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Managing Privacy in the Smart Grid

Managing Privacy in the Smart Grid. Jennifer M. Urban Assistant Clinical Professor of Law Director, Samuelson Law, Technology & Public Policy Clinic UC Berkeley School of Law. Source: Lawrence Berkeley National Laboratory-Smart Grid Technical Advisory Project. Two Demand Response Models.

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Managing Privacy in the Smart Grid

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  1. Managing Privacy in theSmart Grid Jennifer M. Urban Assistant Clinical Professor of Law Director, Samuelson Law, Technology & Public Policy Clinic UC Berkeley School of Law

  2. Source: Lawrence Berkeley National Laboratory-Smart Grid Technical Advisory Project

  3. Two Demand Response Models Utility  Residence Direct Load Control (PCTs) • Radio signal tells appliances to • cycle • shut-off • change set-point on thermostat Residence  Utility • Advanced Metering Infrastructure (AMI) • Automated meters • Advanced Meters and Smart Meters • Linked to management systems at the utility • No meter reader: wireless or powerline • Smart Meters (and consumer devices) • “Interval Data” to sub-one-minute • Home Area Network and Smart Appliances • Data on individual appliances • Sometimes gateway, sometimes direct communication • Who controls the HAN gateway and where is it placed?

  4. Non-Intrusive Appliance Load Monitoring (NALM) • NALM: fundamental tool for extrapolating activity

  5. Interval Data • 3000 data points per month for 15-minute intervals – vs. 1 • Virtual biography of household activity in near real-time • Adding specific appliance data (e.g., smart dryers, PEVs) adds even more detail AC, dinner, lights, tv 3 days a week working in LA Lights, shower, tv Assault Me Now Rob Me Now Daily Patterns Weekly Patterns

  6. Privacy implications • New data flows • Granular energy usage data that can be very revealing of home life • Transmission in real-time or near real-time • -Wardriving? • -Wiretapping? • New relationship between utility and consumer • Data flowing to new players and systems • New players and business models • 3rd parties – device manufacturers and service providers (TED, Google PowerMeter, Microsoft Hohm) • Monetization (advertising, etc.) • 3rd party access to information held by new parties • -Law enforcement • -Private parties (subpoenas, business interests) • New risks • Networks • -Many points of attack • -Web-based access: security? • “Smart” meters, with limited physical security • Sensor networks making inside visible/controllable remotely • Applicable regulation/legal protections unclear

  7. Managing Privacy Implications • Baseline privacy standards should be drawn from Fair Information Practice principles • Fair Information Practices (FIPs) • Transparency • Individual Participation • Purpose Specification • Data Minimization • Use Limitation • Data Quality and Integrity • Security • Accountability and Auditing Key Additional Requirements “Notice and Choice” Insufficient NIST work • All Smart Grid entities and practices should be covered: Third party access to and use of revealing usage data is of significant concern and should be carefully considered

  8. References --Joint Comments of the Center for Democracy & Technology and the Electronic Frontier Foundation on Proposed Policies and Findings Pertaining to the Smart Grid, Before the Public Utilities Commission of the State of California, Rulemaking 08-12-009, filed Mar. 9, 2010, http://www.law.berkeley.edu/7973.htm --Comments of the Center for Democracy & Technology, on Draft NIST Interagency Report (NISTIR) 7628, Smart Grid Cyber Security and Requirements, National Institute of Standards and Technology, Dec. 1, 2009 http://www.cdt.org/content/cdt-comments-nist-smart-grid --Comments of the Center for Democracy & Technology, In the Matter of Smart Grid Technology, Federal Communications Commission, Oct. 2, 2009. http://www.futureofprivacy.org/smart-grid-privacy/ --Ohm, P., Broken Promises of Privacy: Responding to the Surprising Failure of Anonymization, University of Colorado Law Legal Studies Research Paper No. 09-12, Aug. 13, 2009. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1450006 --Quinn, E., Privacy and the New Energy Infrastructure, Feb. 15, 2009. http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1370731 --Goldman, C. and Levy, R., Slide Presentation: NARUC Webinar #2. Engaging the Customer. Dec. 16 2009. Lerner, J. I., Mulligan, D. K.,”Taking the 'Long View' on the Fourth Amendment: Stored Records and the Sanctity of the Home,” Stanford Technology Law Review (STLR), Vol. 3, 2008. http://ssrn.com/abstract=1099121 P.A. Subrahmanyam, D. K. Mulligan, D. Wagner, U. Shankar, E. Jones, J. Lerner. "Network Security Architecture for Demand Response/Sensor Networks". Technical report, On behalf of California Energy Commission, Public Interest Energy Research Group, January, 2005. http://groups.ischool.berkeley.edu/samuelsonclinic/files/demand_response_CEC.pdf

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