«Ref: C14-RMF-68-03 19 March 2015 Council of European Energy Regulators asbl Cours Saint-Michel 30a, Box F – 1040 Brussels, Belgium Arrondissement ...»
One result of the CEER public consultation was that the majority of respondents showed strong support for the proposed guiding principles. However, the respondents also consider that there are still other guiding principles that should be taken into account: customer data ownership (this idea is already included within several of the recommendations outlined above) and simplicity (which is already included within the Guiding Principle on Transparency).
The implementation of the chosen customer data management model should take into consideration the costs incurred; because these costs will likely be passed on to the customers.
The guiding principles underlying customer data management are Privacy and Security, Transparency, Accuracy, Accessibility and Non-Discrimination. Besides that, cost-efficiency considerations should always be taken into account when implementing the chosen data management model.
In some countries this information is already available.
The table below presents the five guiding principles and seven recommendations outlined in this paper in relation to the functioning of data management arrangements.
This CEER Advice on customer meter data management for better retail market functioning proposes seven recommendations across a set of five general guiding principles on which data management should be based from a customer point of view and regardless of the specific data management models implemented in the different MSs.
Customer meter data, already protected by EU privacy legislation, should always be subject to the control of the customer; meaning that specific parties which do not require the use of such data by law/regulation (e.g. for system operation), should always be required to ask for consumers’ consent in order to access or use it.
As established in the Electricity and Gas Directives, the policy framework for accessing energy usage data should provide customers with access to objective and transparent data.
Therefore, transparency is one of the key requirements any data management model should comply with. In this sense, customers should be able to access online information on their rights with regard to customer data management, on the way data is stored and for how long, and on how they can access that data in a way that is convenient for them.
Moreover, NRAs, DSOs/metering operators, consumer organisations and/or public authorities in each MS should develop information campaigns and other awareness-raising and educational programmes with the aim of building customer confidence in data management, so as to empower the customer. It is only this way that the benefits related to meter data usage, especially in a smart grid context, might be achieved.
With regard to more technical considerations, and provided that the EU energy sector is currently evolving towards an internal common market, the national data management models implemented nowadays should converge in the long run towards a harmonised model with common standards for data content, data formats and data exchange in the retail market. Such harmonisation at European level, together with the assurance that there is nondiscriminatory access to information, will be crucial for eliminating entry barriers for potential market participants and, ultimately, fostering efficient retail market competition at EU level.
It is important to take into account that the implementation of the guiding principles and their corresponding recommendations should ultimately be driven by a cost-efficiency consideration in all cases.
CEER’s 2015 Work Programme outlines an ambitious strategy to strengthen the position of the customer on the European market. As part of its work in 2015, CEER will also develop a paper on a competitive retail market, which will focus on the customer and the customer needs in a well functioning retail market32.
CEER 2015 Work Programme Ref: C14-WPDC-26-05 and the ACER “Energy Regulation: A bridge to 2025”
Annex 1 – CEER The Council of European Energy Regulators (CEER) is the voice of Europe's national regulators of electricity and gas at EU and international level. CEER’s members and observers (from 33 European countries) are the statutory bodies responsible for energy regulation at national level.
One of CEER's key objectives is to facilitate the creation of a single, competitive, efficient and sustainable EU internal energy market that works in the public interest. CEER actively promotes an investment-friendly and harmonised regulatory environment, and consistent application of existing EU legislation. Moreover, CEER champions consumer issues in our belief that a competitive and secure EU single energy market is not a goal in itself, but should deliver benefits for energy consumers.
CEER, based in Brussels, deals with a broad range of energy issues including retail markets and consumers; distribution networks; smart grids; flexibility; sustainability; and international cooperation. European energy regulators are committed to a holistic approach to energy regulation in Europe. Through CEER, NRAs cooperate and develop common position papers, advice and forward-thinking recommendations to improve the electricity and gas markets for the benefit of consumers and businesses.
The work of CEER is structured according to a number of working groups and task forces, composed of staff members of the national energy regulatory authorities, and supported by the CEER Secretariat. This report was prepared by the Retail Market Functioning Task Force of CEER’s Customers and Retail Markets Working Group.
CEER wishes to thank in particular the following regulatory experts for their work in preparing this report: Ms Gunilla Eng Åbrandt, Ms Katarina Abrahamsson, Ms Gloria Mármol Acitores, Mr Jeroen Cordeweners, Ms Stefanie Fix, Ms Ines Handrack and Mr Grant McEachran.
More information at www.ceer.eu.
Annex 4 - Mapping the guiding principles of customer data management to the CEER 2020 Vision for Europe’s Energy Customers - RASP principles Figure 2: Mapping the guiding principles to CEER’s 2020 Vision for Europe’s energy customers Reliability Customer data management is relevant for providing reliability in the context of the 2020 Vision through the systems and processes that are put in place. In particular, it is reflected in our Guiding Principle on Accuracy, as the data produced by the systems and processes should be of a robust quality and result in customers receiving accurate bills.
Affordability We have reflected the importance of affordability as relevant to customer data management in the context of our Guiding Principle on Accessibility. Customers own their data and should be in a position to benefit from access to that data. Equally, recognising the wider benefits of data sharing and subject to approval of the customer other parties should be able to access that data at either no cost or for a reasonable fee.
Simplicity Again, we have specifically recognised the importance of simplicity within our Guiding Principle on Accessibility. It is important that data is presented in a customer-friendly way, on the grounds that the ability for customers to understand their data is key to building confidence and generating active participation.
37/38 Ref: C14-RMF-68-03 Customer Data Management for Better Retail Market Functioning We have also identified the Guiding Principle on Transparency, highlighted by the 2020 Vision as relevant in the context of simplicity, as a separate principle for customer data management.
CEER considers that customer data management arrangements should be transparent so that a customer: (1) knows what data exists and what it is used for; (2) knows how to access that data; and (3) is able to easily access that data themselves.
Protection and empowerment Protection and empowerment are relevant to customer data management in the context of how data is made available, who it is made available to and how that data is used. These are
reflected in the following three guiding principles for customer data management:
• Privacy and security – Customers control their data and it should be protected from unauthorised access through appropriate security measures which guarantee the privacy of their data.
• Accessibility - At the same time, access to better data for both the customers themselves and third parties (with permission) should empower customers to make better use of their data in order to secure more positive outcomes.
• Non-discrimination - Competition is an important tool in protecting the interests of customers. There are significant opportunities for third parties to provide services to customers. In order for third parties to be effective in this role, customer data management models should not give undue preference to one stakeholder over another.