Handling Third-Party and Meter Data on Piclo

If you’re a newly registered FSP (Flexibility Service Provider) on Piclo, managing third-party data and MPANs is crucial for entering flexibility markets. This article highlights the essentials and is designed to assist FSPs, particularly optimisers or aggregators, in dealing with the challenges of handling third-party customer data. 

What does MPAN stand for?

MPAN stands for Meter Point Administration Number. It’s a unique identifier assigned to electricity supply points in Great Britain. Think of it as a serial number for a meter – used to track energy usage and supply for a specific location.

MPANs typically start with a unique two-digit number specific to the DSO network the asset is connected to. 

Why does Piclo need my MPANs or meter data?

FSPs need to upload key asset data, such as MPANs (Meter Point Administration Numbers), to the Piclo platform to meet pre-qualification requirements for live flexibility opportunities. This step enables System Operators to carry out vital technical evaluations and verify your assets' eligibility during pre-qualification.

Piclo prioritises data security. We are ISO 27001 certified, and handle all FSP data following top-tier security standards. We employ robust industry-standard encryption protocols to secure data both in transit and at rest, safeguarding your customers' information at every stage. Additionally, Piclo is registered with the UK Information Commissioner’s Office, and our procedures fully comply with GDPR.

Discover more about Piclo’s Security and Compliance in our security statement here.

As an FSP, how do I handle third-party meter data on Piclo?

According to Piclo’s Service Terms, FSPs are the data “controllers” of any MPANs or third-party meter data they upload to the platform.

Here’s what that means in practice:

• FSPs decide how and why personal data (such as MPANs and meter readings) is collected and uploaded to Piclo.
• Piclo becomes the “processor” of that data once it is uploaded.
• FSPs are the “controllers” of said data and can request that any uploaded data be deleted at any time.

Please be aware that FSPs are expected to handle personal data responsibly and establish an appropriate method for gathering it from customers as required. It may be beneficial for FSPs to create a formal End User Agreement (EUA) with their customers that addresses consent and data management.

Does combining MPAN data with other information (like postcodes or meter readings) make it personal data (PII)?

Generally speaking, yes, this can be considered PII. In summary, here’s why:

• An MPAN by itself is not typically regarded as personal data unless it is linked with other information, such as consumption data related to a domestic customer.
• However, MPANs are unique identifiers, so when combined with other data like postcodes or meter readings, they can become personally identifiable information (PII).

Regarding the Piclo user journey, meter data can become PII during:

1. Asset Upload:

• During this process, we ask for:
  • Asset Name
  • Asset Postcode
  • Import/Export Meter IDs (MPANs)
• These combined data points can be considered PII and are necessary for DSOs to assess and verify asset eligibility.

2. Dispatch / Settlement:

• FSPs awarded a flexibility contract by a Distributed System Operator (DSO) must upload meter readings for each obligated asset, especially for short-term competitions.
• These meter readings are linked to the relevant MPANs (assets) and are essential for confirming asset performance and settling FSP obligations with the DSO before payment.

Disclaimer

This article provides general guidance only and does not constitute legal advice. We recommend that FSPs consult with their own legal teams or seek their own independent legal counsel to ensure compliance with local data protection regulations and that their own internal company policies are met.

If you have any further questions, our team is here to help! Please reach out to support@piclo.energy.