The Working Group’s recommendations:
- Electricity consumption data should be treated as Personal Information, because it can be traced back to an individual person. Europeans treat Personal Information very seriously, sometimes arguably at the expense of technological innovation.
- Push-button consent: the Working Group recommends that Smart Meter providers develop easy buttons that consumers can push to grant or remove consent that their data be shared with anyone who seeks to offer them enhanced services.
- The social good is not always the primary consideration. “The imperative to reduce energy consumption,” writes the Working Group, “although it might be a sensible public policy objective, does not override data subjects’ rights and interests in every case.”
- Personal data collected should be kept to a minimum as required to fulfill services offered – and be deleted as soon as possible except in cases where the electricity consumer has requested services like annual comparisons of consumption.
- Privacy by Design: “Security should also be designed in at the early stage as part of the architecture of the network rather than added on later.”
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