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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
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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?
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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
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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
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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?
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Particular concerns Individual control Transparency Authorization/verification Security Access and accuracy Accountability
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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
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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
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