Effective January 1, 2004
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.
Personal Information Protection Principles:
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 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
- Energy sector legal, regulatory and settlement requirements
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 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 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 which 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, 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.
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.
In executing its responsibilities with respect to the confidentiality of personal information, SYNERGY 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.
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
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. Contact information is provided under point #10, page four. Response to an individual’s request will be made in a timely and efficient manner.
10. Challenging Compliance
Contact Information for SYNERGY NORTH’s Chief Privacy Officer:
Mr. Andrew Covello, Vice President, Human Resources & Safety
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.