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Privacy of Customer Energy Usage Data: Protecting Consumers and Giving Them the Tools with which to Protect Themselves. Aryeh B. Fishman Director, Regulatory Legal Affairs Edison Electric Institute. A few basic questions. Why are we talking about privacy? Why do we care?
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Privacy of Customer Energy Usage Data: Protecting Consumers and Giving Them the Tools with which to Protect Themselves Aryeh B. FishmanDirector, Regulatory Legal AffairsEdison Electric Institute
A few basic questions • Why are we talking about privacy? Why do we care? • What has really changed because of Smart Grid technologies? • Do laws and regulations need to change?
Utilities care about privacy • Developed data access and privacy guidelines CEOs • Organized and engaged CIO EAC on these issues • Submitted comments in DOE proceeding on data access • Participated in SGIP CSWG Privacy Subgroup activities • Worked to shape NAESB model business practices (REQ.22) • Engaged White House Office of Science Technology Policy (OSTP) & DOE on these issues
Is SG technology really a game changer for privacy? • Digital meters collect customer energy usage data – same type of data, but different frequency of collection. • What prevents existing law/regulations from being applied to this situation? • utilities • 3rd parties
Key issues • How to safeguard data and maintain customer trust and satisfaction while allowing for innovation? • How to avoid “recommended” policies and practices that may increase costs? • Would a federal regime for enforcing codes of conduct on privacy practices help?
Particular concerns • Individual control • Transparency • Authorization/verification • Security • Access and accuracy • Accountability
Current situation • White House Green Button initiative • DOE survey and map illustrating utility data access policies and practices • NIST-SGIP Privacy Subgroup efforts to develop 3rd party best practices and NAESB REQ.22 gap analysis • White House Consumer Privacy Bill of Rights • Multi-stakeholder process to develop and implement enforceable codes of conduct
EEI going forward • Continue participating in NIST-SGIP and NAESB efforts on data access and privacy • Revisit EEI data access and privacy guidelines with Members • Help shape direction of Consumer Bill of Privacy initiative • Help determine forum for electric industry • Preserve reasonable flexibility for compliance with codes of conduct • Outreach to States and consumer advocates • Consider working with Future of Privacy Forum on its Smart Grid consumer privacy seal program