PRIVACY POLICY STATEMENT

Preface

Kitchener-Wilmot Hydro Inc. is committed to keeping the personal information of its customers accurate, confidential, secure and private. Our Privacy Policy has been designed to inform employees, subcontractors and customers of Kitchener-Wilmot Hydro Inc. of our commitment and recognition to our obligation to meet the spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Contents

Our Privacy Policy describes the principles by which Kitchener-Wilmot Hydro Inc. 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 the customers' rights in respect of this information. Our Privacy Policy incorporates and expands the ten principles for the protection of personal information, as devised 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. Kitchener-Wilmot Hydro Inc. does, however, protect the confidentiality of such information in accordance with the law and our own policies.

Personal Information Protection Principles

  1. Accountability

    Kitchener-Wilmot Hydro Inc. 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. Kitchener-Wilmot Hydro Inc. will require a comparable level of protection of this information from its third party relations.

    Our Privacy Officer, has overall responsibility for our protection of personal information and for Kitchener-Wilmot Hydro Inc.'s compliance with this Privacy Policy.

  2. Identifying Purposes
    Personal information that Kitchener-Wilmot Hydro Inc. collects from customers includes:
    • the customer's name and address and other contact information, such as telephone numbers, e-mail addresses;
    • the meter number;
    • facts about consumption of power, both historic and current;
    • information about a customer's transactions with us, such as account numbers, account balances, payment history;
    • credit and reference information, such as date of birth, employment information, drivers license, previous addresses, and general financial information;
    • medical information to be used in case of emergency power outages;
    • bank information for pre-authorized payments.

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

    • Billing and collection of payment for electric services
    • Pre-authorized payment for services
    • Priority restoration of electrical service to the correct address and meter, as may be required by medical circumstances
    • Energy sector legal, regulatory and settlement requirements
  3. Consent

    Kitchener-Wilmot Hydro Inc. 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 or personal information about them expressly or implicitly. Kitchener-Wilmot Hydro Inc. 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 Kitchener-Wilmot Hydro Inc. with any inquiries. All new customers will be provided with a consent form and an accompanying explanation about the collection, use and disclosure of their personal information when requesting service.

  4. Limiting Collection

    Kitchener-Wilmot Hydro Inc. limits the amount and type of personal information it collects to that which is necessary for the business of the corporation. Personal information will be collected using procedures, which are fair, transparent and lawful. Each affiliate of Kitchener-Wilmot Hydro Inc. will be responsible for its own collection, use, disclosure, and protection of information.

  5. Limiting Use, Disclosure and Retention

    Kitchener-Wilmot Hydro Inc. 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. Kitchener-Wilmot Hydro Inc. 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, Kitchener-Wilmot Hydro Inc. may have a legal duty or right to disclose personal information without the individual's knowledge or consent.

  6. Accuracy

    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.

  7. Safeguards

    In executing its responsibilities with respect to the confidentiality of personal information, Kitchener-Wilmot Hydro Inc. 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 controlled access to cabinets, restricted access to offices, security clearances and limiting access on a "need to know" basis, electronic access controls, firewalls 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.

    Hard copy documents containing Personal Information will be destroyed (i.e. shredded) or made anonymous when no longer required by Kitchener-Wilmot Hydro Inc.

  8. Openness

    Kitchener-Wilmot Hydro Inc. will make its polices and practices relating to the protection of personal information available to its customers. Kitchener-Wilmot Hydro Inc. will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via Kitchener-Wilmot Hydro Inc.'s web page and bill inserts. The information will be available in a format that is easy to understand.

  9. Individual Access

    Any customer of Kitchener-Wilmot Hydro Inc. can have access to the personal information about them that Kitchener-Wilmot Hydro Inc. 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 519.743.3600, or in writing to us at PO Box 9021, Kitchener, Ontario N2G 4P1. Response to an individual's request will be made in a timely and efficient manner.

  10. Challenging Compliance

    Any customer of Kitchener-Wilmot Hydro Inc. may challenge Kitchener-Wilmot Hydro Inc.'s compliance with this Privacy Policy by contacting Kitchener-Wilmot Hydro Inc. directly. Kitchener-Wilmot Hydro Inc. has policies and procedures to receive, investigate and respond to individual's complaints and questions. If the customer is not satisfied with the way Kitchener-Wilmot Hydro Inc. has responded to a complaint, the customer can contact the Privacy Commissioner of Canada.

PIPEDA Consent Form