Privacy Statement

Table of Contents

• Statement
• Content
• Personal Information Protection Principles
• Principle 1 – Accountability
• Principle 2 – Identifying Purposes
• Principle 3 – Consent
• Principle 4 – Limiting Collection
• Principle 5 – Limiting Use, Disclosure and Retention
• Principle 6 – Accuracy
• Principle 7 – Safeguards
• Principle 8 – Openness
• Principle 9 – Individual Access
• Principle 10 – Challenging Compliance

Our Statement Back to top

Oakville Hydro Corporation (Oakville Hydro) is committed to keeping the Personal Information of its customers accurate, confidential, secure and private. This Privacy Policy has been designed to inform officers, employees, contractors, agents and customers of Oakville Hydro, of our commitment to and recognition of our obligation to meet the spirit and terms of the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).

Content Back to top

This Privacy Policy describes the principles Oakville Hydro will use to protect the privacy of Personal Information of customers in its possession or control. It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines the customers' rights in respect of this information. This Privacy Policy incorporates and expands the 10 principles for the protection of Personal Information, as established by the Canadian Standards Association (CSA).

For the purposes of this Privacy Policy, "Personal Information" means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal information does not include information that has been aggregated such that an individual's information cannot be identified.

In this Privacy Policy, "Oakville Hydro", "we", "us" or "our" means Oakville Hydro Corporation, and "customer", "you", and "your" means the individual who is a customer or prospective customer whose Personal Information is in our possession or control. However, this Privacy Policy does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. Oakville Hydro does, however, protect the confidentiality of such information in accordance with the law, regulatory codes of conduct issued by the Ontario Energy Board, contractual arrangements and our own policies.

By accepting service from us, using our Website, or otherwise providing us with your Personal Information, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time. The terms in this Privacy Policy may be changed from time to time, so you should review it for changes periodically on our Website at www.oakvillehydro.com

Personal Information Protection Principles Back to top

• Accountability : An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with privacy principles.
  
  
• Identifying Purposes: The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
  
  
• Consent : The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
  
  
• Limiting Collection : The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
  
  
• Limiting Use, Disclosure, and Retention : Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information must be retained only as long as necessary for the fulfillment of those purposes.
  
  
• Accuracy : Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
  
  
• Safeguards : Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
  
  
• Openness : An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
  
  
• Individual Access : Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
  
  
• Challenging Compliance : An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.

Accountability Back to top

Oakville Hydro is accountable for all personal information in its possession or control and shall designate one or more persons who will be responsible for the Company’s compliance with the following principles:

The President & Chief Executive Officer (CEO) of Oakville Hydro has ultimate responsibility for the protection of personal information of customers. The CEO may delegate the day-to-day operational privacy responsibilities to another individual. All staff share responsibility for adhering to Oakville Hydro’s privacy policies and procedures.

• Oakville Hydro has designated a Corporate Privacy Officer to oversee compliance of the Oakville Hydro Privacy Policy. The Corporate Privacy Officer is responsible for Oakville Hydro’s privacy policies and practices and to whom privacy complaints or inquiries may be forwarded: Maryanne Wilson can be reached by e-mail at privacyofficer@oakvillehydro.com or by telephone at 905-825-9400.

Oakville Hydro is responsible for personal information in their possession or control, including any personal information that has been transferred to a third party for processing. Oakville Hydro will use contractual or other means to provide a comparable level of protection of personal information while such information is being processed by a third party.

Oakville Hydro shall implement policies and procedures to give effect to the Oakville Hydro Privacy Policy including:

• implementing procedures to protect personal information and to oversee the company’s compliance with MFIPPA;
• establishing procedures to receive and respond to inquiries or complaints with respect to an individual’s personal information; and
• training staff and communicating to staff about the company’s privacy policies and practices.

Identifying Purposes Back to top

Oakville Hydro will identify the purposes for which it collects Personal Information at or before the time the information is collected, such as when you apply for service from us. If Oakville Hydro identifies other purposes for which any Personal Information we have collected from you may be used, Oakville Hydro will seek your consent before such use. You may refuse permission for Oakville Hydro to use your Personal Information for any new purpose unless the new purpose is required or permitted by law or regulatory authorities. However, refusal to provide such consent may prevent us from providing you with some services since we require a minimum amount of Personal Information about you to provide electricity distribution services to you.

At a minimum, Oakville Hydro collects Personal Information from customers for the following purposes:

• To identify or contact customers, respond to customer inquiries and otherwise maintain business relations with customers;
• To deliver and maintain electricity service;
• To bill and collect payment;
• To establish credit worthiness;
• To sign up for pre-authorized payment;
• For legal, regulatory and electricity market operation requirements;
• To help prevent or investigate fraud, theft of power or other breaches of the law;
• To provide customers with information about Oakville Hydro services, the electricity industry and rates;
• To request customer participation in surveys or contests; and
• To notify customers about events or causes sponsored by Oakville Hydro or its parent company, Oakville Hydro Corporation.

Oakville Hydro may monitor and/or record any telephone conversation with you for quality assurance and training purposes.

Those responsible for collecting personal information should be able to explain to individuals the purposes for which the information is being collected. In certain circumstances, the customer may be referred to a designated person within Oakville Hydro who can explain those purposes in greater detail.

Unless required by law, Oakville Hydro shall not use or disclose, for any new purpose, personal information that has already been collected without first identifying and documenting the new purpose and obtaining the consent of the customer.

Consent Back to top

Oakville Hydro will obtain your consent before, or when, it collects, uses or discloses your Personal Information. Your consent to the collection, use and disclosure of your Personal Information may be either express or implied, depending on the circumstances, the purposes for which such Personal Information is being collected and the sensitivity of the information. Consent may be obtained directly from you or from a third party that has obtained your consent to disclose your Personal Information to Oakville Hydro. For example, if you sign a separate contract with a retailer, Oakville Hydro may obtain your Personal Information from the retailer and Oakville Hydro may provide your billing and consumption information to the retailer. Consent may also be given by an authorized representative such as a legal guardian or person with power of attorney.

Oakville Hydro will not use or disclose your Personal Information for purposes other than those for which it was collected except with your consent or as permitted or required by law or regulatory authorities.

Oakville Hydro will collect, use or disclose your Personal Information without your knowledge or consent only in limited circumstances as permitted or required by law or regulatory authorities. Subject to certain legal and contractual restrictions and reasonable notice, you can refuse or withdraw your consent to the collection, use or disclosure of your Personal Information at any time. However, refusal to provide such consent, or withdrawal of such consent, may prevent us from providing you with some services since we require a minimum amount of Personal Information about you to provide electricity distribution services to you. Oakville Hydro will explain the implications of such withdrawal or refusal to provide such consent.

Oakville Hydro will not, as a condition of supplying you with a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the specified, legitimate purpose.

Under certain exceptional circumstances, Oakville Hydro may have a legal duty or right to collect, use or disclose your Personal Information without your knowledge or consent.

Because of the structure of the electricity sector in Ontario, it may be necessary to share your billing and consumption information with third party billing and settlement agencies, such as where you have signed a separate contract with a retailer. Your information may also be shared or disclosed to other agencies or organizations as required or permitted by law or regulatory authorities. Our billing, settlement and regulatory relationships with third parties are governed by our license and regulatory codes that are established by the Ontario Energy Board.

In accordance with applicable laws, Oakville Hydro will not disclose any consumer information (which may include Personal Information) to any of its affiliates without the consumer's written consent except where consumer information is required to be disclosed:

• For billing or market operation purposes
• For law enforcement purposes.
• For the purpose of complying with a legal requirement
• For the processing of the consumer's past due accounts which have been passed to third parties for collection.
  

Oakville Hydro will retain Personal Information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations.

Oakville Hydro will not trade, rent or sell your Personal Information. However, in the course of a business transaction, such as a proposed sale of Oakville Hydro Electricity Distribution Inc's business or assets (or a part thereof), or a merger or amalgamation of Oakville Hydro with another company, we may disclose your Personal Information to third parties such as prospective purchasers of Oakville Hydro Electricity Distribution Inc's shares, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction.

Limiting Collection Back to top

Oakville Hydro shall limit the amount and type of personal information it collects to that which is necessary for the purposes identified by the company. Oakville Hydro shall collect personal information using procedures which are fair and lawful.

The types of Personal Information that Oakville Hydro usually collects from individual customers include:

• Customer name and address (mailing and service address) and other contact information (i.e. home and work telephone numbers and e-mail addresses);
• Facts about historic and current consumption of power for your home or business;
• Customer transactions with Oakville Hydro (i.e. account number, account balances, payment history, and account activity);
• General financial information (i.e. credit card number, credit and reference information, and employment information);
• Identifying information (i.e. date of birth, driver's license);
• Medical information to be used in case of planned power outages;
• Bank information requested for pre-authorized payments; and
• Information we receive from you through your correspondence or communications with us. Depending on the circumstances, we may collect some or all of the Personal Information listed above from individual customers.

Limiting Use, Disclosure and Retention Back to top

Oakville Hydro shall not use or disclose personal information for purposes other than those for which it was collected, unless consent is given by the individual to use or disclose it for another purpose or as required by law. Oakville Hydro shall retain personal information only as long as necessary for the identified purposes.

If Oakville Hydro uses personal information for a new purpose, it will document this purpose.

With the consent of the customer, Oakville Hydro may disclose a customer’s personal information to the following:

• an agent retained by Oakville Hydro in connection with the collection of the customer’s account; credit grantors and reporting agencies;
• a person who, in the reasonable judgment of Oakville Hydro, is seeking the information as an agent of the customer; and
• any other third party or parties, where the customer has provided consent to such disclosure or disclosure as required by law.

Oakville Hydro shall maintain reasonable and systematic controls, schedules and practices for the protection of personal information. Record retention, which shall include minimum and maximum retention periods, and destruction shall apply to personal information. Information that is no longer necessary or relevant for the identified purposes for which it was collected or required by law to be retained shall be destroyed.

• Oakville Hydro will keep personal information only as long as necessary for the identified purposes.

Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous. Oakville Hydro will develop guidelines and implement procedures to govern the destruction of personal information.

Only those employees of Oakville Hydro who require access for business reasons or whose duties reasonably so require, are granted access to personal information about customers.

Accuracy Back to top

Oakville Hydro maintains procedures to ensure all Personal Information we collect and use is kept as accurate, complete and up to date as necessary for the purpose for which it is to be used. However, we rely on you to disclose all material information to us and to inform us of any errors or changes in such information.

Individuals may challenge the accuracy and completeness of Personal Information about them and have it amended, as appropriate, as set out in Section 8 below.

Safeguards Back to top

Oakville Hydro shall protect personal information from loss or theft, unauthorized access, disclosure, copying, use, modification or destruction through appropriate security measures. Oakville Hydro shall protect all personal information regardless of the format in which it is held.

The nature of the safeguards will vary depending on the sensitivity of the information, amount, distribution, format and the method of storage of the personal information. Oakville Hydro will give the highest level of protection to the most sensitive personal information.

The methods of protection should include:

• Physical security, such as locked filing cabinets and restricted access to offices;
• Organizational security, such as security clearances and limiting access on a “need to know” basis; and
• Technological security, such as, the use of passwords and encryption.

Oakville Hydro will make all of its employees aware of the importance of maintaining the confidentiality of personal information.

Openness Back to top

Oakville Hydro shall make readily available to customers specific information about its policies and practices relating to the management of personal information.

Oakville Hydro will be open about the policies and practices used to manage personal information. Individuals will have access to information about these policies and procedures. This information will be available in a format that is easy to understand.

Oakville Hydro shall make the following information about its privacy policies and practices available:

• how to gain access to personal information held by Oakville Hydro;

• a description of the type of personal information held by Oakville Hydro including a general account of its use; and

• a copy of any brochure or other information that explains Oakville Hydro’s privacy policies, standards or codes.

Individual Access Back to top

Upon request, an individual shall be informed of the existence, use, disclosure of his or her personal information in Oakville Hydro’s possession and shall be given access to that information.

A customer shall be able to challenge the accuracy and completeness of the information and have it amended where necessary. In certain situations, Oakville Hydro may not be able to provide access to all the personal information it holds about an individual. However, such exceptions are limited and specific. Exceptions may include information that contains references to other individuals, information that was supplied in confidence and/or information that cannot be disclosed for legal, security or commercial proprietary reasons.

• Upon request, Oakville Hydro shall inform an individual of the personal information that Oakville Hydro has in its possession or control about that individual.
• Upon request, Oakville Hydro shall provide an account of the use and disclosure of such personal information and, where reasonable and possible, shall state the source of the information.
• In order to safeguard personal information, a customer may be required to provide sufficient information to properly identify them to assure Oakville Hydro that they are providing information with respect to the existence, use and disclosure of personal information and authorizing access to an individual’s file to the right individual. Any information provided for identification purposes shall only be used for such purpose.
• In providing a list of third parties that Oakville Hydro has disclosed personal information about a customer to, Oakville Hydro will provide as much information as possible to the customer. When it is not possible to provide a list of third parties to which it has actually disclosed information to about an individual, Oakville Hydro shall provide a list of third parties to which it may have disclosed information to about the individual.
• Oakville Hydro shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Oakville Hydro will share with third parties who have had access to such personal information any amended information and identify the existence of any unresolved differences.

Challenging Compliance Back to top

Customers can make their requests by contacting Oakville Hydro by telephone at (905) 825-9400, by fax to (905) 825-4447, by e-mail to the attention of privacyofficer@oakvillehydro.com, or in writing to Oakville Hydro Electricity Distribution Inc., Customer Service, Box 1900, 861 Redwood Square, Oakville, L6K 0C7 and our customer service representatives will assist them. Response to a customer's request will be made within 30 days, provided the request is made in writing, the size of the requested information does not require additional time and the customer provides satisfactory proof of the customer's identity.