Department for Energy Security and Net Zero (DESNZ) Consultation on Developing an Energy Smart Data Scheme - Which? response

Summary

Which? welcomes the opportunity to respond to the Department for Energy, Security & Net Zero (DESNZ) consultation on developing an energy smart data scheme. If designed and implemented effectively, an energy smart data scheme has the potential to empower consumers, enhance competition, facilitate the decarbonisation of the energy system and support a more flexible and resilient energy/power grid. However, without the right consumer protections and regulatory oversight, there is a risk of exclusion, financial detriment and misuse of energy data. 

As the UK consumer champion, Which? is committed to ensuring that smart data initiatives work in consumers’ best interests. A trust framework aims to provide a set of minimum and consistent cross-sector requirements on participating organisations, which protect consumers from harm and foster trust and confidence. Which? proposes a model for smart data trust frameworks which is underpinned by principles of governance, protection and scalability. These aim to embed consumer protections from the start and create a trusted ecosystem for data-sharing within the energy sector and also between the energy sector and others. Without this cross-sector join-up, there is a risk of the energy sector operating in isolation, which introduces risk of harm and detriment to consumers. 

Our response outlines how an energy smart data scheme should be developed in alignment with consumer protection principles while supporting Demand-Side Response (DSR), smart energy innovations and fair access to flexibility services.