On April 22, 2013, the Article 29 Working Party (the “Working Party”) adopted an Opinion on the proposed data protection impact assessment template for smart grid and smart metering systems (“DPIA Template”). Expert Group 2 of the European Commission’s Smart Grid Task Force submitted the DPIA Template to the Working Party following the European Commission’s March 9, 2012 recommendation regarding preparation for the roll-out of smart metering systems.
The Working Party’s Opinion criticizes the DPIA Template, concluding that it is not sufficiently mature, and sets forth detailed recommendations for improvement. Once the DPIA Template is redrafted to take these recommendations into account, it should be submitted again to the Working Party for another opinion regarding the revised version. In an earlier opinion, the Working Party analyzed the wider privacy implications of smart metering.
Notably, the Working Party recommends in the Opinion that the European Commission consider creating a general privacy impact assessment methodology that could serve as the basis for future, sector-specific privacy impact assessment templates.