If customers believe a utility is itself abusing personally identifiable data, or is generally enabling the use of personal information beyond what they deem acceptable (whether or not legal), then they are likely to resist the implementation of AMI. Consumers may refuse to consent (where required), hide their data or awaken political opposition. Utilities may face customer liability claims or regulatory fines if inadequate privacy or security practices enable eavesdroppers, adversaries or bad-actors to acquire and use AMI data to a customer’s detriment. Utilities must take privacy and security concerns into account when designing AMI and must persuade consumers, regulators and politicians that privacy interests are adequately protected.
The first step is to adopt appropriate privacy policies defining what data may be collected and their permissible uses, disclosing those practices clearly and conspicuously, and obtaining consents where required. Since AMI data differ qualitatively from what utilities collected in the past, they will likely need new and stronger privacy and security policies. Consumers are interested primarily in controlling what information is collected, who has access to it, and how it may be used. These interests are often described in fair information privacy practices or core principles, such as theOECD’s Guidelines on the Protection of Privacy and Transborder Flows of Personal Data.
Once a utility establishes the permissible uses of AMI data, it is in its interest to assure that unauthorized uses do not occur. For example, if an electricity service provider is allowed to sell appliance related data to a manufacturer or retailer, the utility will want to protect its economic interest by preventing access or use by others who might become competitive data brokers. Every utility will want to avoid regulatory sanctions for violating express or implied privacy policies as well as damages claims based on compromised customer data or facilities.
A policy that appropriately limits the use of collected data provides no consumer protection if the data can be accessed by unauthorized persons or can be used by authorized persons for unauthorized purposes. Thus the utility’s second step is to establish systems for enforcement of the policies and control of the data through adoption of suitable security practices, training and audits.