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APF Policy Statement re Smart Grids and Smart Meters


Background

The term 'Smart Grid' refers to a cluster of technologies that are intended to enable energy providers (particularly of electricity, but also gas) to gather real-time data about energy consumption, and thereby adapt energy prices and achieve greater energy efficiency, and greater profits. The measurements are not limited to the 'backbones' services, but extend all the way out to consumers' premises.

Promotional literature suggests that consumers are intended to be a primary beneficiary of Smart Grids. This is claimed to be by means of 'smart meters' and 'in-home displays', which are said to enable a significantly improved capability to achieve energy efficiency and thereby decrease consumers' costs. In practice, installing the necessary consumer-facing capabilities is expensive, the effort involved considerable, and the savings not all that substantial.

On the other hand, even a cursory examination reveals that the technologies involve surveillance of the activities of consumers, in real time, and the retention of data in order to enable comparison of current usage against prior usage patterns. Electrical usage patterns are capable of revealing a considerable amount of sensitive data about people, including occupied premises, premises that are currently unoccupied, empty premises, habitual behaviours, and even the use of individual devices.

This sensitive data is transmitted over networks, and gathered, stored, used and disclosed. Its initial use may be by organisations directly involved in energy supply, and perhaps only for purposes related to energy supply. The data is attractive, however, and will doubtless soon afterwards be applied to a range of other purposes, and passed to a range of other organisations.

Yet worse, the players in the game appear not to have any appreciation that Smart Grid technology could, and by default will, have such impacts. Important among the players are the following:

Given that market structure, perhaps it's less surprising that the players have no interest in the privacy of the people who pay the bills.

So do 'privacy watchdogs' play their role and bring the electricity suppliers, their technology providers, and the State and Territory governments into line? Unfortunately, no.

Privacy protections in Australia are lamentably weak. The private sector provisions in particular were designed to help business, not people. Privacy Commissioners generally have such limited powers that they can do little to assist the public, even if they want to. Recent federal Privacy Commissioners have shown willingness to protect business, but not to use even the limited powers that they have available to them in order to protect people.


The APF's Policy Position

1. Smart Grid technologies are potentially highly privacy-intrusive.

2. There is little evidence of the proponents of Smart Grid technologies giving consideration to personal data arising from smart grid operations.

3. There is no evidence of the proponents of Smart Grid technologies engaging with privacy advocacy organisations even in order to gain an appreciation of public concerns, let alone to collaboratively design systems so that they will achieve benefits without severely harming consumers' privacy.

4. As the public gradually becomes aware of the technologies' privacy-intrusiveness and the arrogance of the organisations that are imposing the technologies on consumers, there will be considerable backlash, probably sufficient to cause major financial losses for the organisations involved.

5. The APF expresses serious concern about the manner in which the technologies are being implemented.

6. The APF urges Australian, NSW, Victorian and Queensland Privacy Commissioners to take action to protect people's privacy in the face of 'smart grid' initiatives, and to indicate to proponents that it is essential that such projects be the subject of privacy impact assessments including consultation with consumer and privacy advocates on behalf of the public generally.

7. The APF draws attention to the inadequacy of relying on currently-available overseas publications in the area, including the highly business-friendly document NIST (2010), the more balanced document published by a Privacy Commissioner on behalf of industry (IPCO 2009), and the privacy-positive examination in EPIC (2009).

8. The APF indicates its preparedness to participate in a constructive manner in discussions with proponents of the technologies. The APF's approach to consultations is explained on its Policy Index Page.


References

Austin P. (2010) 'Plug pulled on smart meter plan' The [Melbourne] Age, 23 March 2010, at http://www.theage.com.au/victoria/plug-pulled-on-smart-meter-plan-20100322-qrdc.html

Bita N. (2010) 'Energy meters could make burglars smarter' The Australian, 22 November 2010, at http://www.theaustralian.com.au/news/nation/energy-meters-could-make-burglars-smarter/story-e6frg6nf-1225958013268?referrer=email&source=AIT_email_nl&emcmp=Ping&emchn=Newsletter&emlist=Member

EPIC (2009-) 'The Smart Grid and Privacy' Electronic Privacy Information Center, Washington DC, since June 2009, at http://epic.org/privacy/smartgrid/smartgrid.html/

EPIC (2009) 'Comments to NIST' Electronic Privacy Information Center, Washington DC, 1 December 2009, at http://epic.org/redirect/120309smartgridcmmt.html

Foo F. (2010) '15,000 smart homes planned for NSW' The Australian, 23 November 2010, at http://www.theaustralian.com.au/australian-it/smart-homes-planned-for-nsw/story-e6frgakx-1225958811643

IPCO (2009) 'SmartPrivacy for the Smart Grid: Embedding Privacy into the Design of Electricity Conservation', Information and Privacy Commissioner of Ontario, November 2009, at http://www.ipc.on.ca/images/Resources/pbd-smartpriv-smartgrid.pdf

Jamieson A. (2009) 'Smart meters could be 'spy in the home' The [London] Telegraph, 11 October 2009, at http://www.telegraph.co.uk/finance/newsbysector/energy/6292809/Smart-meters-could-be-spy-in-the-home.html

MunroS. (2010) 'Feds Moving Forward on Smart Grid Security and Privacy: The latest draft from NIST prescribes responses to growing unease about access to data' GreenTechMedia, 17 February 2010, at http://www.greentechmedia.com/articles/read/feds-moving-forward-on-smart-grid-security-and-privacy/

NIST (2010) 'Guidelines for Smart Grid Cyber Security: Vol. 2, Privacy and the Smart Grid' The Smart Grid Interoperability Panel – Cyber Security Working Group, NISTIR 7628, August 2010, at http://csrc.nist.gov/publications/nistir/ir7628/nistir-7628_vol2.pdf

Reeks G. (2010) 'Are meters too smart by half?' Brisbane Times, 26 June 2010, at http://www.brisbanetimes.com.au/technology/are-meters-too-smart-by-half-20100625-z9ix.html

Robertson J. (2009) 'Security researchers offer caution on smart grids' The [Melbourne] Age,
1 August 2009, at http://news.theage.com.au/breaking-news-technology/security-researchers-offer-caution-on-smart-grids-20090801-e4oe.html

Talaga T. (2010) 'Smart grid needs protecting: Privacy czar' Toronto Star, 11 May 2010, at http://www.thestar.com/news/canada/article/808074--smart-grid-needs-protecting-privacy-czar


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Created: 15 February 2011 - Last Amended: 15 February 2011 by Roger Clarke - Site Last Verified: 11 January 2009
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