The Polish Personal Data Protection Authority (UODO) has submitted its observations to the Minister of Energy on a draft amendment to the regulation concerning energy consumption measurement systems.

The Authority highlighted a risk of excessive data collection on consumers, which could allow deducing their lifestyle. The measurement frequency provided in the draft, set at least once per second, is considered concerning. This high frequency of data collection would enable profiling of users' daily habits and activities, which UODO regards as an excessive interference with their private life. Furthermore, the proposed provisions would prevent consumers from directly and transparently accessing their consumption information.

It was also noted that the omission, in an annex to the draft, of EU law requirements for measuring devices would deprive consumers of their right to a direct and transparent reading of their consumption. They would thus be deprived of access to their billing data without having to meet additional conditions. UODO emphasized the need to analyze the draft's compliance with the data minimization principle and to determine whether the intended objectives could be achieved by less intrusive means, especially for consumers without dynamic tariffs. Given the identified risks, it was recommended to carry out a data protection impact assessment as part of the legislative process. (DPNT.401.422.2026)