PERSONAL INFORMATION PROTECTION PRINCIPLES
Whitby Hydro Energy Services is accountable for the protection of all personal information within the organization’s possession or control, including any personal information that has been transferred to a third party for regulatory, legal or processing purposes. Whitby Hydro Energy Services will require a comparable level of protection of this information from its third party relations.
2. Identifying Purposes
Personal information that Whitby Hydro Energy Services collects from customers includes: the customer’s name and address and other contact information; the meter number; facts about consumption of power, both historic and current; facts about payment for electric service, including general financial information; credit and reference information, such as date of birth, employment information, drivers license, previous addresses, telephone numbers, e-mail address, medical information to be used in case of emergency power outages, and bank information requested for pre-authorized payments.
When an individual applies for service, Whitby Hydro Energy Services will make the individual aware of the purposes for which Whitby Hydro is requesting the personal information. If Whitby Hydro Energy Services identifies other purposes for which the personal information may be used, Whitby Hydro Energy Services will seek the individual’s consent prior to such use. Whitby Hydro Energy Services will advise that it is the individual’s right to refuse permission for Whitby Hydro Energy Services to use personal information for any new purposes.
Additional purposes for collecting personal information may be identified to an individual before or at the time of collection. However, at a minimum Whitby Hydro Energy Services will collect personal information for the following purposes:
_ Billing and collection of payments for electric service
_ Pre-authorized payment for services
_ Priority restoration of electric service to the correct address and meter, as may be required by medical circumstances
_ Energy sector legal, regulatory and settlement requirements
Whitby Hydro Energy Services will obtain consent before or when it collects, uses or discloses personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information about them expressly or implicitly. Whitby Hydro Energy Services will collect, use or disclose personal information without an individual’s consent only in limited circumstances as permitted by law. Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time.
All existing customers will be informed of what types of personal information have been collected, the purpose for the collection and the procedures available for contacting Whitby Hydro Energy Services with any inquiries. All new customers will be provided with an explanation about the collection, use and disclosure of their personal information when requesting service.
4. Limiting Collection
Whitby Hydro Energy Services limits the amount and type of personal information it collects to that which is necessary for the business of the utility. Each affiliate of Whitby Hydro Energy Services will be responsible for its own collection, use and disclosure of information. Personal Information will be collected using procedures which are fair, transparent and lawful.
5. Limiting Use, Disclosure and Retention
Whitby Hydro Energy Services will only use the personal information for the purpose for which it was collected as identified in principle #2, unless consent is given by the individual to use or disclose it for another purpose. In accordance with the Affiliates Relationship Code, created under the provincial Electricity Act, no customer information will be disclosed by one affiliate to another. In other words, no customer personal information will be shared by the distribution company and the energy services company.
Whitby Hydro Energy Services will develop explicit retention periods for closed accounts (zero balance), after which the personal information will be destroyed or made anonymous.
Under certain exceptional circumstances, Whitby Hydro Energy Services may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.
In order to ensure the reliable delivery of electric service and the correct billing for such service, all personal information will be kept accurate, complete and up to date. Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.
In executing its responsibilities with respect to the confidentiality of personal information, Whitby Hydro Energy Services will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances and limiting access on a “need to know” basis and use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.
Whitby Hydro Energy Services will make this policy relating to the protection of personal information available to its customers.
9. Individual Access
Any customer of Whitby Hydro Energy Services can have access to the personal information about them that Whitby Hydro Energy Services has in its possession or control. Any customer may request that their personal information be amended for purposes of accuracy and completeness.
Customers can make their requests by telephone 905-668-5878, via email firstname.lastname@example.org or in writing to Whitby Hydro Energy Services, 100 Taunton Road East, Whitby, Ontario L1N 5R8 Attention: Privacy Office. Response to an individual’s request will be made in a timely and efficient manner.
10. Challenging Compliance