Why We Must Secure Digital Rights Within UK Hydrogen Infrastructure
Hydrogen has become an increasingly important component of UK decarbonisation strategy, as part of its commitments under the Paris Agreement to reach net-zero emissions by 2050. Hydrogen’s role in decarbonising “hard-to-abate sectors”, such as heavy transport, is today recognised in the UK, which issued its first Hydrogen Strategy in 2021, with the aim to reach 10 GW by 2030. In 2023, this was followed up with two successful safety trials (Hydeploy and FutureGrid) that confirmed the technical feasibility of blending current butane with 20% of Hydrogen. This year, the first operational hydrogen projects are expected (HAR1) with 125 MW of installed capacity.
The Powering Up Britain plan framed hydrogen deployment as central not only to decarbonisation but also to security of supply¹, especially in the context of Russia’s invasion of Ukraine. The UK government noted in 2022 that “recent geopolitical events have shown the need to move away from volatile global fossil fuel markets and strengthen our energy independence”². Although the UK imports little gas directly from Russia, the resulting volatility in global gas markets exposed the vulnerability of fossil fuel dependency and sharpened the strategic rationale for low-carbon hydrogen as a long-term substitute for natural gas³.
As the UK moves decisively towards a future with hydrogen, the furthering of digital infrastructure is becoming both a technical and strategic priority. Smart meters, in particular, enhance the ability to accurately measure energy use when gas composition changes from butane to hydrogen, playing a growing role in enabling hydrogen deployment. The reliability of first and second generation smart meters (SMTS 2 and SMTS1) under a 20% hydrogen blend has dominated discussions, aiming at ensuring no replacement costs are incurred. Yet while smart-meters hardware has been the centre of attention, little has been said about the significant software upgrades that are being prepared alongside the 20% hydrogen blend.
The UK's hydrogen deployment timeline is converging with significant smart meter infrastructure expansion in ways that create an opportunity for enhanced behavioural surveillance through the convergence of several parallel trends. The Energy Networks Association's announcement that Britain's gas grid will be ready for 20% hydrogen blending from winter 2023/4⁴, coincides with the government's January 2025 call for evidence on energy Smart Data schemes aimed at creating "new business models" for third-party energy data access. Simultaneously, the commercial data analytics sector is positioning for expansion with Grid4C developing AI platforms to "extract maximum business value out of smart meters" for "new revenue streams".⁵
While hydrogen deployment itself doesn't technically require enhanced smart meter surveillance capabilities, this convergence of infrastructure modernisation, commercial data frameworks, and government policy development creates momentum that could enable the data extraction industry to bundle expanded monitoring features with legitimate hydrogen infrastructure upgrades. The scale and timing of these parallel developments - which affects millions of homes simultaneously during a period of regulatory flux - may provide the political and technical cover for implementing surveillance capabilities that extend far beyond what hydrogen safety actually requires.
The Extent Of Household Data Collection By Smart Meters
The gap between today's basic periodic data collection and hydrogen's genuine continuous safety monitoring requirements creates the perfect justification for dramatically expanded software capabilities - including all the behavioural surveillance features that aren't needed for actual safety but could be bundled in under "enhanced safety monitoring."
The issue therefore lies in the fact that hydrogen blending is the opportunity for much more frequent and granular collection of household data than before. This level of data collection effectively reveals Households’ behavioural patterns in real time not just energy consumption. Hydrogen sensors can reveal: cooking methods (searing vs. simmering), health indicators (fresh cooking vs. instant foods), room-level presence (which bathroom's water heater fired tracking individual family members), and routine changes that suggest illness or depression. They detect cultural patterns through flame modulation (wok technique with rapid flame cycling or These privacy risks are not theoretical. Real-world cases demonstrate how this data gets exploited. In the UK, energy suppliers have used consumption data to make decisions about payment methods, including the controversial forced installation of prepayment meters in vulnerable households by British Gas. In the US, California and Ohio police routinely access utility records without warrants to identify potential illegal operations; insurers purchase usage patterns to adjust premiums; and utilities have shared customer data with police over 500 times for general "lifestyle" profiling. Hydrogen blending's technical requirements may provide perfect cover for expanded surveillance.
Data Governance Frameworks For New Generation Smart Meters Are Ill-Defined
Several specific GDPR vulnerabilities could be systematically exploited under hydrogen deployment. The new Data (Use and Access) Act 2025 creates "recognised legitimate interests" that remove the requirement for "detailed legitimate interests assessment which balances the data controller's interest against the individual's interest" for processing deemed to have societal value, potentially covering hydrogen safety monitoring. Current smart meter data protection relies on the principle that "data protected by GDPR generally requires opt-in consent to access, unless suitably aggregated or otherwise anonymised," but contains provisions for accessing protected data if 'substantial public interest' can be demonstrated - yet "substantial public interest is not in itself defined either in the GDPR or UK Data Protection Act". Additionally, government practice already demonstrates extensive data sharing justified under "public task" legal basis, with energy data "shared with third parties such as other government departments, regulatory bodies and independent evaluation contractors" and retained for up to 3 years. These existing regulatory exemptions, combined with hydrogen's safety imperatives and essential service status, could systematically override individual privacy rights while maintaining technical GDPR compliance through vital interests (Article 6(1)(d)) and public interest (Article 6(1)(e)) justifications.
Yet, decisions are being made without addressing data governance gaps. Current regulatory frameworks focus on technical requirements such as "measurement accuracy" and "risk management" while largely ignoring questions of data collection, consumer consent, algorithmic transparency, or digital rights protections. Infrastructure investment creates technological and financial dependencies that become difficult to modify once established. Once hydrogen-compatible metering systems are upgraded and private capital is invested, retrofitting privacy protections becomes exponentially more expensive and politically challenging.
Energy-usage Data Surveillance Is A Privacy Infringement
Current smart meters already create significant privacy risks that hydrogen deployment could entrench. Research demonstrates that energy consumption data can reveal intimate details about household activities and occupants. Hydrogen blend further requires smart meters to distinguish between natural gas and hydrogen blend consumption patterns. This alone creates new data collection beyond what smart meters currently do. Smart meters will have to (i) collect data at a much higher frequency that today’s 30-min readings, providing a more granular usage patterns, (ii) track gas composition for billing accuracy, revealing appliance usage and providing input for more detailed behavioural inference.
High-frequency smart meter data enables identification of specific devices such as microwaves, water heaters, televisions, and cooking appliances⁶⸴⁷. This granular analysis can infer when occupants are home, their daily routines, meal preparation patterns, and changes in household behaviour that may suggest illness, financial stress, or other personal circumstances. When combined with additional data sources such as postal codes or demographic information, energy consumption profiles can be used to infer characteristics including household composition, employment patterns, and economic status. The UK's Information Commissioner has noted that such detailed profiling may constitute processing of personal data, requiring specific protections under data protection law.
This Matters Now: The Policy Window Is Closing
We are currently in a window of opportunity to cement privacy and personal data rights into hydrogen infrastructure. However, there is an urgent need to act quickly, because of the following three converging factors:
Regulatory decisions are being made now: Ofgem's RIIO-3 framework consultations (2025-26) will establish the investment and governance principles for hydrogen infrastructure for the next decade. Once these frameworks are locked in, retrofitting privacy protections becomes exponentially more difficult and expensive. Ofgem's Future Billing Methodology consultation is establishing technical and commercial arrangements for hydrogen billing, including data collection and processing requirements
Technical standards are already being set: The British Standards Institution is currently developing technical specifications for hydrogen-compatible meters and monitoring systems. Data governance requirements must be embedded at the technical standard level, not bolted on afterward.
Investment flows have already started: Energy companies are making major capital allocation decisions for hydrogen infrastructure and R&D.
While DESNZ focuses on safety and technical feasibility, and Ofgem examines cost recovery, no regulatory body is systematically addressing the data governance implications. The result is policy fragmentation where hydrogen deployment proceeds without adequate digital rights protections. This represents a missed opportunity: infrastructure transitions are moments when new governance frameworks can be established more easily than after systems become operational.
The UK government has endorsed hydrogen blending into gas networks, with trials like HyDeploy and FutureGrid demonstrating technical feasibility. But the digital infrastructure supporting this transition is advancing with minimal public scrutiny or governance oversight. Rather than using this transition as an opportunity to strengthen data governance, current policies risk establishing surveillance-enabled infrastructure for decades through hydrogen-specific investment commitments.
To avoid embedding today's data risks into tomorrow's clean energy systems, the UK must use the hydrogen rollout as an opportunity to reform energy data governance. Privacy-by-design, data minimisation, consumer consent, and algorithmic transparency should be prominent regulatory considerations, not afterthoughts. Without them, decarbonisation of heating may come at the recompense of digital rights at home.
References
DESNZ (2023). Powering Up Britain. Department for Energy Security and Net Zero
DESNZ (2022). UK Hydrogen Strategy: Update to the Market. Department for Energy Security and Net Zero
IEA (2023). United Kingdom 2023 Energy Policy Review. International Energy Agency
UK Hy4Heat programme: hydrogen smart meters and components for domestic use will be provided by Pietro Fiorentini - Pietro Fiorentini [Internet]. Pietro Fiorentini. 2023 [cited 2025 Aug 30].
Grid4C I. Grid4C - AI Powered Energy Analytics [Internet]. Grid4c.com. 2021. Available from: https://www.grid4c.com/
Greveler, U., Justus, B., & Loehr, D. (2012). Multimedia content identification through smart meter power usage profiles. Computers, Privacy and Data Protection Conference.
Molina-Markham, A., Shenoy, P., Fu, K., Cecchet, E., & Irwin, D. (2010). Private memoirs of a smart meter. Proceedings of the 2nd ACM Workshop on Embedded Sensing Systems for Energy-Efficiency in Building.
Pasquale, F. (2020). The Black Box Society: The Secret Algorithms That Control Money and Information. Harvard University Press.
