Submission: Privacy and trust in the new energy market

Consumer Action Law Centre (Consumer Action) welcomes the opportunity to provide input the Energy Market Reform Working Group’s (EMRWG) paper, New products and services in the electricity market—consultation on regulatory implications (Consultation).

Recommendations:
1. The consumer experience must underpin any market reform.
2. Consumers can be irrational and may not use energy services in a way that is efficient for “the system”. We encourage the EMRWG to undertake its own analysis with behavioural economics to inform them on how consumers interact with complex markets.
3. All providers of energy services must be members of energy ombudsman schemes.
4. Consumer authorised parties must be able to verify to retailers or distributors that a consumer has provided their explicit informed consent prior to releasing data.
5. Consumers must opt in via their explicit informed consent, in relation to the use of their data.
6. Data must be stored securely by third parties, with clear guidelines for keeping that data, including timelines.
7. The NECF must include explicit obligations on retailers and distributors to keep records that confirm they have sighted a consumer’s authorisation to release their data.
8. Privacy regulators must actively monitor (and enforce) obligations in respect to data.
9. Consumer rights and protections as they relate to each service or technology, as well as a path for dispute resolution, must be made clear to the consumer at point of contract.
10. Disclosure of information must relate to both product attributes and product use.
11. Key terms describing aspects of the energy market must be standardised to encourage consumer engagement and facilitate consumer trust and apply to energy service providers.
12. Key protections must be developed for those consumers investing in off grid supply.
13. A framework for re-connection to the grid must be developed for those on alternate supply.

A full copy of our submission is available here.

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