EU Article 29 Working Party Criticises The Proposed Data Protection Impact Assessment Templates For Smart-Meters

Author:Ms Cynthia O'Donoghue
Profession:Reed Smith

The Article 29 Working Party (A29WP) adopted the Opinion on Data Protection Impact Template Assessment for Smart Grid and Smart Metering Systems (Opinion), which evaluates the Privacy Impact Assessment (PIA) template that the member states intend to adopt. The PIA, which was prepared by industry representatives, seeks to ensure that smart-meter operators comply with data protection rules; however, the A29WP pointed out a number of inadequacies in the template. The EU initiative to roll out smart gas and electricity meters, which can send usage data via remote communications, underpins the desire for a more effective and efficient energy supply. In the Opinion, the A29WP points out the risk that smart-meter usage data may be used to infer information about "consumers' use of specific goods or devices, daily routines, living arrangements, activities, lifestyles and behaviour." The energy supply industry expert group developed the PIA to ensure that smart-meter operators comply with data protection rules, and to facilitate compliance assessments by Data Protection Authorities, as well as to provide information to consumers. The PIA template contains an eight-step impact assessment and provides step-by-step guidance on how to carry it out. The A29WP...

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