HYDRO OTTAWA CUSTOMER PRIVACY NOTICE
This Customer Privacy Notice describes the principles Hydro Ottawa will use to protect the privacy of Personal Information of customers and other individuals in its possession or control.
In general the use of products and services by a customer is based upon Hydro Ottawa’s statutory authority to collect, use and disclose Personal Information for all purposes related to the delivery of Hydro Ottawa’s services to its customers. Hydro Ottawa’s Privacy Notice addresses the uses of Personal Information, and where relevant, the choices available to individuals and the consent to be obtained for any purposes not related to its mandated functions in the provision of electricity.
By accepting services from Hydro Ottawa, visiting our Website, or otherwise providing us with your Personal Information, you are acknowledging the practices described in this Privacy Notice. The terms in this Privacy Notice may be changed from time to time, so you should review it for changes periodically.
Hydro Ottawa is committed to keeping Personal Information it collects in accordance with our obligations to meet the terms of applicable privacy laws including the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Municipal Freedom of Information and Protection of Privacy Act (Ontario) (“MFIPPA”), and conditions of the Ontario Energy Board issued Electricity Distribution License for Hydro Ottawa Limited (“Distribution License”).
WHAT WE COLLECT
Personal information is information about an identified or identifiable individual. Personal information that Hydro Ottawa may collect includes such information as your name, birth date, contact information including email address, information needed to support your account and validate your identity, transaction information and other information about you collected electronically, in person or by telephone.
Personal Information 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 Notice, “Hydro Ottawa”, “we”, “us”, or “our” means Hydro Ottawa Holding Inc. and its directly and indirectly owned affiliates and subsidiaries, including without limitation, Hydro Ottawa Limited, Energy Ottawa Inc. operating as “Portage Power”, Envari Energy Solutions Inc. operating as “Envari”, and “customer”, “you”, and “your” means the individual who is a customer, prospective customer, vendor or other individual member of the public whose Personal Information is in our possession or control. This Privacy Notice does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. Hydro Ottawa does, however, protect the confidentiality of such information in accordance with the law, including regulatory codes of conduct issued by the Ontario Energy Board, and contractual arrangements.
If you have questions or concerns regarding your Personal Information or this Privacy Notice, please address them to:
Hydro Ottawa Holding Inc.
PO Box 8700
Ottawa, Ontario K1G 3S4
Attention: General Counsel
Email: [email protected]
HOW DO WE DEMONSTRATE ACCOUNTABILITY?
Hydro Ottawa is accountable for the protection of Personal Information within the organization’s possession or control including all Personal Information held by us or transferred to a third party for processing. We do this by maintaining a privacy program and policies, and putting in place policies and procedures that direct Hydro Ottawa and its affiliates to manage Personal Information in accordance with the principles set out in this Privacy Notice.
WHAT DO WE DO WITH THE PERSONAL INFORMATION WE COLLECT?
Hydro Ottawa will tell you why we collect Personal Information before or at the time of collection. Our employees and representatives collecting Personal Information will explain these purposes or refer you to a designated person within Hydro Ottawa who can explain the purposes.
Unless required by law, Hydro Ottawa will not use or disclose, for any new purpose, Personal Information that has been collected without first identifying and documenting the new purpose and obtaining a customer’s consent.
All Personal Information that Hydro Ottawa collects is collected for the following purpose:
- To establish, deliver and maintain energy services and telecommunication or ancillary services;
- To identify and authenticate our customers, respond to customer inquiries and otherwise maintain a responsible business relationship with customers;
- To bill and collect payment, and provide notifications;
- For pre-authorized payments;
- To perform credit reviews to determine credit worthiness;
- To determine eligibility for products and services;
- To recommend particular products and services to meet customer needs;
- To develop, enhance, promote or provide Hydro Ottawa products and services;
- To provide customers with information about the electricity industry, rates and energy conservation programs such as programs that allow you to benchmark your energy consumption against other customer groups;
- To notify customers about new and existing programs, events, causes or any other matters sponsored by Hydro Ottawa;
- To manage and develop Hydro Ottawa business and operations;
- To meet legal and regulatory requirements;
- To monitor to support protection of infrastructure (such as CCTV), physical security, network, data;
- For the development of new products and services;
- To support Hydro Ottawa’s legitimate interests as an organization, such as to support contractual obligations, or enforce/defend claims made in regulatory matters or litigation; and
- To support quality controls and training, such as through call recording.
HOW DOES HYDRO OTTAWA OBTAIN CONSENT?
In obtaining consent, Hydro Ottawa will use reasonable efforts to ensure that you are advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood.
Unless the collection or use of Personal Information is mandated by law or our license, Hydro Ottawa will get your consent to use and disclose Personal Information at the same time we collect the information. However, Hydro Ottawa may seek your consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose.
Hydro Ottawa will require your consent to the collection, use or disclosure of Personal Information as a condition of the supply of a product or service only if it is required to provide the good or service.
In determining the appropriate form of consent, Hydro Ottawa will take into account the sensitivity of the Personal Information and your reasonable expectations.
In general, the use of Hydro Ottawa supplied products and services by you constitutes implied consent for Hydro Ottawa to collect, use and disclose Personal Information for all identified purposes.
You may withdraw consent at any time, subject to legal or contractual restrictions, and reasonable notice. For instance, we cannot honour a withdrawal of consent when the Personal Information is required to provide an ongoing service or product. Customers may contact Hydro Ottawa for more information regarding the implications of withdrawing consent.
HOW DO WE LIMIT COLLECTION?
Hydro Ottawa collects Personal Information primarily from their customers. Hydro Ottawa will not, as a condition of supplying you with a product or service, require you to consent to the collection of Personal Information beyond that required to fulfill the specified, legitimate purpose.
Hydro Ottawa may also collect Personal Information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.
HOW DO WE LIMIT USE, DISCLOSURE AND RETENTION?
Hydro Ottawa may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened. Hydro Ottawa may disclose Personal Information without knowledge or consent to a lawyer representing the companies, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.
Only those employees of Hydro Ottawa who require access for business reasons, or whose duties reasonably so require, are granted access to Personal Information about customers.
Due to 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.
Hydro Ottawa may engage employees, contractors or other companies and third parties to perform services for Hydro Ottawa that involve access to Personal Information. These third parties may be located outside of Ontario or Canada.
In accordance with the Distribution License, Hydro Ottawa 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.
Hydro Ottawa shall keep Personal Information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about a customer, Hydro Ottawa shall retain, for a period of time that is reasonably sufficient to allow for access by the customer, either the actual information or the rationale for making the decision.
Hydro Ottawa maintains reasonable controls and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
HOW DO WE ENSURE ACCURACY?
Personal information used by Hydro Ottawa must be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer. Hydro Ottawa will update Personal Information about customers primarily upon notification by you, and as and when necessary to fulfill the identified purposes for the information collection.
HOW DO WE SAFEGUARD PERSONAL INFORMATION?
Hydro Ottawa protects Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Hydro Ottawa protects the information regardless of the format in which it is held.
Hydro Ottawa protects Personal Information disclosed to third parties by communicating the confidentiality of the information, ensuring appropriate contractual controls, by identifying the purposes for which it is to be used, limiting the number of persons whose job function requires access to the information, and requiring physical and procedural security measures to safeguard that information.
All employees of Hydro Ottawa with access to Personal Information are required as a condition of employment, to respect the confidentiality of Personal Information.
HOW DO WE ENSURE OPENNESS?
Hydro Ottawa is committed to making information about this Notice easy to understand, accessible and updated. Hydro Ottawa will make changes to its Privacy Notice from time to time and such changes will be posted on the website, and by bill inserts if appropriate.
HOW DO WE PROVIDE INDIVIDUAL ACCESS?
Upon request, you may obtain information regarding the type, use and disclosure of your Personal Information that Hydro Ottawa has in its possession and control. Hydro Ottawa may require satisfactory proof of identity prior to providing access to Personal Information. Hydro Ottawa may charge a nominal fee for responding to such a request to cover the costs of reproduction. Hydro Ottawa may refuse to provide you with access to your Personal Information where such refusal is permitted (such as where it would violate the privacy of another person), or as required by law or regulatory authorities.
If you feel that your information is inaccurate or incomplete, you may request that it be corrected; and if not corrected, we will note the dispute on your record. You may request deletion, but as a utility, we are obliged to keep certain data to meet our regulatory and contractual obligations, and deletion will only be available for information that is not related to our core purposes, as noted above, and may impact our ability to communicate with you via the internet. To request the deletion of your data on social media, please contact Customer Service by following this link: https://hydroottawa.com/en/contact.
HOW CAN YOU CHALLENGE COMPLIANCE?
Any customer may challenge Hydro Ottawa’s compliance with this Privacy Notice by contacting Hydro Ottawa’s General Counsel as set out above.
Hydro Ottawa will investigate all complaints concerning compliance with this Privacy Notice. If a complaint is found to be justified, Hydro Ottawa shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. You will be informed of the outcome of the investigation regarding the complaint.
WEBSITE ANALYSIS TOOLS AND THE COLLECTION OF PERSONAL INFORMATION:
Hydro Ottawa’s website, online services, interactive applications, email messages, and advertisements may use “cookies” and other analytical technologies.
Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. For example, “cookies” may be associated with Hydro Ottawa’s online forms that you may wish to submit on a regular basis.
These technologies also help Hydro Ottawa measure performance and engagement. The purpose of collection of Personal Information by these technologies will be consistent with the purposes stated above under the heading “Identifying Purposes”.
Our goal is to make your experience with Hydro Ottawa more convenient and personal. Customers are free to prevent the installation of cookies by simply disabling this feature in your browser options; as well you are able to delete cookies. This may impact your experience of our website.
We have built our website using industry-standard encryption and authentication tools to protect the security of personal information.
We also use technological measures such as secure routers and firewalls to help protect personal information. Information collected through the website is encrypted before it travels over the Internet using industry-standard technology for conducting secure online transactions.
Unfortunately, because of its nature, we cannot guarantee against the loss or misuse of personal data transmitted over the Internet.