More Information on Smart Meters and Data
Electricity consumption data collected by smart meters is considered to be personal data for purposes of data protection laws in Ireland, including the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). As such, ESB Networks ensures that the National Smart Metering Programme (NSMP) is delivered in compliance with these and that all personal data collected by your meter is safe and secure.
In so doing, ESB Networks has engaged with the Commission for Regulation of Utilities (CRU), the Department of Environment, Climate and Communications (DECC) and the Data Protection Commission (DPC) on the data privacy aspects of the NSMP and has published a comprehensive set of Data Protection Assessments (DPIAs) which outline how ESB Networks collects, processes and protects personal data. These DPIAS are available to read here.
Data is collected by smart meters and processed by ESB Networks pursuant to its legal obligations under the terms of ESB Network’s Distribution System Operator license (with which ESB Networks is obliged by law to comply). All personal data collected and processed by ESB Networks as part of the NSMP is processed in accordance with ESB Network’s Privacy Notice, which can be read here.
Smart meters are now operational and are read remotely, where communications have been established, greatly reducing the need for estimated bills. Electricity supply companies are also now offering new smart services to customers who have a smart meter installed.
In this section we explain what data smart meters record, how they communicate and how we protect your data.
What data is recorded on my smart meter?
Unlike traditional meters which only recorded your electricity consumption, your smart meter will record details of your electricity consumption, any electricity exported onto the grid, and events, alerts and instrumentation data related to the power supply at your premises. Each data category is explained in more detail below.
Each day, your meter will record the total amount of electricity consumed and exported over the previous 24-hour period. This is referred to as Register Data.
The meter also records a more detailed breakdown of the electricity consumed and exported in up to 30 minute periods. This is referred to as Interval Data and includes the recording of electricity consumed during the Day, Night and Peak periods. The Day period is from 8am to 11pm but excludes the Peak Period which is from 5pm to 7pm. The Night period is from 11pm to 8am.
In order to ensure the meter is working properly, the meter records diagnostic information about the meter itself. This is referred to as Event Data.
The meter also has the capability to record diagnostic metrics relating to power quality on the network in the vicinity of the premises at which it is installed. These metrics enable ESB Networks to remotely diagnose reported customer supply issues (such as low voltage) without the need to schedule a Network Technician visit and the temporary installation of additional on-site diagnostic equipment. This is referred to as Instrumentation Data.
How often does the meter send data to ESB Networks?
Smart meters communicate remotely with ESB Networks over a secure 2G mobile network using technology like that used to send text messages. Your meter will create the equivalent of an encrypted text message and send it to an IT system called a Head End System (HES). Data collected from the meter is then stored securely in a central Meter Data Management System (MDMS) managed and operated by ESB Networks. Only ESB Networks has access to data held on your smart meter and access to data held in the MDMS is restricted.
Each day, normally around midnight and via a secure 2G mobile network, your meter will send ESB Networks the total amount of electricity consumed and exported over the previous 24 hour period. If you have chosen a plan or tariff which requires your Supplier to be provided with your Day, Night and Peak electricity consumption data this will also be sent from the meter at midnight.
Your smart meter will activate itself approximately every two hours to check its integrity and connection to the mobile network, it will send details of any electricity exported onto the network and if it finds any problems with the meter it will create another encrypted text message and send details of those problems to ESB Networks.
If you have chosen a plan or tariff which requires your Supplier to have your 30-minute electricity consumption data this data will also be sent from your meter to ESB Networks MDMS every two hours.
This is explained further in the next section.
How does ESB Networks ensure your data is secure?
Only ESB Networks has access to your smart meter and the data on it. To ensure your data is secure, access is tightly controlled and we employ multiple layers of cyber security on our IT systems and business processes. For example, a SIM card is embedded in all smart meters and security protocols are in place to ensure that only approved SIM cards are permitted to join the secure and encrypted 2G communications network used by smart meters to communicate with the Advanced Meter Infrastructure (AMI), this network is operated for ESB Networks by Three Ireland Ltd.
The specific models of smart meters installed by ESB Networks have been independently tested from a cyber security perspective and the Advanced Meter Infrastructure (AMI) and other IT systems are protected by industry standard security systems, including firewalls. These security arrangements are subject to regular independent testing and review.
You can read the register values on your meter, a video on how to read your meter is available here
How long is my meter data retained for?
Smart meter data (i) collected by smart meters and (ii) exported to the Advanced Meter Infrastructure (AMI) and stored in the Meter Data Management System (MDMS) is retained by ESB Networks only for the minimum period necessary for ESB Networks to comply with its legal obligations in relation to that data.
Consumption data is retained for seven years to comply with the existing Metering Code, an industry code issued by CRU (Commission for Regulation of Utilities) with which ESB Networks (and electricity suppliers) are required to comply. It should be noted that this retention period applies only to consumption data which is uploaded from your smart meter to the Advanced Meter Infrastructure for use in the calculation of customer billing, use of system charges and wholesale settlement, this data is also used to resolve historical metering customer queries and complaints. This is an important feature of the design of the National Smart Metering Programme.
While your smart meter itself records electricity consumption at half hourly intervals, this Interval data is not exported to the ESB Networks MMDS except where and to the extent that it is necessary to do so on foot of a request from your electricity supplier based on the tariff or plan selected by you. Consumption data recorded by your smart meter itself, but which is not required to be exported to the MDMS for billing purposes is automatically overwritten by the meter after a maximum of 350 days.
What is the legal basis for ESB Networks collecting smart metering data?
The CRU’s decision to implement smart metering for all residential and smaller business customers was initially announced in July 2012. This decision was made following comprehensive customer behaviour and technology trials and a positive cost-benefit analysis, as provided for in the Energy Efficiency Directive (and repeated in the Third Energy Package). The European Union (Energy Efficiency) Regulations (implementing the Energy Efficiency Directive) gave the CRU the responsibility for the implementation of smart metering in Ireland. The CRU concluded the High Level Design for the NSMP in October 2014 and finalised the suite of detailed policy decisions required to give practical effect to that High Level Design in 2016.
The collection of personal data by smart meters and its processing by ESB Networks is necessary to meet a number of legal obligations imposed on ESB Networks by its Distribution System Operator (DSO) license. ESB Networks has obligations under Condition 7 (Detection and Prevention of Theft of Electricity), Condition 8 (Meter Point Registration Service and Meter Registration Agreement) and Condition 9 (Provision of Metering and Data Services).
In July 2020, CRU determined, pursuant to Condition 9(2) of the DSO License, that the following actions also fall under the scope of the obligations imposed on ESB Networks by Condition 9:
- Programming all smart metering systems installed by it to record (import and export) (i) half-hourly interval data (ii) twenty-four hour, day, day peak and night register readings (iii) instrumentation data and (iv) meter event data from such systems.
CRU also determined that the foregoing data should, subject to further direction, be processed by ESB Networks solely for purposes of:
- continuing to implement the High-Level Design to meet the requirements of the Programme and the emerging obligations from the Clean Energy Package (CEP), in accordance with the Decision and Condition 9 of the DSO License;
- establishing and commissioning the Advanced Meter Infrastructure (AMI) to support operation of the Programme;
- operating the AMI to enable delivery of the Retail Market Smart Services (including time of use tariffs) as described in the electricity retail market processes as updated per schema Version 13; and
- continuing to comply with existing obligations under Condition 9.
More details can be found in our DPIA’s which are located here