Internet of things
Vodafone is a world leader in the supply of Machine-to-Machine (M2M) services, and we have customers in many different industry segments (including automotive, utilities, manufacturing and consumer electronics) that have integrated M2M functionality into their business processers.
We engage with policymakers to share our experiences of how this technology is being deployed and used by our business customers. In doing so, we make policy recommendations on the communications policy framework that we believe should underpin this important growth area of the economy. Vodafone’s response to the European Commission’s consultation on Europe’s policy options for a dynamic and trustworthy development of the Internet of Things, which concluded in August 2013, can be found here. Our July 2014 submission to BEREC’s M2M working group on an appropriate regulatory framework for M2M can be found here.
Vodafone’s view is:
- There should be a presumption in favour of industry self-regulation
The M2M market is evolving very quickly. If there are regulatory concerns, there should be a presumption in favour of industry agreed codes of conduct. Industry self-regulation is already evident in this area, for example the numerous activities being undertaken by the GSMA. If self-regulation is not appropriate, there should be a ‘light touch’ regulatory approach.
- Mandate for public policy benefits associated with M2M
Mandatory obligations and controls should not be introduced unless there is a very clear public interest, for example in relation to carbon savings or public safety.
In Sweden, the rollout of smart meters was prompted by legislation that each household should be able to accurately monitor monthly electricity consumption by July 2009. This led to Sweden becoming a world leader in M2M as a share of total connections.
- Enable new business models for M2M services
The industry successfully relies on global roaming agreements (via locally licensed operators) for delivery of M2M communications. If this was not allowed, pan-national M2M providers would in theory need to configure hundreds of different variants of a ‘global’ M2M service, involving country specific IMSI codes, unprecedented logistical complexity and additional roaming agreements. This would stifle innovation.
- Ensure necessary safeguards via tools such as Privacy by Design, Security by Design and Privacy Impact Assessments
Rely on existing ‘horizontal’ regulatory frameworks, and the measures outlined above. For example, in 2012 the European Commission published a recommendation on the rollout of smart meters which included guidelines for Member States on data privacy, including Privacy Impact Assessments. This approach has now been applied in Member States.