Use Your Thumbprint To Enroll For Texas Retail Electricity Service?

In a Texas PUC rulemaking addressing the use of portable electronic devices (PEDs) for customer enrollment during door-to-door sales, TXU Energy has suggested that, in addition to the proposed use of electronic signatures, the two-step verification process required for use of a PED-based enrollment allow other uniquely identifiable inputs from the applicant, such as a thumbprint.

As previously reported, the proposed rule for PED enrollments would require the customer to provide an electronic signature at two separate points during the enrollment process -- the first during authorization disclosures via PED, and the second during verification of the authorization.

In an initial round of comments, TXU said that, "TXU Energy agrees with the concept of dual verification as it would also help ensure that customers are present for the entire enrollment process and effectively provides the same level of protections that exists through telephonic verification; however, there is no need to strictly limit the requirement to electronic signatures."

In reply comments, TXU has specifically suggested that uniquely identifiable input from the applicant that could be used in addition to an electronic signature could include thumbprints.

"We believe the proposed rule's strict limitation to electronic signatures could inadvertently prevent REPs from utilizing existing PED technology that would capture affirmations from the customer in a method that is as or more secure than an electronic signature. While an electronic signature can be difficult to authenticate, allowing the customer to directly input into the PED a unique identifier such as one of the account access verification data, an audiovisual recording, or even a thumbprint, would be much stronger evidence of affirmative customer consent to enrollment," TXU said

"[S]ome REPs may prefer to utilize an alternative method of documenting authorization and verification that provides an equivalent or even greater level of protection than an electronic signature such as asking a customer to enter one of the account access verification data options or provide a biometric signature," TXU said

"TXU Energy would again submit that requiring customers to enter some type of unique identifier, either information known only to the customer and not the agent, or a biometric trait that can only be tied directly to the customer, offers an 'equivalent' level of protection [to the proposed third-party TPV requirement proposed by certain parties]. It is highly unlikely that a door-to-door agent intending to submit unauthorized enrollments would have proprietary information such as a driver's license number or social security number, and virtually impossible that such an agent could work around a requirement to have a customer's biometric information such as a finger print," TXU said