Citizens Advice response to the Ofgem call for input on data sharing in a digital future: consumer consent
We welcome Ofgem’s call for input having initially recognised the need for a consumer consent solution when we published our paper on the smart meter data dashboard in 2018. Our research shows that 89% of consumers think that it’s important to have control over how their data is used. A consumer data dashboard will help build the trust and confidence that consumers need to engage in the energy market as it transitions to net zero.
The current methods of seeking consent include important checks and balances designed to control data access. While networks and suppliers largely access energy demand data based on their licence conditions, third party intermediaries (TPIs) and other new services are required to seek more explicit consent. These will play a crucial role in facilitating a more complex and flexible energy system, but it is important that they are adequately regulated to provide consumers with the protections they need.
The existing systems for obtaining consent give consumers some transparency and control at the initial point of interacting with a service provider, but fail to give longer term reassurance and ongoing control.
A single technical consent solution - like the consumer facing data dashboard proposed in option one - will make it simpler for consumers to know who is using their data, for what purpose and over what time period. One of the benefits of a single data dashboard is that it would prevent consumers from needing to identify the users of their data themselves and then seek out individual dashboards.
This approach would also reduce the burden on industry by providing a clear path for compliance. It should also make it clear how public bodies can gain consent to access consumer smart meter data, helping to unlock innovative new use cases that meet the needs of consumers.
Any consumer focused solution should work for a range of consumer groups including people who are less digitally confident. It is vital that the consumer dashboard is thoroughly user tested and explains the functions and purpose of the tool in simple language.
Ofgem will play an important role in outlining expectations for a minimum viable product. It should also clarify how a new consumer consent process would interact with data sharing rules under existing licence conditions and as administered by the Smart Energy Code. Ultimately, the industry will be responsible for the success of the dashboard and should embrace this proposal as an opportunity to build consumer confidence.