The introduction by the DTI of “digitally signed” consents and approvals
In 2003 we reported that the Oil and Gas Directorate was consulting on the use of digital signatures. The results of that consultation were broadly positive and the DTI is therefore proceeding with its plans to issue electronically consents and approvals for operations within the United Kingdom Continental Shelf. This represents part of the DTI's contribution to a wider Government initiative to make all government services available electronically by 2005.
The UK Oil Portal is at the heart of the DTI’s proposals. It is a web-based interactive portal and is the first such system for any oil regulatory body around the world. The UK Oil Portal will deliver consents in the form of digitally signed electronic files. The benefits of such a system are significant to both the Government and the oil companies. The timeframe between applications and obtaining approvals will be significantly reduced, as will the need for physical documentation to be stored, since the UK Oil Portal also comprises a document management system which will store documents in a form that allows them to be used as legally admissible evidence.
Earlier this month, the DTI, together with LOGIC, launched the Oil and Gas Trust Scheme
for issuing digital certificates. This will be managed by LOGIC, backed up by a small team that initially will include the DTI and UKOOA.
A digital signature performs the same function as a manual signature by (i) providing “authenticity” that the electronic communication has come from whom it purports to come from; and (ii) establishing “integrity” that the electronic communication has not been altered or tampered with in any way. A digital certificate is required in order to be able to digitally sign a document.
The DTI have developed a set of Trust Rules which define the criteria for approval of Trust Service Providers (TSPs) who are the organisations which will issue digital certificates to oil companies. A number of companies have already been approved to issue digital certificates to the oil and gas oil industry.
The rules been developed in accordance with the following industry requirements:
- No undue burden on TSPs provided they follow industry and legislative best practice, nor on users.
- Simple and low cost to administer.
- Use of standards that already exist that are fit for purpose.
- Capable of application to the global industry.
- No proprietary technologies or specific providers specified.
- Reliance must not be placed on any one single provider to protect against the failure of a TSP or scheme.
- Meets UK government requirements.
Following the consultation process the DTI and a number of oil companies have been running a number of pilot systems - the aim was to develop a low cost solution to the use of digital certificates, one that has applicability outside of regulatory reporting and one that is not UK specific.
The first use of digital certificates has already begun - the DTI now digitally sign environmental consents and notices using the UK Oil Portal. As the scheme develops, it will cover matters such as well operations, pipelines consents, production reporting and decommissioning notices and consents to licence assignments.
During 2005, the DTI will start to require submissions to government via the UK Oil Portal to be digitally signed. These will include such items as Annual Field Returns and emissions returns under the EEMS system. In due course it could also extend to licence applications. However, the scheme has been designed so that it is also capable of applying between individual operators and also between operators and suppliers and the hope is that it will gradually be used for many different applications within the industry.
For further details of the Oil & Gas Trust Scheme, please go to http://www.og.dti.gov.uk/portal_files/dig_trust.htm
For further information on digital signatures, please contact Judith Aldersey-Williams in the Aberdeen office on 01224 622002 or e-mail Judith.Aldersey-Williams@cms-cmck.com