Effective date: March 26, 2019
This Policy applies to individuals only; it does not apply to information about businesses. Toronto Hydro does, however, protect the confidentiality of business customer information in accordance with applicable law, including regulatory codes of conduct issued by the Ontario Energy Board, and contractual arrangements.
Personal information protection principles
Table of contents
- Identifying Purposes
- Consent, Limiting Use, Disclosure and Retention
- Limiting Collection
- Limiting Use, Disclosure and Retention
- Individual Access
- Challenging Compliance
- Toronto Hydro Website
Toronto Hydro is accountable for the protection of personal information within its custody or control, including any personal information that Toronto Hydro has transferred to a third party for processing purposes. Toronto Hydro may engage third parties from time to time to perform services for Toronto Hydro that involve access to personal information. Such third parties may be located outside of Ontario or Canada and, in such instances, the information might be accessed according to the laws in those jurisdictions. Toronto Hydro shall use contractual or other means to provide a comparable level of protection of this information while the information is being processed by such third parties.
Toronto Hydro has privacy and security standards, guidelines, and procedures to support this Policy and improve the protection of personal information.
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2. Identifying Purposes
- To authenticate identity;
- To contact customers (at mailing and/or service address), respond to customer inquiries or service issues, and to otherwise maintain business relations with customers;
- To deliver, monitor and maintain electricity service;
- To monitor and assess quality of service (for example, Toronto Hydro may monitor and/or record telephone communication with you for quality assurance and training purposes);
- To bill and collect payment and maintain records of same (including arrangements for pre-authorized payments through bank account or credit card);
- To determine account eligibility and creditworthiness (for example, through employment and reference checks);
- To provide information to credit bureaus and other utility providers to update credit information;
- To address and respond to issues related to the usage of critical, power dependant, medical equipment during an outage;
- To provide information to third party service providers, such as an electricity retailer with whom you have contracted;
- To minimize, investigate and/or report potentially dangerous use of electricity, error, fraud, theft of power or other breach of law or contract;
- To assist Toronto Hydro with legal matters or proceedings, including preparation for same;
- To facilitate a business transaction involving Toronto Hydro assets, such as a transfer, sale or financing of assets (see further detail below under Limiting Use, Disclosure and Retention);
- To provide customers or members of the public with information about Toronto Hydro services, the electricity industry, rates and energy conservation;
- To facilitate the development, communication, delivery, review or analysis of climate change, conservation and demand management programs by Toronto Hydro or its contractors;
- To request customer or public participation in surveys, contests or other similar activities and initiatives;
- To notify customers or members of the public about events, causes or programs sponsored by Toronto Hydro and to keep track of participation levels and interest in such events;
- To provide individuals with information they have requested, such as financial quarterly reports or news releases;
- To prepare financial records for Toronto Hydro; and
- To meet other legal, regulatory and electricity market operation authorizations and requirements.
The above collections, uses and disclosures, which are not exhaustive, are a necessary part of your relationship with Toronto Hydro.
Toronto Hydro will obtain your consent before, or when, it collects, uses or discloses your personal information, except where collection, use or disclosure is authorized or required by law. For example, by accepting distribution and related services from us, your consent to the collection, use and disclosure of your personal information for the purposes of providing you with such distribution and related services is implied.
Consent may be obtained directly from you or from a third party that has obtained your consent to disclose your personal information to Toronto Hydro. For example, if you sign a separate contract with a retailer, Toronto Hydro may obtain your personal information from the retailer and Toronto 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.
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 certain products or services for which information is necessary.
In certain circumstances under the laws of Canada and Ontario, Toronto Hydro may have a duty or right to collect, use or disclose your personal information without your knowledge or consent.
4. Limiting Collection and Access
Section 34 of MFIPPA requires Toronto Hydro to keep an updated Personal Information Bank, which is defined as “a collection of personal information that is organized and capable of being retrieved using an individual’s name or an identifying number or particular assigned to the individual.” You can contact Toronto Hydro to obtain a copy of the Personal Information Bank at firstname.lastname@example.org.
5. Limiting Use, Disclosure and Retention
Toronto Hydro will use and disclose personal information as reasonable and necessary for the purposes outlined above as otherwise consented to by you, and as authorized or required by applicable law. For example, MFIPPA lists general categories of circumstances where the use and disclosure of personal information is permitted by law under sections 31 and 32 of that statute.
Further, 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. 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 the Affiliates Relationship Code, Toronto 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; or
- for the purpose of complying with a legal requirement.
Toronto 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. Toronto Hydro will not trade, rent or sell your personal information. However, in the course of a business transaction, such as a proposed sale of Toronto Hydro's business or assets (or a part thereof), or a merger or amalgamation of Toronto Hydro with another company, we may disclose (with appropriate safeguards) your personal information to third parties such as prospective purchasers of Toronto Hydro's shares, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction.
Toronto Hydro maintains procedures to ensure that the personal information we collect, use and disclose 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 or annotated, as appropriate, as set out in Section 9 below.
In fulfilling its responsibilities with respect to the confidentiality of personal information, Toronto Hydro will employ a number of safeguards, appropriate to the sensitivity of the specific 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, such as locked filing cabinets, restricted access to offices, security clearances, limiting access on a "need to know" basis, use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and relevant third parties to ensure compliance. It is also important for you to take precautions to protect your personal information such as keeping your user name and passwords confidential.
9. Individual Access
Upon request and with satisfactory proof of the customer's identity, any customer of Toronto Hydro may obtain information regarding the type, use and disclosure, of his, or her, personal information that Toronto Hydro has in its custody or control. Any customer may request that his, or her, personal information be amended for purposes of accuracy and completeness. Where a disagreement regarding the accuracy of a customer’s information cannot be resolved, Toronto Hydro will annotate the information to reflect the disagreement. Toronto Hydro may require the customer to provide access or correction requests in writing. We may also charge a nominal fee for responding to such requests, and, if so, will advise you in advance of such costs. This right of access, however, is not absolute. For instance, Toronto Hydro may refuse to provide you with access to your personal information where such refusal is authorized or required by law or regulatory authorities.
Customers can make their requests by contacting Toronto Hydro by telephone at 416-542-8000, by fax to 416-542-3452, or in writing to Toronto Hydro, Customer Care, 500 Commissioners Street, Toronto, Ontario M4M 3N7, and our customer service representatives will assist you. Response to a customer's request will be made within a reasonable time provided the request is made in writing and the customer provides satisfactory proof of the customer's identity.
10. Challenging Compliance
If the Chief Privacy Officer does not resolve the issue to the customer's satisfaction, the customer may contact the Privacy Commissioner of Ontario.
11. Toronto Hydro Website
(a) Visiting the Toronto Hydro Website
Personal information submitted through Toronto Hydro's Website will be encrypted using a minimum 128 bit encryption with 1024 bit public key technology to help protect and enable its arrival in an unread and unaltered state to Toronto Hydro's technology infrastructure. However, users should be aware that personal information could be intercepted over the Internet. Toronto Hydro is not responsible for the interception, collection, use or alteration of information transmitted over the Internet, such as by email.
(c) Automatic Data Collection
As is the case with Websites generally, when visitors access the Toronto Hydro Website, the site software automatically collects the Internet Protocol (IP) address of the computer through which the user is connected to the Internet. The Toronto Hydro Website also automatically collects information about the user's Internet browser software, operating system, the date and time of the user's visit, the URL of the last page visited by the user before entering the Toronto Hydro Corporation family of Websites, and the pages accessed while on our site. This information is not used to gain personal information on individual users but is aggregated with that of other visitors to help us understand how the site is being used and how to make it better.
(e) Email Communications
(f) Response Tracking
Toronto Hydro uses Website usage information about visitors to our Website who have responded to a promotional campaign about Toronto Hydro's services for the purpose of future promotional campaigns, and evaluating usage statistics. For this purpose, we collect information about the campaigns and some of the pages you visit on our Website through the use of tracking numbers passed through URL's transferred to our information technology as well as pixels tags (also known as clear GIFs).
As well, Toronto Hydro may use third-party companies to host and serve online advertisements for Toronto Hydro promotional campaigns. Pixel tags may be used in connection with online advertisements, for example, to allow us to count the number of times the advertisement was viewed versus the number of individuals who enrolled in the product or service advertised.
Personal information about you is not collected by any such third-party companies, nor is any tracking information generated from the pixel tag used by them for any purpose other than to report advertising response and Website activity to us.
(g) Links to Third-Party Sites
Toronto Hydro's Website contains links to third-party Websites. Toronto Hydro is not responsible for (a) any information you provide to other Websites outside of TorontoHydro’s domain that you access through a link on our Website or (b) the privacy practices or the content of such Websites outside of Toronto Hydro’s domain.