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Citizens Advice response to Ofgem’s consultation on access to half-hourly electricity data for settlement purposes

17 September 2018

The use of half hourly (HH) electricity consumption data could make settlement more accurate, timely and cost-efficient. This has benefits to industry: reducing barriers to entry in the market, and reducing costs to consumers if efficiency savings are passed through. It will also enable new products and services for consumers. Ofgem’s draft economic case values the benefits of HHS between £1.8 billion to £5.4 billion by 2045.

As such, we support settlement reform and recognise that half hourly data access for a majority of consumers is necessary to maximise the benefit of these reforms.

In its consultation, Ofgem has set out three options, which have varying degrees of difficulty in meeting this aim and which afford consumers different levels of control over their data.

In our consultation response [ 170 kb] we argue:

  • There should be a value exchange between consumers who share their half-hourly data, and suppliers and other actors who use that data to improve settlement or forecasting.

  • In order to make an informed decision on the extent to which reduced data privacy rights for individuals might be outweighed by benefits to all consumers and society, Citizens Advice would welcome more information about the correlation between the amount of half hourly data available and the benefits achieved.

  • Out of the three data access options (opt-in, opt-out and mandatory collection of HH data), we think that the status quo (opt-in) is an optimal solution for consumers as it retains consumer control, doesn’t change the existing terms and incentivises suppliers to make the case to consumers to access their more detailed data. We do acknowledge though that an opt out does allow consumers to retain ultimate control over the sharing of their data and as such it is an acceptable solution if not an optimal one.

  • Micro business energy consumersare in many respects very similar to domestic consumers, and there isn’t always a clear distinction between the two. We would not like to see a widening of the current protection gap between domestic and micro business consumers by embedding different regulation with regards to HH data use.

  • The choices made when a consumer agreed to have a smart meter installed (or later if this was amended) should be respected. With regard to changing the ‘default’ setting from opt-in to opt-out, this would need to be communicated very clearly at the point of change of contract/tariff. Where a consumer is simply changing tariff with their existing supplier that supplier should be obliged to retain whatever preference the consumer had previously expressed or use the change in tariff process to have a specific conversation with the consumer about whether they would like to change those settings.

  • Ofgem should conduct further analysis before granting suppliers access to HH data for forecasting. The costs and benefits of doing so are not yet known, and consumer research shows that people are slightly less willing to share their HH data for forecasting purposes compared with settlement.

  • Like Ofgem, we take the view that export data is personal data. We have not undertaken any consumer research examining this particular issue so are unable to definitively answer whether consumers regard it as “less” personal but this seems a logical supposition.