Citizens Advice Response to RECCO's Consumer Consent Solution Design Consultation

Citizens Advice Response to RECCO’s Consumer Consent Solution Design Consultation 217 KB

We welcome the opportunity to respond to this consultation. We have called for the creation of a consumer consent portal since the DCC contract was first awarded in 2013. We have advocated for a portal to allow consumers to see who is accessing their smart meter data and make choices about it.

As noted in our response to Ofgem’s consultation on the Consumer Consent Impact Assessment, the ability to make choices as to whether or not to share smart meter data is important to consumers. Currently there are no means by which a consumer can know who is accessing their smart meter data or for what purposes. This makes it impossible for consumers to consistently exercise their right to make informed choices about sharing their smart meter data, and risks creating significant distrust in both smart meters and the wider energy industry. If we want consumers to engage with smart-enabled products and services they will need tools that provide adequate transparency, control and accountability as to how their data are used.

The number of consumers who say that it is either important or very important that they be able to opt-out of sharing their smart meter data has remained high over the years - at 89% in 2019, and 92% in 2024. Those who make the most use of smart-enabled products and services are most likely to rate it as important, so we should anticipate an increased appetite for better control as more services make use of smart energy data.

The concerns we raised in our response to Ofgem’s 2025 consultation all remain relevant - particularly that the goals of this project have shifted away from its original aim of providing consumers information about who is accessing their smart meter data and giving them the ability to make choices about that access where possible. Rather than being consumer centered, the new proposal is more focussed on offering benefits to industry by creating a tool that can allow them to establish and manage consent from their customers on an opt-in basis. We note that the background summary focuses on enabling new market entrants rather than ensuring consumers can see who is accessing their data. If implemented properly the tool should achieve both goals but the prioritisation of industry over consumer benefits is of concern when this product was originally conceived to improve consumers experience and trust. 

We are also concerned that the portal as described in the consultation document is no longer expected to show any data flows that aren’t consent based or some where consent was given before the launch of the portal. Sections 4.18 and 4.19 of the consultation document imply that energy supplier data access will no longer be in scope and that other users can “choose to engage on a voluntary basis”. These are significant gaps likely to undermine both trust in and the usefulness of the tool. Efforts must be made to ensure that the launched product shows as many data flows as possible and these cannot just be those that are new, based on explicit consent or where the provider has opted in to letting people see it. Our previous proof-of-concept for the portal was able to show all DCC-based data access. This should be considered a bare minimum for the product to be viable. Without this numerous data flows a consumer would expect to see will be missing from the portal.