The European Union's Article 29 Working Party published on April 11, 2011 an opinion on smart metering,  recommending Privacy by Design, data minimization, and consumer  interface options that give customers increased control over their data  and privacy settings.
The opinion indicates that most data collected by smart  meters will be considered "personal data" under the Data Protection  Directive because the data will be associated with a unique identifier  such as a meter identification number, which in turn can be linked to a  living individual. The opinion states that the "data controller" will in  most cases be the energy supplier, but that the grid operator may also  be controller, as may be the third party service provider (so-called  Energy Service Companies, or ESCOs). As mentioned in the Art 29 WP's opinion 1/2010 on data controllers and processors, it is not infrequent for there to be more than one controller.
Data  collected by smart meters may be processed based on consent, but the  opinion warns that consent must be made on a "fully-informed" basis. The  Art 29 WP recommends that the household control panel for smart meters  include a push button consent option to help consumers exercise their  consent options, and change the options over time. 
The opinion goes into considerable detail on some  issues, commenting for example that a smart meter with a small, text  only, user interface would provide consumers with insufficient access to  their own data, in particular to load graphs.  The opinion also  describes how the collection of data from the smart meter should be  minimized, for example by keeping load graph data within the smart meter  until the data actually needed by the energy supplier.  Many of the  recommendations resemble existing practices in the telecoms industry for  the handling of traffic data and location data.  For example, smart  meter data should be deleted as soon as they are no longer  needed. Controllers should develop written policies on data retention  and evaluate each purpose for which smart data are needed and ensure  that only the minimum data necessary for that purpose are retained,  while other data are deleted. For example, some customers may request  historic year-to-year consumption comparisons. For those customers, and  those customers only, the controller may retain historic consumption  data.
The opinion strongly recommends the implementation of  Privacy by Design, including privacy impact assessments, security and  privacy audits.
 
 
 









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