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Welland Hydro's Privacy Policy

Table of Contents 

 

Preface

Welland Hydro-Electric System Corp. (“Welland Hydro”) is committed to keeping the personal information of its customers accurate, confidential, secure and private. Our Privacy Policy has been designed to inform customers, employees, and third-party contractors of Welland Hydro’s commitment and recognition of our obligation to protect customer personal information in its custody or control and meet the terms of the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).

 

Our Privacy Policy describes the principles by which Welland Hydro protects the privacy of personal information in its possession.  It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines customers’ rights in respect of accessing their personal information. Our Privacy Policy incorporates and expands on the ten principles for the protection of personal information, as established by the Canadian Standards Association (CSA).

 

This Privacy Code does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. Welland Hydro does, however, protect the confidentiality of such information in accordance with the law and our own policies.

 

The terms set out in Welland Hydro’s Privacy Policy and Policy Statement may change from time to time.  Please check our website periodically for any revisions.

 

Ten Principles for the Protection of Personal Information

 

 

Principle 1 — Accountability

Welland Hydro 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. Welland Hydro will require a comparable level of protection of this information from its third-party suppliers and contractors. 

 

The President & CEO, in conjunction with the Privacy Officer, has overall responsibility for the protection of personal information and for Welland Hydro’s compliance with this Privacy Policy.

 

Principle 2 – Identifying Purposes

Personal information that Welland Hydro 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;
  •   credit and reference information, such as date of birth, employment information,

        driver’s license, previous addresses, and general financial information;

  •   medical information to be used in case of planned or emergency power outages; and
  •   bank information for pre-authorized payments.

 

When an individual applies for service, Welland Hydro will make the individual aware of the purposes for which Welland Hydro is requesting the personal information.  If Welland Hydro identifies other purposes for which the personal information may be used, Welland Hydro will seek the individual's consent prior to such use.  Welland Hydro will advise that it is the individual's right to refuse permission for Welland Hydro 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 Welland Hydro will collect personal information for the following purposes:

 

a)      to establish and maintain responsible commercial relationships with customers

         and to provide ongoing service; and

b)      to meet all legal, regulatory, settlement, and market operations requirements;

c)      to identify or contact customers, respond to customer inquiries and otherwise

         maintain business relations with customers;

d)      to help prevent or investigate fraud, theft of power or other breaches of the law;

e)      billing and collection of payments for electric service;

f)       to register customers for pre-authorized payment for services;

g)      priority restoration of electric service to the correct address and meter, as may

         be required by medical circumstances;

h)      to provide customers with information about our services, the electricity

         industry, energy conservation and rates;

i)       to request customer participation in surveys or contests; or

j)       to notify customers about events or causes sponsored by Welland Hydro or our

         affiliates.

 

Welland Hydro may:

 

a)      Monitor and/or record any telephone conversations with its customers for

         quality assurance and training purposes.

b)      Share information with third-party service providers who perform services on

         our behalf.  These service providers are given only the information necessary to

         perform those services that we have contracted them to provide and are

         obligated to meet the same privacy standards as Welland Hydro.

 

 

Principle 3 – Consent

Welland Hydro 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.  Welland Hydro 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.  However, refusal to provide such consent or withdrawal of such consent, may prevent the Company from providing some services as it requires a minimum amount of personal information to provide electricity distribution services.

 

 

Principle 4 – Limiting Collection

Welland Hydro limits the amount and type of personal information it collects to that which is necessary for the business of the utility.  Each affiliate of Welland Hydro 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.

 

 

Principle 5 – Limiting Use, Disclosure and Retention

Welland Hydro will only use the personal information for the purpose for which it was collected as identified in Principle 2 - Identifying Purposes, unless consent is given by the individual to use or disclose it for another purpose.  Welland Hydro 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, Welland Hydro may have a legal duty or right to disclose personal information without the individual's knowledge or consent.

 

 

Principle 6 – Accuracy

Welland Hydro maintains procedures to ensure that all personal information it collects is kept as accurate, complete and up to date as possible.  

 

Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.

 

Principle 7 – Safeguards

In executing its responsibilities with respect to the confidentiality of personal information, Welland Hydro 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.  These include; 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.

 

 

Principle 8 – Openness

Welland Hydro will make its policies and practices relating to the protection of personal information available to its customers.  Welland Hydro will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via separate mailings, bill inserts and bill messages.

 

 

Principle 9 – Individual Access

MFIPPA gives customers of Welland Hydro the right to request access to the personal information that Welland Hydro 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 formal requests by email, privacy@wellandhydro.com, online, Freedom of Information Request or by letter to P.O. Box 280, Welland ON L3B 5P6.  Response to an individual’s request will be made within 30 days.

 

 

Principle 10 – Challenging Compliance

Any customer of Welland Hydro may challenge Welland Hydro's compliance with this Privacy Policy by contacting Welland Hydro directly.  Welland Hydro has policies and procedures to receive, investigate and respond to individuals' complaints and questions.  If the customer is not satisfied with the way Welland Hydro has responded to a complaint, the customer can contact the Information and Privacy Commissioner of Ontario at:

 

Information and Privacy Commissioner, Ontario

2 Bloor Street East, Suite 1400,

Toronto, ON M4W 1A8

 

Telephone:     1-800-387-0073 or (416) 326-3333

Fax:                (416) 325-9195

Website:         www.ipc.on.ca

E-Mail:            info@ipc.on.ca