Are there any exceptions to the Municipal Utility Customer Privacy Law?

Yes. There are five exceptions. A municipal utility may release Customer Information to:

Exception 1: Agents, vendors, partners, or affiliates of the municipal utility that are engaged to perform any services or functions for or on behalf of the municipal utility.
 
This exception would encompass entities providing services to or on behalf of the utility, such as the utility’s power supplier, AMI vendors, third-party vendors for on-line bill payments, or another department within the municipality itself.

Exception 2: Transmission and distribution utilities and operators within whose geographic service territory the customer is located.

For example, if the municipal electric utility receives service from the American Transmission Company and the company requests the utility to provide it with Customer Information, the utility may disclose the information to the company.

Exception 3: The Public Service Commission of Wisconsin or any person whom the Commission authorizes by order or rule to receive the Customer Information.

For example, a municipal utility may be required to disclose Customer Information in its reports to the Commission. In that case, the municipal utility would file a public and a non-public version of the report with the Commission so that the information would not become generally available to the public. The public version of the report would black out the Customer Information.

Exception 4: An owner of a rental dwelling unit to whom the municipal utility provides notice of past-due charges pursuant to sec. 66.0809(5) of the Wisconsin Statutes.

For those municipal utilities that have elected to put delinquent utility bills on the tax rolls, they may follow the process set out in Section 66.0809(5), which allows the municipal utility to release to landlords billing information pertaining to their tenants.

Exception 5: Any person who is otherwise authorized by law to receive the Customer Information.

For example, a municipal utility may release specific Customer Information to the police when served with a warrant or an administrative subpoena under the Comprehensive Drug Abuse Prevention and Control Act of 1970.

Whether such information can be released without a warrant or subpoena to the local police (perhaps pursuant to Exception 1) is an open question. The most conservative approach is to not release the information without a warrant or subpoena.