We were able to express our views on the Energy Strategy 2050 during the pre-parliamentary consultation procedure. We believe that the legal basis for the processing of personal data is too imprecise and have asked for changes to be made. We are also supporting and advising the Smart Grid Road Map Switzerland working group.
We believe that the provisions on the processing of personal data that were included in the draft consultation paper on Energy Strategy 2050 fail to achieve the level of precision required when establishing a legal basis. We therefore demanded that the purpose of the system be described in a manner which makes it clearly identifiable to the persons concerned. The greater the likelihood that an individual's right to privacy may be infringed - in other words, the most sensitive the personal data or personality profiles - the greater the level of detail required in the legal basis.
Irrespective of the type of personnel data that is to be processed, it is not sufficient to say that the purpose of the system is to enable the federal agency concerned to fulfil its statutory duties. On the contrary, an exhaustive list of tasks must be drawn up which details the exact purpose of the data processing.
On the subject of smart metering (digital electricity meters) and data protection, we have supported and advised the "Smart Grid Road Map Switzerland" working group that was set up by the Federal Office of Energy. We made a number of recommendations during the course of various meetings (see also our explanations on the subject, in German). The proportionality of the data processing is one of the key issues with regard to the use of such meters. This means that only data that are specifically required for the purpose of metering should be processed, and that once they are no longer needed, the data must be deleted, anonymised or aggregated.