Privacy of Customer Energy Usage Data Protecting Consumers

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? › 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 › 3 rd 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 3 rd 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