28.04.2013

Art. 29 WP: Opinion on the Data Protection Impact Assessment Template for Smart Grid and Meters

Opinion 04/2013 (WP205) on the Data Protection Impact Assessment Template for Smart Grid and Smart Metering Systems (‘DPIA Template’) prepared by Expert Group 2 of the Commission’s Smart Grid Task Force
[...] With regard to data protection and security for the smart metering systems and the smart grid, the Commission Recommendation provides guidance to Member States on data protection by design and by default and the application of some of the data protection principles laid down in Directive 95/46/EC2. The Commission Recommendation further provides that Member States should adopt and apply a template for a data protection impact assessment (‘DPIA Template’), which should be developed by the Commission and submitted to the Working Party on the protection of individuals with regard to the processing of personal data (WP29) for its opinion within 12 months of publication of the Commission Recommendation. [...]
On 8 January 2013, the Commission submitted to the WP29 the final version of the DPIA Template prepared by EG2 stakeholders. [...]
The WP29 recognises the progress made from earlier versions and the useful elements that the DPIA Template already contains. Nevertheless, it is of the opinion that the DPIA Template in its current form is not sufficiently mature and well-developed.
Therefore, the WP29 recommends the Commission to take the necessary steps to ensure that work on the DPIA Template continues and that the final deliverable will provide sufficiently specific, useful and clear practical guidance to data controllers.
To facilitate further work, the WP29 provides some more specific recommendations in Annex 1 to this Opinion. However, considering the methodological flaws of the document and its lack of specificity to the smart grid context, the WP29 is not in a position to provide further, more detailed and conclusive, input at this stage.
[...]

Update 01.05.2013: Letter to Philip Lowe