FISD Guideline: General Principles of Datafeed Reporting Access

Approved by the FISD Executive Committee

January 28, 1999

BACKGROUND

This Guideline arises from the recommendation of the FISD Working Group on Datafeed Reporting Access Declarations (DAD’s) on the need for an initial statement of general principles governing the content and use of datafeed reports DAD’s.

Vendors, Exchanges and Specialist Data Providers -- together referred to in this Guideline as Information Providers -- currently vary in the extent to which they specify datafeed reporting requirements and the ways they interpret datafeed reports for billing and other purposes. Differences in compliance requirements, policies relating to units of count and billing practices are progressively being documented by FISD identified and reconciled. The purpose of this Guideline is to provide a common framework for datafeed access reporting within which the details of best practice can be established and more efficient systems for reporting, billing and verification developed.

INTRODUCTION

For the purpose of this Guideline the datafeed report The Datafeed Access Declaration (DAD) is a representation by the Client -- i.e. end-user of information rather than subvendor or redistributor -- to the Information Providers whose information is delivered by a Vendor’s datafeed. It comprises a report identifying the number of accesses (devices or device equivalents) for which the Client is required to report in accordance with may be billed in accordance with the terms and conditions of the Information Providers contracts and, if required by contract, a certification by an authorized officer of the Client as to the completeness and accuracy of the report.

Because of the flexibility inherent in datafeed systems, Information Providers rely on Clients to manage, control and report on accesses to their Information -- and use datafeed reports DAD’s or equivalent documents as the basis for billing. Most Information Providers place the client under a contractual obligation to provide datafeed reports DAD’s. In some cases, Information Providers reserve the right to depermission Clients in the event that no datafeed report DAD is produced or the Information Provider has reason to believe the datafeed report DAD is incomplete or inaccurate.

• Information Providers should provide notes, guidance on specific obligations (e.g. when the reports should be returned) and reference data such as permissioning codes to help Clients complete the datafeed report DAD as quickly and efficiently as possible. (These notes and guidance materials may usefully be provided either with the report documentation or on Information Providers websites.)

• Where required by contract the datafeed report DAD should include separate totals for each Site (Site should also be defined by contract -it usually is taken to mean street address). The datafeed report DAD should be completed on a regular basis for contractually specified periods. It should set out the number of accesses authorized or allowed in accordance with Information Provider contract terms to view fee-liable information supplied via the Vendor’s datafeed, including Vendor services, information from Exchanges and Specialist Data services. The numbers reporting requirements mayed should also include accesses to information redistributed from other Client sites. The definition of access and the method of counting accesses for the purposes of the datafeed report DAD should be specified in the various agreements under which information is provided.

• The datafeed report DAD may should be limited to numbers of accesses for which service subscriptions or exchange fees are payable in accordance with contract, or may need to include plus other information required by contract, e.g. total device count, whether or not fees are payable. Clients should only not be required to report information that is not needed either for billing purposes or to meet other contractual requirements. The definition of items to be included in datafeed reports should be specified in the various agreements under which information is provided. If the report requires accesses to be entered that are not chargeable, steps should be taken to differentiate them from billable accesses.

• The Client may be obliged by contract to maintain effective internal control systems and procedures to support the information contained in any datafeed report DAD, and to identify the systems used for this purpose. The Client may be contractually liable for any additional fees arising from reporting errors and/or omissions.

• Datafeed Reports -- e.g. DAD’s -- sent by Clients to Vendors should cover Vendor services, Specialist Data services and indirect-billed Exchanges. Datafeed Reports to direct-billed Exchanges should be sent direct to the Exchanges -- or to exchange-designated facilities such as VARS -- and do not need to be included in datafeed reports DAD’s sent to Vendors.

• Certain Exchanges have policies designed to eliminate multiple billing of fees where data is provided via more than one Vendor, or to arrange credits or refunds in these circumstances. Unless otherwise specified, procedures for implementing these policies will be organized independently of the datafeed DAD reporting process. In particular, the Client should therefore include in the datafeed report DAD all accesses for indirect-billed Exchange data via each Vendor unless other procedures have been agreed with the Exchange.

• Failure to provide a timely and accurate datafeed report DAD may result in termination of data from the Client and/or other consequences specified by contract. Clients should be aware that Vendors may be contractually obliged by Information Providers to depermission those who have not provided timely and accurate reports.

• Information Providers dealing directly with Clients should establish clear and consistent practices in the event that a Client has not returned a datafeed report DAD, and ensure that these practices are communicated to Clients. Typical good practice recommendations may include:

• clear escalation paths and contact hierarchy
• three written warnings before depermissioning rights are exercisedfinal by recorded delivery/registered mail.

• Where an Information Provider has reason to believe a datafeed report DAD is incomplete or incorrect the Client may be requested to provide further information to support the datafeed report DAD declaration, or may be audited by the Information Provider Vendor or Exchange in accordance with the terms of their contract termss.

A typical datafeed report should contain:

• Client name, billing address and reference number
  
• Period of datafeed report DAD
  
• Name and address of each location covered by reporting obligations at which information can be viewed
  
• Overall number of accesses to fee-liable Information Provider data or services at each location information and vendor services at each location
  
• Number of accesses (during the period covered by the datafeed report DAD) for each Vendor, Exchange and Specialist Data Service at each Location.
  
• (Where required by contract) Declaration by an authorized officer that the numbers reported is complete and accurate in accordance with contractual requirements.
  
• Notes and guidance from the Information Provider to the Client and reference data such as permissioning codes, to help Client complete datafeed report DAD as clearly and quickly as possible.