Privacy Policy Statement Brant County Power Inc.

Preface
Brant County Power Inc. and its affiliate company, Brant County Power Services 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 Brant County Power 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 Brant County Power 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 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.  Brant County Power Inc. does, however, protect the confidentiality of such information in accordance with the law and our own policies.

Personal Information Protection Principles

1. Accountability
   Brant County Power 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.  Brant County Power Inc. will require a comparable level of protection of this information from its third party relations.

   Grace Williams, our Privacy Officer, has overall responsibility for our protection of personal information and for Brant County Power Inc.'s compliance with this Privacy Policy.

2. Identifying Purposes

   Personal information that Brant County Power Inc. collects from customers includes:
   - the customer’s name and address and other contact information, such as telephone numbers, email address;
   - 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; and
   - bank information for pre-authorized payments.

   When an individual applies for service, Brant County Power Inc. will make the individual aware of the purposes for which we are requesting the personal information.  If Brant County Power Inc. identifies other purposes for which the personal information may be used, we will seek the individual's consent prior to such use.  Brant County Power Inc. will advise that it is the individual's right to refuse permission for us 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 Brant County Power Inc. 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
   Brant County Power 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 of personal information about them expressly or implicitly.  Brant County Power 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 Brant County Power 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
   Brant County Power Inc. limits the amount and type of personal information it collects to that which is necessary for the business of the utility.  Each affiliate of Brant County Power Inc. will be responsible for its own collection, use and disclosure or information.  Personal Information will be collected using procedures, which are fair, transparent and lawful.
5. Limiting Use, Disclosure and Retention
   Brant County Power 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.  Brant County Power 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, Brant County Power 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, Brant County Power 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 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.

8. Openness
   Brant County Power Inc. will make its policies and practices relating to the protection of personal information available to its customers.  Brant County Power Inc. will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via Brant County Power 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 Brant County Power Inc. can have access to the personal information about them that Brant County Power 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) 442-2215 or (877) 871-2215, via email information_general@brantcountypower.com or in writing 65 Dundas Street East, Paris, ON N3L 3H1.  Response to an individual’s request will be made in a timely and efficient manner.

10. Challenging Compliance
    Any customer of Brant County Power Inc. may challenge our compliance with this Privacy Policy by contacting us directly.  Brant County Power Inc. has policies and procedures to receive, investigate and respond to individuals' complaints and questions.  If the customer is not satisfied with the way we have responded to a complaint, the customer can contact the Privacy Commissioner of Canada at (800) 282-1376.