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PUC Declines To Include Certain Expanded Customer Information In Lists Provided To Green Supplier Of Default Service REC Program

Utility Suggests Provider Be Subject To Data Security Rider, Obligations For Receipt Of Customer Information

June 11, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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The Maine PUC declined to include all of the sought expanded information that 3Degrees Group, Inc., which is the designated supplier for the Maine Green Power Program, which is a REC add-on program for Standard Offer customers and other customers, had requested to be included in customer lists provided by the utilities

The PUC previously authorized the provision of residential and small commercial customer mailing lists by the utilities to 3Degrees Group, with the lists including account name, service address, and mailing address

In seeking an update to the customer lists, 3Degrees also requested that additional information be included in the lists, such as customer account number, phone number, email address, and customer usage.

3Degrees requested that the customer lists include the following (with 3Degrees's stated rationale) :

• account number - used to provide customer enrollment requests that include a valid account number, increasing accuracy and ease of enrollment processing for CMP and Emera Maine

• account name / account holder name - used to ensure that enrollment request is made by person(s) authorized on the account, increasing accuracy and ease of enrollment processing for CMP and Emera Maine

• rate class - used to accurately determine customer participation by rate class (commercial, industrial, residential)

• service address - used for Courtesy Knock campaigns and for customer segmentation and targeting

• mailing address - used for annual Maine Green Power report and segmentation and targeting of approved direct mail campaign(s)

• email address - used to segment and target social media (Facebook) advertising, customers will not receive unsolicited emails from the Maine Green Power program

• phone number - used for Courtesy Call campaigns to communities not reached through Courtesy Knock campaigns

• average monthly usage (kWh) - used to enhance the customer experience by providing a personalized estimate of the level of support needed to match their residence’s usage

• Maine Green Power enrollment status - used to reconcile 3Degrees enrollment records against utility records, customers already enrolled can be removed from future marketing campaigns

• solicitation status - used to ensure 3Degrees does not solicit customers who have opted out of all solicitation from the utility

While the PUC authorized a further provision of the customer lists to 3Degrees, the PUC ruled that the information that the utilities shall be required to provide 3Degrees will be limited to the following information: (1) account name; (2) service address; (3) mailing address; (4) customer rate class; (5) Maine Green Power enrollment status; and (6) solicitation status (to the extent that the utilities have such information).

Central Maine Power had objected to the provision of (1) customer phone number; (2) customer email address; and (3) average monthly usage, citing privacy concerns

CMP also had raised data security concerns with respect to customer privacy, stating that in the case of vendors hired directly by CMP that receive confidential information from CMP, such vendors are required to sign a Data Security Rider to the applicable contract for services. CMP suggested that similar obligations be incorporated into future agreements with Maine Green Power providers.

The PUC did not specifically address CMP's suggestion to require such obligations for Maine Green Power providers receiving the customer information

The PUC did state, however, that, "It is with a high degree of caution that the Commission entrusts the release of customer utility information to a third-party, and 3Degrees is expected to handle this information with an acceptable standard of care and guard its knowledge of customer information, as well as electronically protect the information."

Docket No. 2015-00339

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