Privacy Policy

Effective January 1, 2023

Our Privacy Commitment to You:

SYNERGY NORTH is committed to keeping the personal information of its customers accurate, confidential, secure and private. This Privacy Policy/Code has been designed to inform employees, customers, and subcontractors of SYNERGY NORTH of our commitment and recognition to our obligation to meet the spirit and terms of the federal Municipal Freedom of Information and Protection of Privacy Act (Ontario) (MFIPPA).

This Privacy Policy describes the principles SYNERGY NORTH will use to protect the privacy of personal information in its possession. It addresses the reasons why such information is collected, how it is used, how it’s confidentially protected and outlines customers’ rights with respect to this information. This Privacy Policy incorporates and expands the 10 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. SYNERGY NORTH does, however, protect the confidentiality of such information in accordance with the law and our own policies.

Tim Wilson, MBA
President & CEO
SYNERGY NORTH

1. Accountability
SYNERGY NORTH 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. SYNERGY NORTH will require a comparable level of protection of this information from its third-party relations.
Mr. Andrew Covello, Vice President of Human Resources & Safety, is designated as SYNERGY NORTH’s Chief Privacy Officer, and has overall responsibility for our protection of personal information and for SYNERGY NORTH’s compliance with this Privacy Policy.

2. Identifying Purposes
Personal information that SYNERGY NORTH 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 licence, previous addresses, telephone numbers, e-mail addresses, 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, SYNERGY NORTH will make the individual aware of the purposes for which SYNERGY NORTH is requesting the personal information. If SYNERGY NORTH identifies other purposes for which the personal information may be used, SYNERGY NORTH will seek the individual’s consent prior to such use. SYNERGY NORTH will advise that it is the individual’s right to refuse permission for SYNERGY NORTH 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, SYNERGY NORTH 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

3. Consent
SYNERGY NORTH 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. SYNERGY NORTH 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 estrictions 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 SYNERGY NORTH 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
SYNERGY NORTH limits the amount and type of personal information it collects to that which is necessary for the business of the utility. Each affiliate of SYNERGY NORTH will be responsible for its own collection, use, and disclosure of information. Personal information will be collected using procedures that are fair, transparent and lawful.

5. Limiting Use, Disclosure and Retention
SYNERGY NORTH will only use the personal information for the purpose for which it was collected as identified in principle 2.2, 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.

SYNERGY NORTH 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, SYNERGY NORTH 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, SYERGY NORTH 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, 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. It is also important for you to take precautions to protect your personal information such as keeping your user name and passwords confidential.

8. Openness
SYNERGY NORTH will make its policies and practices relating to the protection of personal information available to its customers. SYNERGY NORTH will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via SYNERGY NORTH’s web page and bill inserts. The information will be available in a format that is easy to understand.

9. Individual Access
Upon request and with satisfactory proof of the customer’s identity, any customer of SYNERGY NORTH can have access to the personal information about them that SYNERGY NORTH 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, via e-mail, or in writing to the Corporation’s Chief Privacy Officer as listed.

Response to an individual’s request will be made in a timely and efficient manner.

10. Challenging Compliance
Any customer of SYNERGY NORTH may challenge SYNERGY NORTH’s compliance with this Privacy Policy by contacting our Chief Privacy Officer directly. SYNERGY NORTH has policies and procedures to receive, investigate and respond to individuals’ complaints and questions. If the customer is not satisfied with the way SYNERGY NORTH has responded to a complaint, the customer can contact the Information and Privacy Commissioner of Ontario.

Contact Information for SYNERGY NORTH’s Chief Privacy Officer:
Mr. Andrew Covello, Vice President, Human Resources, Safety & Corporate Risk/Chief Privacy Officer
SYNERGY NORTH
Human Resources & Safety Division
34 North Cumberland Street, Mezzanine Level
Thunder Bay, ON P7A 4L4

Mr. Covello’s direct contact information:
Phone: (807) 343-1020
Fax: (807) 344-7520
E-mail: Email A Covello

If using e-mail as a point of contact, please ensure that you identify “Privacy” in your subject line.