Citizens Advice response to Ofgem consultation on a Consumer Consent Solution

Citizens Advice response to Ofgem consultation on a Consumer Consent Solution 169 KB

We welcome Ofgem’s consultation, having initially identified the need for a consumer consent solution when we published our paper proposing the creation of a smart meter data dashboard in 2018. Our research shows that 92% of consumers think that it’s important to be given options to opt out of providing access to their data. A consumer consent portal will help build the trust and confidence that consumers need to engage in the energy market as it transitions to net zero and more consumer data-derived innovative services begin to be offered.

We further welcome Ofgem’s work in specifying design principles for the consumer consent solution. However we believe that Ofgem should make clear specific requirements for the design of a consent solution that go beyond the principles set out in the consultation. These include ensuring appropriate friction for consumers wishing to revoke consent for products where the revocation of consent could result in the product no longer working as intended (e.g. Time of Use tariffs), expanding the scope of the dashboard to enable visibility of data flows where consent is not the lawful basis for collection e.g. where data collection is justified by ‘legitimate interest’, and ensuring that the consent solution is interoperable as quickly as possible.

Additionally, we are unclear on what Ofgem views as the benefits of allowing significant (i.e. non-cosmetic) differentiation at the UI level. As we outlined in our response to the call for input, consumers will benefit from a consent solution that functions in the same way and has the same features wherever they encounter it. A more piecemeal approach with different solutions produced by different actors in the energy market risks confusion or seemingly contradictory information. We also highlight the importance of non-digital avenues for consumers to review consent.