Privacy Policy

The group of Guelph Hydro Inc. companies (Guelph Hydro Electric Systems Inc., and Ecotricity Inc. and identified as “We” in this policy) is committed to ensuring that the personal information of its customers is accurate, confidential, secure, private and meets the spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

This Privacy Policy describes the ten principles that we use to protect the privacy of personal information in our possession. It outlines why such information is collected, how it is used, how its confidentiality is protected and details the customers' rights in respect of this information. The Policy incorporates and expands the 10 principles for the protection of personal information, as devised by the Canadian Standards Association (CSA). This Policy does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. We do, however, protect the confidentiality of such information in accordance with the law and our own policies.

1. Accountability: We are 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. We require a comparable level of protection from our third party relations. Our Privacy Officer, Nicole Mailloux, is responsible for our compliance and commitment to this Policy.

2. Identifying Purposes: Personal information that we collect from customers includes: the customer's name and address and other contact information; the meter number; facts about consumption of power and water, both historic and current; facts about payment history, including general financial information; credit and reference information, such as date of birth, employment information, driver's licence, previous addresses, telephone numbers, e-mail address, 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, we will fully explain why we are requesting the required information. If we identify other purposes for which the personal information may be used, we will seek your consent prior to use. We will advise you of your right to refuse permission for us to use personal information for any new purposes. At a minimum, we will collect personal information for the following purposes: • Billing and collection of payments • Pre-authorized payment for services • Priority restoration of electric service to the correct address and meter, as may be required by medical circumstances • Energy and water sector legal, regulatory and settlement requirements Conducting customer surveys including customer satisfaction surveys

3. Consent: We will obtain consent before or when we collect, use or disclose personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information either expressly or implicitly. We 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. Should a customer withdraw consent, other forms of security, including but not limited to security deposits, may be required. All existing customers will be informed of the type of personal information that has been collected, the purpose for the collection and the procedures available for contacting us with any inquiries. All new customers will be provided with a verbal and/or written explanation about the collection, use and disclosure of personal information when requesting service. We will obtain verbal and/or written consent before we collect personal information from all new customers.

4. Limiting Collection: We limit the personal information we collect to that which is necessary for the business of the utility. Each of our companies is to 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: We 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 Affiliate Relationships Code, created under the provincial Electricity Act, no customer information will be disclosed by one affiliate to another. We will develop explicit retention periods for closed accounts (zero balance), after which the personal information is destroyed or made anonymous. Under certain exceptional circumstances, we 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: We 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. These will include physical, organizational or technological measures, for example locked filing cabinets, restricted access to offices, security clearances, limiting access on a “need to know” basis and use of passwords and encryption. We will communicate these measures to all employees and third parties to ensure proper implementation and compliance.

8. Openness: Customers will be informed of our Privacy Policies and practices and all related policies and procedures via our web pages, bill inserts, or other means.

9. Individual Access: Any of our customers can access their personal information that we have in our possession or control, and may request that it be amended for purposes of accuracy and completeness. Customers can make their requests by telephone 519.822.3010, via email (binquiri@guelphhydro.com) or in writing (395 Southgate Drive, Guelph, ON N1G 4Y1). Response to an individual's request will be made in a timely and efficient manner.

10. Challenging Compliance: Any of our customers may challenge our compliance with this Privacy Policy by contacting us directly. If the customer is not satisfied with the way we respond to a complaint, he or she may contact the Privacy Commissioner of Canada. Revised Nov 2007

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