The Need for a Consumer Privacy Seal
- Third party access to consumer energy data enables a wide range of benefits, but also raises legitimate concerns
- Responsible companies that provide exciting new products and services such as home security, smart appliances, remote home management will generate positive consumer interest and help advance consumer engagement with energy management, demand response and smart meters.
- It is essential that a flexible framework exists that ensures consumer privacy protections are in place and that responsible businesses can responsibly access the data needed to serve consumers.
- Risk to utilities, consumers if inadequate process for obtaining consumer permission
- Risk to consumer engagement and innovation if consent process is burdensome and ineffective
- Utilities must be confident that third parties that access consumer energy data directly from utilities or via smart meters do so with the permission of consumers and in accord with responsible privacy standards.
- Regulatory requirements and vendor due diligence will play a lead role, but are unlikely to suffice to provide oversight for the wide range of services that consumers will be seeking to enable.
- A third party privacy seal program can play an essential role in this ecosystem by vetting the privacy standards of third parties and by providing assurance to utilities, regulators and consumers that companies are in compliance with responsible standards. A third party seal can also provide consumers with an avenue for complaint handling and resolution and provide regulators with a supplement to their efforts to ensure consumers are protected.
What is the FPF Smart Grid Seal?
- Privacy seal based on best practices
- Covers:
- Data collected directly from consumers by smart devices (i.e. home security systems that seek to access consumer energy data, smart appliances, etc.)
- Data collected by third parties a) directly from a smart meter, b) provided to a third party by a utility or c) utility data provided by a consumer to a third party.
- Goals:
- Ensure consumer trust in smart devices
- Assist utilities in vetting 3rd parties
- Allow for a standard consent process to be used across many states
What the Seal does NOT Cover
- Is not a standard for utilities
- Does not cover utility collection or use of data for billing, operations, demand response, etc.