DataGuard Energy Data Privacy Program
On January 12, 2015, President Obama announced the release of the final concepts and principles for a Voluntary Code of Conduct (VCC) related to the privacy of customer energy usage data for utilities and third parties. The final VCC is the result of a 22-month multi-stakeholder effort that was facilitated by the Energy Department's Office of Electricity Delivery and Energy Reliability (DOE) in coordination with the Federal Smart Grid Task Force. The VCC reflects input from stakeholders across the electricity industry and incorporates comments and responses from the public that were collected via DOE's Federal Register Notice issued earlier this year. The VCC, which has now been branded as the DataGuard Energy Data Privacy Program (DataGuard), provides companies with a consumer-facing mechanism for demonstrating their commitment to protecting consumers' data and thus increase consumer confidence.
Consumers and industry stakeholders can learn more about the DataGuard Energy Data Privacy Program at www.DataGuardPrivacyProgram.org.
Adopting the DataGuard Energy Data Privacy Program
Companies adopting the DataGuard Energy Data Privacy Program will be expected to publicly commit to conformance with and observance of the DataGuard Voluntary Code of Conduct. To determine conformance, interested companies should download the DataGuard Voluntary Code of Conduct Concepts and Principles to verify compliance within their company. Adoption of DataGuard will occur when a company, after determining compliance, signs and submits an Adoption Statement (pdf). Signatures must come from an individual within the company with the authority to commit the organization to DataGuard. By completing and submitting the Adoption Statement, the company signifies that it is in conformance with the DataGuard Voluntary Code of Conduct as of the effective date listed on the Adoption Statement. DOE is currently seeking companies interested in adopting the DataGuard ahead of the consumer announcement of this initiative. If you are interested in adopting the DataGuard, please contact Eric Lightner at DOE.
Revisions and Updates
DOE will coordinate a DataGuard Revisions Working Team (RWT) that will review the concepts and principles for updates and revisions every 2 years. The team will review any suggested revisions that are received as well as conduct an independent review of the concepts and principles to determine if any revisions may be warranted. The RWT will also assess suggested revisions of an urgent nature that are clearly identified as needing a determination prior to the next two-year deadline. The RWT will be made up of volunteers, and best efforts will be made to ensure that the RWT is populated by a diverse set of stakeholders, such as utilities of various sizes, municipalities, cooperatives, consumer advocates, privacy advocates, regulators and/or third parties. The volunteers will serve for finite terms, although they could be subject to some degree of voluntary renewal upon approval of the entire RWT. The initial RWT, once formed, will discuss and decide issues regarding governance, bylaws, finite terms, etc.
When revisions are finalized, an adopting company that wishes to opt out of the revised concepts and principles must communicate its intent and the effective date of its opt out to the DOE. The company must then remove all DataGuard logos from communication by the opt-out effective date included in its notification to DOE.p>If you would like to be notified of the program updates and revisions or would like to be a member of the DataGuard Revisions Working Team, please contact please contact Eric Lightner at DOE.
Throughout the U.S., intelligence is being added to the grid through the deployment of advanced technologies and grid modernization efforts. This increased intelligence has led to concerns regarding consumer data access and the privacy of consumer energy consumption data. Historically, utilities have taken very seriously the job of protecting customers’ privacy, and privacy and security protections will remain fundamental objectives. However, with the new technologies being deployed today, these fundamental protections warrant new attention. Consumers must feel secure that their data will be protected and treated responsibly. Therefore, it is important that stakeholders on all sides of the privacy debate work together to address concerns and coordinate activities.
On January 31, 2012, U.S. Department of Energy, Office of Electricity Delivery and Energy Reliability (DOE OE) hosted the Smart Grid Privacy Workshop to facilitate a dialog among key industry stakeholders. In addition, on February 23, 2012, the White House released the report, Consumer Data Privacy in a Networked World: A Framework for Protecting Privacy and Promoting Innovation in the Global Digital Economy (Privacy Blueprint). The Privacy Blueprint outlines a multi-stakeholder process for developing legally enforceable voluntary codes of conduct to help instill consumer confidence.
In response to workshop findings and in support of the Privacy Blueprint, DOE OE and the Federal Smart Grid Task Force are facilitating a multi-stakeholder process to develop a voluntary code of conduct for utilities and third parties providing consumer energy use services that will addresses privacy related to data enabled by smart grid technologies.
The following documents are public comments received in response to DOE's Federal Register Notice.
- APPA Comments
- Daniel Secrist Comments
- EEI Comments
- EEI Supplemental Comments
- FTC Comments
- Kim Post Comments
- Simple Energy Comments
- Southern Company Comments
Work Groups have been established to focus on the development of the mission statement and the evaluation of different aspects of the proposed VCC elements. If you are interested in participating in a Work Group or have questions regarding their activities, please contact the appropriate lead directly.
Work Group Leads
- Mission Statement Work Group – Dan Francis, AEP
- Notice/Awareness Work Group - Amanda Stallings, Public Utilities Commission of Ohio
- Choice/Consent Work Group – Eric Ackerman, EEI
- Access/Participation Work Group – Megan Hertzler, Xcel Energy
- Integrity/Security Work Group – Brandon Robinson, Balch & Bingham LLP, representing Southern Company
- Management/Redress Work Group - Chuck Piotrowski, Green Mountain Power
- Integration Work Group - Eric Ackerman, Edison Electric Institute
- Implementation Work Group - Lincoln Wood, Southern Company
December 11, 2014
U.S. Department of Energy Webinar on Smart Grid Data Privacy: A DataGuard
On Thursday, December 11, 2014, the Energy Department's Office of Electricity Delivery and Energy Reliability in coordination with the Federal Smart Grid Task Force conducted a webinar to conclude the development phase of a DataGuard related to privacy of customer energy usage data for utilities and third parties. The webinar summarized changes made to the DataGuard concepts and principles as a result of comments received through the public comment period. In addition, a proposed implementation plan and adoption process was presented as well as preliminary results from focus groups conducted to gauge consumer sentiment.
- FTC Perspective, Mark Eichorn
- VCC Implementation, Lincoln Wood
- Responsive Changes to Public Comments, Eric Ackerman
- Focus Group Results, Jim Jager
- Moving Forward and Next Steps, Eric Lightner
- Public comment edits
- Marketing plan
- Adoption and revision blueprint.
November 22, 2013
A third meeting was convened on November 22, 2013 to discuss the draft principles.
November 22, 2013 meeting documents:
- Meeting Minutes Nov 22 FINAL.pdf
- Assembled Draft Principles 111413.pdf
- Agenda Draft Nov 22 meeting final.pdf
- choice consent draft principles 2013_11_08.pdf
- choice and consent examples final2013_11.pdf
- DOE VCC Integrity-Security Draft Principles (11-7-2013).pdf
- Self-Enforcement_Redress - final principles 11_2013.pdf
- US DOE Privacy VCC Mission Statement.pdf
- VCC NAWG Draft Principles 2013_11_08.pdf
June 4, 2013
The second meeting took place on June 4, 2013 2013 from 9:30am to 5:00pm in Washington, D.C.
June 4 Meeting Documents:
- VCC Meeting Minutes June 4 2013
- Agenda for June 4 Meeting
- Work Group Structure
- VCC Mission Statement Draft
- VCC Notice and Awareness Group Summary
- Choice and Consent June 4 Meeting Doc
- Access and Participation Members
- Access and Participation Issues Table
- Integrity Security Review
- Self enforcement and redress
June 4 Meeting Presentations:
- Choice and consent #3 report June 4
- DOE VCC Workgroup #4 Access
- DOE VCC Workgroup #5 Integrity Security summary
- DOE VCC Workgroup #6 Management Redress
- Mission Statement Subgroup Slides final
- VCC Notice Group Presentation June 3 2013
February 26, 2013
Federal Smart Grid Task Force convened the first meeting in the multi-stakeholder process on February 26, 2013 from 9:30am to 4:30 pm in Washington, DC. Stakeholders engaged in an open, transparent, consensus-driven process to develop the VCC. The objectives of the meeting were to 1) promote discussion among stakeholders regarding a proposed VCC outline, including the types of data to be covered and 2) establish procedural rules for developing the VCC.
February 26, 2013 Meeting Documents: