Submissions

To: Ministry of Business, Innovation & Employment
Date: October 2024

Purpose

This submission’s primary purpose is to welcome the proposed establishment of an EDR as a tool to empower consumers, particularly disabled people who face significant energy hardship and have higher electricity needs. DPA also raises important concerns and provides recommendations regarding data accessibility for those impacted by the digital divide and associated matters.

Summary of DPA submission

DPA has collaborated with Electricity Allies in advocating for this change, which will help shift the electricity marketplace towards customers. DPA emphasizes that having good customer information matters to the disability community, as many disabled people require a stable power supply while navigating significant energy hardship and poverty. Disabled people are more likely to live in cold, damp, mouldy homes requiring more heating/cooling, and need more electricity for disability-related equipment, leading to additional energy-related costs. This often forces disabled people to choose between heating, eating, or doctor's visits, potentially leading to mounting debts or disconnection.

DPA agrees that full monitoring of a customer’s electricity usage by retailers could on disabled people must be factored into any changes. DPA notes that the disabled community continues to experience a reduced ability to engage with digital and online services compared to non-disabled people. DPA is concerned about the risk of data breaches compromising consumer information privacy. DPA does not support the charging of fees for data requests, as this would be prohibitive for many low-income and disabled customers who may need frequent access to data.

Key Recommendation:

DPA recommends that alternatives to getting information and data to customers who have limited or no access to digital and online services is retained.

Supporting Statement 1:

A Department of Internal Affairs report (2020) on digital access by disabled people showed that the disabled community continue to experience a reduced ability to engage with digital and online services compared to non-disabled people.

Supporting Statement 2: This could include, for example, the ability to request data be sent by post/courier, customers still contacting retailers by phone, and retailer representatives calling in person at customer’s homes to discuss their usage.