accuracy of the contact information for a designated PSAP is the sole responsibility of that designated PSAP. Secure access to PSAP-DB is available at <PSAP-DB URI> Kind regards PSAP-DB Administrator, ECO Contact details" 7.1.5 Protocol for Use and Contingency Plans If the project proceeds, it is recommended that the PSAP user community access PSAP-DB using the online interface at all times. This approach ensures that users can always be sure that the information obtained from PSAP-DB is up-to-date and it reduces the risk of unauthorised access to the information contained therein. However, as the provision of emergency services is an operation that needs to be available 24 hours per day, 365 days per year, a contingency needs to be put in place in the rare event that access to PSAP-DB is unavailable. The ECO can provide online availability over 95% of the time but it is not in a position to offer the gold standard of "five nines" availability i.e. "99.999%" availability where the downtime is less than 5.26 minutes per year. The cost of this would be prohibitive. Furthermore, the ECO has already received some feedback from PSAPs that have invested in their own bespoke operational systems and they envisage having a copy of PSAP-DB stored within these systems. Therefore, PSAP-DB will be designed to allow for an offline version of PSAP-DB to be generated. The user interface will allow a designated contact point to generate an offline copy. This offline copy can be made available in the following formats: Draft ECC REPORT <No> - Page 19 A .pdf file containing the information. This file will be "watermarked" with a unique reference number so that any subsequent sharing of the document which could cause a security breach can be traced back to the individual who created the offline copy. For PSAPs with their own purpose-built operational systems, a version of the information can be provided in .xml or.csv format. In each case described above, an authentication step will be required before downloading. A user must log in to PSAP-DB and click a button to request an offline download. An agreement will then be displayed that waives the ECO from any responsibility or liability for any breach of security, damage or loss arising from the creation of an offline version of PSAP-DB. The user will be required to accept the terms of the agreement before proceeding. Then the user will select a desired file format, manually enter their e-mail address and password and click OK. The screen will then display the following message: "Dear <salutation><Firstname ><Lastname>, You have generated an offline copy of PSAP-DB in <file format>. You will shortly receive an email with a secure link from which you can download the file. Given the sensitive nature of the information contained in this file please consider it as highly confidential and do not forward it to any other party. The ECO accepts no responsibility or liability for any breach of security, damage or loss arising from the creation, downloading, transferring or forwarding of this file. Kind regards PSAP-DB Administrator. Contact details" 7.1.6 Membership Management - Designated Focal PSAP Contact Points If the relevant authorities in a particular country decide that they want to participate in PSAP-DB they will need to notify the PSAP-DB administrator at the ECO. The ECO will need to be informed that a PSAP has been designated as the focal PSAP for that country and the name, address and contact information of a designated contact point will need to be provided to the ECO. The ECO will then make contact with the designated contact point and send a formal agreement that will need to be completed and returned with a signature. The purpose of the agreement is to provide clarity on the roles and responsibilities of both parties to the agreement (the designated focal PSAP and the ECO as database administrator) and to formally acknowledge those roles and responsibilities. The main issues that the agreement seeks to provide clarity on are: That the designated contact point will acknowledge that it is responsible for initially entering and then maintaining its own PSAP-DB entry for the duration of the agreement and that it accepts responsibility for the accuracy of the information contained in PSAP-DB for its own entry. That the ECO will acknowledge that it is responsible for hosting, securing and maintaining PSAP-DB and providing a secure interface for access to PSAP-DB for the user community. The agreement will also contain an explicit statement that the ECO will not accept any responsibility for the accuracy of the data contained in PSAP-DB. Upon receipt of the signed agreement, the ECO will then provide instructions on how to set up a user profile. When the user profile is set up, the designated contact point will receive an email to activate the account. Upon activation the designated contact point will be provided with a link to the PSAP-DB website where they can request membership of PSAP-DB. Upon receipt of the membership request, the ECO will accept the membership request and the designated contact point will be provided with another link allowing him to log in and set up a password. They will then have access to PSAP-DB and will be able to enter the contact information for the designated focal PSAP for which they have responsibility. Annex 3 contains a preliminary draft agreement for discussion within WG NAN / PT ES. 7.1.7 Membership Management - PSAP operatives Draft ECC REPORT <No> - Page 20 Any PSAP operative from a participating country in Europe should be able to use PSAP-DB and the ECO will require that every PSAP operative has a unique user profile. This will allow the ECO, as PSAP-DB administrator, to maintain a record of all interactions with PSAP-DB. In order to gain access to PSAP-DB, a PSAP operative will need to go to the PSAP-DB website, set up a user profile and request access. The access request will be sent to the focal PSAP contact point in the same country and the focal PSAP contact point will have discretion on whether or not to grant access. The ECO will accept no responsibility for such decisions. When a membership request is accepted, the PSAP operative will receive an email with an activation link. Before activating the account, the PSAP operative will be required to accept a user agreement that sets out the roles and responsibilities of the ECO, as PSAP-DB administrator, and the PSAP operative as a PSAPDB user. When the agreement is accepted, the account can be activated. The ECO and the primary contact point in the relevant country will then receive an email acknowledging this. 7.2 RESOURCE COMMITMENT Undertaking the design, development, hosting and ongoing maintenance of PSAP-DB will require a financial and human resource commitment from the ECO. Any resource commitment must be approved by the ECO Council. 7.2.1 Financial Commitment Section 6.1 provides a conceptual level overview of how PSAP-DB would be structured and how it would work. As the design and structure will be based on an existing template it is expected that the initial IT development costs will be minimal. Table 2 below provides an overview of the estimated costs. External IT Development Costs Year 1 (year ended 2016) 3 days development 25,000DKK (Approx €3355) External IT Development Costs Year 2 (year ended 2017) 3 days development 25,000DKK (Approx €3355) Table 2: Estimation of PSAP-DB development costs for Years 1 and 2. If the approval process goes according to schedule, then year 1 will be 2016 and expenditure is not likely to happen until the second half of the year. The ECO Council has already approved the budget for Year 1 expenditure on PSAP-DB at its meeting December 2015 subject to WG NaN's decision on whether or not to proceed. . In subsequent years, and depending on feedback from the user community, a small budgetary provision may be set aside to develop improvements and enhancements if needed. In such cases, budgetary approval would be sought for specific enhancements to the system on a case-by-case basis. 7.2.2 Human Resource Commitment by ECO The ECO estimates that it will need to commit the following resources to the development and maintenance of PSAP-DB. ECO - Expert commitment - Year 1 (year ended 2016) 15 person days ECO - Expert commitment - Year 2 (year ended 2017) 15 person days ECO - Administrative commitment - Year 1 (year ended 2016) 5 person days ECO - Administrative commitment - Year 2 (year ended 2017) 5 person days Table 2: Estimation of human resource commitment to PSAP-DB for Years 1 and 2. Draft ECC REPORT <No> - Page 21 Some of the tasks involved are likely to include: Liaison with the PSAP user community and WG NAN / PT ES, through participation in the Steering Comittee, to define requirements, conditions of use and operational procedures. Work closely with the IT developers to design the system based on the requirements specification agreed with the PSAP user community and WG NAN / PT ES. Maintain communications with EENA, through the Steering Comittee, on progress and develop a migration plan. Liaise with the emergency services authorities who will nominate focal PSAPs in the respective countries and follow-up with focal PSAP contact points to set up accounts so that the initial contact information can be inserted into the database. It is expected that most of the administrative commitment will be dedicated to this task. System and user interface testing. Work with the Steering Comittee to identify training needs and implement a training plan. Implement the migration plan and go live with PSAP-DB. Monitor activity closely during the initial period. When PSAP.net is operational and stable the human resource commitment will decrease significantly and the ECO support will be mainly administrative and IT/technical and can be attributed to the support commitment dedicated for WG NaN administrative support and for general IT support. It is estimated that 3/5 person days of expert support would need to be assigned for Steering Comittee activities and this would be reviewed on an annual basis. Draft ECC REPORT <No> - Page 22 8 LEGAL ISSUES Chapter 6 provided a preliminary overview of how PSAP-DB could be structured and accessed. The database and associated access procedures will, by design, seek to protect the ECO from any liability arising out of any external misuse or breach of confidentiality. As database hosts, the ECO will have a responsibility for securing the database from unauthorised access. This chapter identifies the legal issues associated with an ECO-hosted database and proposes measures to address those issues. 8.1 LEGAL FRAMEWORK The legal basis and framework for the rights and obligations for the use of PSAP-DB would be the underlying contracts between ECO and the PSAP-DB users (PSAP operatives and focal PSAPs/registrants). These contracts would consist of the individual legal expressions of intent such as of the offer and the subsequent acceptance, which if aligned forms a contract. Practically speaking, the offer would be the declaration of PSAP-DB-terms presented to the user and the acceptance would be the signing or clicking of the acceptance of these terms. PSAP-DB would be a tool that could be used by PSAPs in 48 European countries. Therefore, there is no single national statute or regulation that would stipulate the information security obligations of either the database host or the contracting parties. The users must accept the level of security etc. described in the contract. The contract could e.g. describe a "reasonable" and "appropriate" security level to protect from unauthorised access to PSAP-DB. The same legal foundation would impose a duty of care to PSAP-DB users not to disclose passwords or protected information to third parties. It will be up to the users of PSAPDB to decide if they want to conclude the contract and thereby accepting the described level of security or not. With regards to the level of security it is uncommon that any legal requirement would dictate what measures are required to achieve "reasonable" and "appropriate" security. In the case of PSAP-DB, the ECO, as database host, would need to identify any risks and, in conjunction with the Steering Comittee, assess those risks and implement appropriate security measures in response to those risks. Any security measures would have to be effectively implemented and updated in response to new developments. The process would then need to be repeated periodically. It should be described in the terms that each participating PSAP would need to implement protocols of use as recommended by the steering committee. For example, when a PSAP employee retires, resigns or is dismissed it will need to notify the PSAP-DB administrator immediately so that the employee's PSAP-DB account can be deleted. 8.2 THE ROLE OF THE STEERING COMITTEE WG NaN / PT ES considers that the Steering Comittee would play an important role in dealing with any potential legal issues that could arise between stakeholders participating in PSAP-DB. Apart from its role in advising the ECO on terms and conditions of access and protocols for use, it would be the main forum for mediating in and arbitrating on any potential legal issues that could arise. If the Steering Comittee works effectively then the overall risk of legal arbitration proceedings taking place between participating parties is greatly reduced. 8.3 DISPUTE RESOLUTION PROCESS Breach of contractual duties will be handled as the contract describes. The terms can state that any disputes should be brought to the Steering Comittee for mediation. If it is not solved there, the case could be solved through an extrajudicial dispute resolution process. The terms should also explain available sanctions against users, such as refusal of access, due to breach of terms. Draft ECC REPORT <No> - Page 23 Due to the contractual descriptions in the PSAP-DB terms, there would be no risk of judicial court actions against ECO. The Any conflicts would follow the path of mediation in the Steering Comittee and a subsequent extrajudicial arbitration process if necessary. The contract/terms would also describe that ECO cannot be held economically liable for any claim, also claims stemming unauthorised access. 8.4 POTENTIAL SCENARIOS WHERE LEGAL ISSUES COULD ARISE The following sections now aim to identify the potential risks, assess the probability and impact of those risks, and propose appropriate measures to mitigate those risks. 8.4.1 8.4.1.1 Unauthorised Access to PSAP-DB Data Responsible Party The ECO, as database host, would assume responsibility for securing access to PSAP-DB as part of its IT infrastructure. The ECO hosts a number of different IT tools and services and manages membership for all registered CEPT users on its IT infrastructure, as explained in Chapter 4. The ECO has implemented technologies and procedures to ensure appropriate levels of security to protect from unauthorised access such as hacking. The ECO will ensure that the PSAP-DB data is stored in an encrypted format and that the latest security updates has been applied to its firewall. 8.4.1.2 Probability and Impact Probability of unauthorised access: Low The impact of unauthorised access: Medium WG NaN/PT ES considers that the ECO's IT infrastructure is reasonably and appropriately secured and monitors its arrangements on an ongoing basis. WG NaN / PT ES would consider the impact of unauthorised access to PSAP-DB as medium. If contact information for all European PSAPs became public through a security breach it would mean that PSAPs could be contacted on a different number from the normal advertised emergency services numbers. This would not be a desirable situation but those numbers could be changed very quickly so the impact would only last for a short while and procedures could be implemented to lessen the impact. For example, if the ECO became aware of a security breach it could immediately notify all participating PSAPs and a procedure should be invoked to block access to and then change all contact information with immediate effect. PSAPs already have confidential E.164 long form numbers, for example for contact with police, ambulance, fire brigade, coast guard and PSAPs in other countries with whom they have bilateral agreements. Anecdotal information suggests that this type of breach is not entirely uncommon at the national level and many PSAPs already have measures in place to change telephone numbers when necessary. In the event of unauthorised use of a valid PSAP-DB user account the probability and impact are the same. If such an event arose, an investigation would need to be carried out to determine which account was used and how the account details were compromised. For example, if a user account was not deleted following the retirement, resignation or dismissal of a PSAP employee or if the username and password of a valid account was shared or made publicly available in some way. The ECO considers this as the greatest single threat to unauthorised access and a protocol for deleting the accounts of former PSAP employees would need to be agreed by the Steering Comittee and implemented. The responsibility for notifying the PSAP-DB administrator will rest with the relevant PSAP. 8.4.1.3 Risk of Conflicts arising from Unauthorised Access WG NaN / PT ES would consider the risk of conflicts arising due to unauthorised access as being low. There has not been such conflicts regarding the other systems ECO is responsible for. It will however be important that that PSAP-DB has implemented appropriate security controls in response to the assessed risk. This is a matter that WG NaN / PT ES would consider as being appropriate for discussion with the Steering Comittee. Draft ECC REPORT <No> - Page 24 The risk of conflicts arising between individual PSAPs for not securing confidentiality would also be low. Even if such a situation arose, it is something that would need to be addressed by the Steering Comittee in the first instance so it is unlikely that the situation would deteriorate to a level where arbitration proceedings would be necessary. In any case, any subsequent legal action for breach of employment rules would be between the former employee and the concerned PSAP for any damage caused. 8.4.2 8.4.2.1 Corruption, Loss or Unavailability of PSAP-DB Responsible Party The ECO, as database host, would assume responsibility for the maintenance of the database and underlying IT infrastructure. The ECO already has standard procedures in place for backing up its data and the backup tapes are stored offsite. 8.4.2.2 Probability and Impact Probability of corruption, loss or unavailability of PSAP-DB: Low Impact of corruption, loss or unavailability of PSAP-DB: Low The ECO's raison d'etre is to support the work of the CEPT and its subordinated business committees and its IT infrastructure, tools and services are vital components of that support. The ECO therefore has appropriate disaster recovery plans in place so that it can maintain its operations in the event of unforeseen circumstances. The ECO would consider the impact of corruption, loss or unavailability of PSAP-DB as low. Apart from the ECO's own contingency plans, there will be an offline version of PSAP-DB available to the participating PSAPs in the event that PSAP-DB is inaccessible or unavailable. The ECO can provide online availability over 95% of the time but it is not in a position to offer the gold standard of "five nines" availability i.e. "99.999%" availability where the downtime is less than 5.26 minutes per year. The cost of this would be prohibitive. Nevertheless, the offline version may be used by the participating PSAPs until the online system is restored. There would be one limitation which is that updates to PSAP-DB would not be available during downtime. However, given that the contact information for a PSAP is quite static in nature, the impact of this limitation is extremely low and a process for manual updates could be implemented if the downtime duration was longer than anticipated. 8.4.3 8.4.3.1 Unauthorised Access to an Offline Version of PSAP-DB Responsible party WG NaN / PT ES understands that the ECO, as database host, would make available a facility to download an offline version of PSAP-DB. This facility serves two purposes. Firstly, to facilitate those PSAPs who wish to upload a copy of PSAP-DB to their bespoke operational systems and, secondly, to ensure that PSAP-DB can be used in the event that online access to PSAP-DB is restricted or unavailable. 8.4.3.2 Probability and Impact Probability of unauthorised access to an offline version of PSAP-DB: Medium Impact of unauthorised access to an offline version of PSAP-DB: Medium WG NaN / PT ES considers the impact of unauthorised access to an offline version of PSAP-DB to be the same as the impact of unauthorised access to the online system. However, the probability is considered to be higher as central control is lost and the responsibility for maintaining security and confidentiality is transferred to any authorised user who creates an offline version. WG NaN / PT ES understands that the ECO has already considered this from a system design perspective and an audit trail would be built-in to the Draft ECC REPORT <No> - Page 25 system. According to terms of conditions, the responsibility and liability for confidentiality and security will be transferred to the PSAP-DB user when an offline version of PSAP-DB is generated. In the case that an offline version is provided to an external third party (or made public) with deliberate or malicious intent then the ECO, after advise from the Steering Comittee, can block a user for using the PSAP-DB Furthermore, any designated contact point wishing to create an offline version will accept the terms and conditions of a user agreement which will transfer responsibility and liability for confidentiality and security to that party. . Editor's Note 1: Are there other scenarios not covered above? Draft ECC REPORT <No> - Page 26 9 IMPACT ASSESSMENT At the 9th meeting of WG NaN, which took place in Oslo on 22-23 October 2014, the topic was discussed and considered. The following is an extract taken from the meeting minutes which provides a summary of the discussion: "WG NaN is in principle supportive of the initiative but advises to proceed with caution. PT ES will study the matter and report back to WG NaN on the legal and practical issues (e.g. liability) of hosting such a database including providing clarity on the expected impact (responsibility) on NRAs , Ministries and PSAPs and ECO." The 40th ECC Plenary meeting, which took place in Helsinki on 30 June – 3rd July 2015, also discussed the PSAP-DB feasibility study. The following is an extract from the meeting minutes: "Discussion followed on the Project Team Emergency Services (PT ES) work item relating to the request received from the non-Governmental European Emergency Number Association (EENA) for the transfer of the database of transnational emergency calls to European Public Safety Answering Points (PSAP). PT ES has begun work to consider the possibility of ECC/ECO hosting the database of PSAP contact information. Subsequent to the concerns raised by the administrations of Portugal and Germany, the meeting discussed whether such a database would fall within the responsibility of ECC/WG NaN/PT ES according to their terms of reference. The legal issues associated with the transfer of the database, including its terms, conditions and costs, as well as the need to understand the level of support (including from the European Commission) for this initiative were also raised. The legal issues will be addressed in the "feasibility study" carried out by WG NaN. ECC also tasked WG NaN to examine whether the hosting of such a database would fall within its terms of reference as part of its analysis. It was agreed that WG NaN would report on the result of such analysis at the next ECC Plenary meeting." Both the WG NaN and the ECC plenary raised concerns about the impact of an ECO-hosted database on the involved stakeholders. This chapter now considers the potential impact. 9.1 IMPACT ON CEPT ADMINISTRATIONS (NATIONAL NRAS/MINISTRIES) The proposal for PSAP-DB envisages that the service would be provided on a voluntary basis as it is not possible to mandate participation via an ECC deliverable as not all CEPT administrations have responsibility for emergency services. Therefore there is no impact in terms of implementing an ECC deliverable at the national level. The impact on CEPT administrations would mainly be confined to discussions within the ECC plenary, WG NaN, and PT ES in terms of considering the ECC framework decision that would formalise ECC support for an ECO-hosted database. The impact is therefore related to a PT ES work item and the resource commitment required by the participating CEPT/ECC delegates and the preparation of any subsequent response to the public consultation on that draft Decision. There would also be a further ongoing impact in terms of the national administration's participation in the proposed Steering Comittee. However, participation in this forum is envisaged as being voluntary. In conclusion, WG NaN / PT ES considers that the impact on CEPT administrations is low as the role of the administrations is mainly limited to the development of the policy framework. There is also no impact at the national level in terms of having to implement an ECC Decision. 9.2 IMPACT ON ECC/WG NAN The impact on WG NaN is also reserved to the consideration of the policy framework if it decides to proceed with the project. There is also a resource impact in terms of the participation of the WG NaN and PT ES delegates in the proposed Steering Comittee. The overall impact on ECC/WG NaN is deemed to be low. Draft ECC REPORT <No> - Page 27 9.3 IMPACT ON THE ECO The impact on the ECO is higher than on other stakeholders as it will be involved in developing the policy framework as well as committing financial and human resources for the development and maintenance of PSAP-DB. As the permanent office of the CEPT, the ECO has the competence and experience to carry out this function subject to approval by WG NaN, the ECC Plenary and the ECO Council for budgetary approval. The overall impact on the ECO is deemed to be medium. 9.4 IMPACT ON PSAPS The responses received to the PT ES questionnaire discussed in Chapter 2 demonstrate support for PSAPDB. The overwhelming majority of respondents to Question 8 (28 responses) consider that PSAP-DB would not have a negative impact on their day-to-day operations while 31 respondents to Question 2 considered that PSAP-DB would help them to carry out their work more effectively. As the service is proposed to be provided free of charge, the financial impact is minimal and is limited to covering the cost of any training needs that arise from using PSAP-DB as well as the cost of calling PSAPs in other countries. The financial and human resource commitment for PSAP representatives willing to participate in the Steering Comittee will be higher but it should be noted that 18 PSAP organisations indicated their willingness to participate in drafting terms and conditions of access and use. The overall impact on PSAPs is deemed to be low. 9.5 IMPACT ON THE PROVISION OF EMERGENCY SERVICES IN EUROPE It is difficult to quantify the benefits of PSAP-DB at this stage but the ultimate benefit of facilitating inter-PSAP communications is the provision of more effective services quickly. If the project does proceed, it will be necessary to gather statistics on the use of PSAP-DB in the future to assess its effectiveness but even at this stage in the process it is possible to speculate that the impact on the provision of emergency services in Europe will be positive. The overall positive impact on the provision of emergency services in Europe is likely to be high. Draft ECC REPORT <No> - Page 28 10 CONCLUSIONS The level of interest and support from European PSAPs in an ECO-hosted PSAP-DB justifies the need for preparing a Feasibility Study on this subject. Subject to approval by WG NaN, the ECC Plenary and ECO Council, the ECO has the resources, competence and experience to develop and maintain PSAP-DB and the impact assessment demonstrates that the burden of providing the service is manageable and will fall mainly on the ECO. Committing resources to the development of a policy framework that would provide formal support for an ECO-hosted PSAP-DB is a relevant activity for the ECC and is in accordance with the ECC Strategic Plan. The costs of developing and maintaining PSAP-DB are set out in this report and the ECO is confident that it can develop and maintain PSAP-DB in a cost-effective manner by leveraging its existing IT systems and its support commitment to the work of the ECC. As the service is provided on a voluntary basis and is overseen by a Steering Comittee, the probability of conflicts arising between participating parties is considered to be low. Furthermore, the impact on the CEPT administrations is also expected to be low as there is no formal policy implementation required at the national level. The impact assessment in Chapter 8 demonstrated that the overall impact of PSAP-DB is expected to be positive. Draft ECC REPORT <No> - Page 29 11 DECISION OF WG NAN BASED ON THE CONCLUSIONS OF THE FEASIBILITY STUDY For discussion at PT ES and WG NaN Draft ECC REPORT <No> - Page 30 ANNEX 1: EENA LETTER Draft ECC REPORT <No> - Page 31 Draft ECC REPORT <No> - Page 32 ANNEX 2: DRAFT ECC FRAMEWORK DECISION INTRODUCTION 112 is the pan-European emergency services number to request emergency assistance from police, fire or medical personnel anywhere in the European Union. As Europe is becoming an increasingly integrated continent with an increasing number of citizens frequently travelling between different countries it is essential that the emergency call answering services can coordinate emergency assistance to calls that could be made in one country but where the emergency assistance is required in another country. These types of calls are known as transnational emergency calls and can occur in cases where an emergency caller inadvertently roams onto a foreign network and where the emergency call is made to request assistance for a citizen in another country. Other examples also exist where cross-border co-operation is required. BACKGROUND To facilitate these types of calls protocols and procedures must be in place to allow public safety answering points (PSAPs) to effectively communicate with each other right across the continent. This requires communication, coordination and a harmonised approach. The ECC considers and develops policies on electronic communications activities in a European context, taking account of European and international legislation and regulations. In recent years, the ECC has played an active role in facilitating more effective emergency communications in Europe through the development of appropriate policies on spectrum use, harmonisation of numbering resources and the provision of accurate and reliable caller location information. Supporting transnational emergency calls is another area where it can add value. REQUIREMENT FOR AN ECC DECISION An ECC Decision is required to provide a facility, on a voluntary basis, to the European Emergency Services Community to facilitate, support and coordinate transnational emergency calls. This facility consists of a database, developed and maintained by the European Communications Office (ECO) in consultation with the relevant ECC working groups and project teams, containing contact information for all European PSAPs and an agreed set of procedures for accessing, updating and communicating information contained therein to the relevant stakeholders. For the purposes of this ECC Decision, this facility is referred to as PSAP-DB. ECC Decision of dd month 2016 on Supporting transnational 112 emergency calls in Europe (decision no (16)xx) “The European Conference of Postal and Telecommunications Administrations, CONSIDERING that CEPT administrations, the emergency services community and the European Commission have expressed an interest in having a database containing contact information to support transnational emergency calls in Europe. that PSAP-DB has been designed to fulfill this requirement; that PSAP-DB is provided by the ECC as a facility, on a voluntary basis, to the European Emergency Services Community; that the contact information contained in PSAP-DB may only be used by European PSAPs to facilitate communications between the European PSAP community to support inter-PSAP communications. that for PSAP-DB to be successful CEPT administrations must encourage emergency services authorities in their respective countries to support PSAP-DB by providing and maintaining up-to-date contact information on the PSAPs located in their national territories; that the information contained in PSAP-DB is confidential in nature and appropriate safeguards must be put in place to maintain confidentiality. Draft ECC REPORT <No> - Page 33 the decision taken at the xx meeting of the ECO Council to make available the necessary resources within ECO in order to fulfil the tasks required under this Decision; that there is a need to nominate at least one contact person within each PSAP for the maintenance of the PSAP contact information; that there is a need for a Steering Comittee to be established that consists of representatives of all stakeholders in order to establish protocols for access and use of PSAP-DB; that the future development of PSAP-DB should take into account any future decisions or regulations mandating the establishment of a database to support transnational emergency calls to 112 that not all CEPT administrations have competence in the area of emergency services communications at the national level; that there is considerable difference in how PSAPs are structured, managed and governed in each country that CEPT countries outside of the European Union have also implemented the pan-European emergency services number 112; that there is a need to limit the amount of resources needed to update and maintain PSAP-DB as far as possible; that CEPT, the ECC and the European Communications Office (ECO) assume no responsibility for the accuracy of the information provided to PSAP-DB. The accuracy of the information is the responsibility of each individual PSAP. that in no event shall the CEPT, ECC or the ECO be liable for any direct, indirect, special or incidental damage resulting from, arising out of or in connection with the use or availability of the information contained in PSAP-DB. DECIDES that CEPT Administrations shall encourage the Emergency Services Authorities in their respective countries to provide and maintain up-to-date contact information to PSAP-DB for the PSAPs located in their national territories; that PSAPs should be encouraged to provide and maintain the following information in PSAP-DB for the PSAPs in their countries: Name, address, primary telephone number, backup telephone number, primary contact person, backup contact person etc, etc, etc that the ECO shall develop and maintain the PSAP-DB in accordance with agreements reached in the ECC and the ECO Council and shall ensure a reasonable and acceptable level of service availability. that CEPT administrations shall communicate the national measures implementing this Decision to the ECC Chairman and the Office when this ECC Decision is nationally implemented.” that the ECO, in consultation with the PSAPs through the Steering Comittee, shall coordinate PSAP-DB training and access for national representatives of the emergency services community that this Decision shall enter into force on ddmmyyy Note: Please check the Office documentation database http://www.ecodocdb.dk for the up to date position on the implementation of this and other ECC Decisions. Draft ECC REPORT <No> - Page 34 ANNEX 3: DRAFT AGREEMENT BETWEEN ECO AND PARTICIPATING FOCAL PSAP To be returned to [email protected] by email (signed and scanned) Template and logo of the organisation Dear PSAP-DB administrator, I have read the PSAP-DB user agreement and conditions of use and I hereby acknowledge my agreement with same. Please be advised that I represent <PSAP-Name> and it has , after consultation with the relevant authorities at the national level, been designated as the primary PSAP for <Country> and it commits to providing and maintaining contact information in PSAP-DB. <PSAP-Name> commits to using PSAP-DB to facilitate inter-PSAP communications in Europe in accordance with the terms and conditions of use and <PSAP-Name> hereby agrees and commits to train its call takers and dispatchers and make sure that they recognise the calls made using PSAP-DB to ensure an appropriate response and a full time availability of English speaking call-takers when contacted by other PSAPs. <PSAP-Name> understands that the ECO cannot be held responsible or liable for any misuse of PSAP-DB nor any damage caused by breach of security, damage or loss arising from the creation, downloading, transferring or forwarding of offline versions of PSAP-DB. <PSAP-Name> commits not to share the database with any unauthorised third parties. The ECO and the PSAPs participating in PSAP-DB reserve the right to take legal action. <PSAP-Name> nominates <Contact 1> and <Contact 2> as the primary and secondary contact points for PSAP-DB. First Name: Surname: Position: Organisation: Telephone and email: Place and date Signature Stamp Editor's Note 2: Editor's Note 3: Elements: Editor's Note 4: Int the terms it should be described: Editor's Note 5: Service description: Facilitate exchange of information, voluntary, best effort Editor's Note 6: Disclaimers against liability, errorous data, loss of service etc. Editor's Note 7: Rights and duties: Procedures, how/who/when to upload and maintain and Duty to download for backup Draft ECC REPORT <No> - Page 35 Editor's Note 8: Access control elements Editor's Note 9: *to database, prohibition for third party usage Editor's Note 10: *to register/upload information Editor's Note 11: *third parties Editor's Note 12: Confidentiality clause Editor's Note 13: Sanctions and exclusion from database Editor's Note 14: Mediation process and extrajudicial dispute resolution clause. Editor's Note 15: Contractual inclusion of CEPT ECC deliverables Editor's Note 16: Right to monitor/retrieve statistical information on usage Editor's Note 17: Contractual description of revision process of terms and conditions Editor's Note 18: Inclusion of rights and procedures for ECO to shut down database Editor's Note 19: Other issues that WE WANT TO ENSURE?
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