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Applying PIPEDA to the Smart Grid

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Ryerson University




This research project examines the collection, use and disclosure of personal information obtained by utilities through Smart Grids. The project used interviews with key executives to determine whether such handling of personal information is in compliance with PIPEDA and the extent to which utilities are protecting and securing personal information.

Key findings:

  • The Smart Grid’s regulatory framework focuses on energy at the expense of privacy.
  • The work of Ontario’s IPC has promoted the technological incorporation of privacy into the Smart Grid but has caused inadvertent regulatory confusion.
  • Utilities, bound by regulation, have little ability to become PIPEDA-compliant corporations.
  • OPC is not active enough in ensuring compliance with PIPEDA’s core notions.

Recommendations are included that will enable the OPC to develop guidelines for utilities about the Smart Grid and personal information protection, and inform Canadians of the privacy implications of the Smart Grid, enabling them as consumers to choose whether they wish to consent in a meaningful manner to such practices.

The key recommendations are:

  • OPC should clearly communicate to utilities and the public that personal information generated by the Smart Grid is subject to PIPEDA.
  • OPC should reach agreements with its provincial counterparts that will clarify respective jurisdiction on Smart Grid issues.
  • OPC should serve as a resource on Smart Grid privacy issues for utilities and customers.
  • OPC should engage Ontario and other provinces to ensure Smart Grid initiatives are in compliance with PIPEDA so that individuals are offered choice and control over the collection of their personal information.

This document is available in the following language(s):

English only

OPC Funded Project

This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.

Contact Information

Tel: 416-979-5316

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