Milton Hydro Privacy Policy


Commitment to Privacy

Milton Hydro Distribution Inc. (“Milton Hydro”) is committed to keeping the personal information of its
customers accurate, confidential, secure and private. Our Privacy Policy has been designed to inform
customers, employees, and third-party contractors of Milton Hydro’s commitment to, and recognition
of, our obligation to protect customer personal information in its custody or control and meet the
terms of the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).

Our Privacy Policy describes the principles by which Milton Hydro 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 customers’ rights in respect of accessing their
personal information. Our Privacy Policy incorporates and expands on the ten principles for the
protection of personal information, as established by the Canadian Standards Association (CSA).

This Privacy Policy does not apply to information about business customers who carry on business as
corporations, partnerships or other forms of association. Milton Hydro does, however, protect the
confidentiality of such information in accordance with the law and our own policies.

The terms set out in Milton Hydro’s Privacy Policy may change from time to time. Please check our
website periodically for any revisions.

Ten Principles for the Protection of Personal Information

Ten internationally accepted principles lie at the core of organizational responsibilities for safeguarding personal information. These are:
 
1. Accountability: 
An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with privacy principles.

Milton Hydro is accountable for all personal information in its possession or control and will designate one or more persons who will be responsible for the Company’s compliance with the following principles:  
  • The President and CEO of Milton Hydro has ultimate responsibility for the protection of personal information of customers. The President and CEO has delegated the day-today operational privacy responsibilities to the Corporate Privacy Officer. All staff share responsibility for adhering to Milton Hydro’s privacy policies and procedures.
  • The Corporate Privacy Officer may be contacted at the following address or by e-mail at privacy@miltonhydro.com:

Corporate Privacy Officer
200 Chisholm Drive
Milton, Ontario, L9C 3G9  

  • Milton Hydro is responsible for personal information in its possession or control, including any personal information that has been transferred to a third party for processing. Milton Hydro will use contractual or other means to provide a comparable level of protection of personal information while such information is being processed by a third party.
  • Milton Hydro has implemented policies and procedures to give effect to the Milton Hydro Privacy Policy including: a) implementing procedures to protect personal information and to oversee the company’s compliance with MFIPPA; b) establishing procedures to receive and respond to inquiries or complaints with respect to an individual’s personal information; and c) training staff and communicating to staff about the company’s privacy policies and practices.
2. Identifying Purposes: 
The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
 
Personal information that Milton Hydro collects from customers includes:
 
  • name and address and other contact information;
  • the meter number;
  • facts about consumption of power, both historic and current;
  • information about a customer’s transactions with us (e.g. account numbers, account balances, payment history);
  • identifying information, such as date of birth, employment information, driver’s licence;
  • credit and banking information for pre-authorized payments.

    
When an individual applies for service, Milton Hydro will make the individual aware of the purposes for which Milton Hydro is requesting the personal information.  If Milton Hydro identifies other uses for the personal information, Milton Hydro will seek the individual's consent prior to such use.  Milton Hydro will advise that it is the individual's right to refuse permission for Milton Hydro 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 Milton Hydro will collect personal information for the following purposes: industry, energy conservation and rates;  
 
  • to establish and maintain responsible commercial relationships with customers and to provide ongoing service;
  • to meet all legal, regulatory, settlement, and market operations requirements;
  • to identify or contact customers, respond to customer inquiries and otherwise maintain business relations with customers;
  • to help prevent or investigate fraud, theft of power or other breaches of the law;
  • to bill and collect payments;
  • to register customers for pre-authorized payment for services;
  • to provide customers with information about our services, the electricity
  • to request customer participation in surveys or contests; or
  • to notify customers about events or causes sponsored by Milton Hydro or our affiliates.

Milton Hydro may:
a)      Monitor and/or record any telephone conversations with its customers for
quality assurance and training purposes.

b)      Share information with third-party service providers who perform services on
our behalf.  These service providers are given only the information necessary to perform those services that we have contracted them to provide and are obligated to meet the same privacy standards as Milton Hydro.

 
3. Consent: 
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
 
Milton Hydro will ask for your consent for the collection, use and disclosure of your personal information when we collect your information.  An individual can provide consent to the collection, use and disclosure of personal information about them expressly or implicitly.  Milton Hydro may collect, use or disclose personal information without an individual's consent only in limited circumstances as permitted or required 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.  However, refusal to provide such consent or withdrawal of such consent, may prevent the Company from providing some services as it requires a minimum amount of personal information to provide electricity distribution services.
 
4. Limiting Collection: 
The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
 
Milton Hydro limits the amount and type of personal information it collects to that which is reasonable and necessary for the purposes identified by the company. Milton Hydro collects personal information using procedures which are fair, transparent and lawful.
 
Access to personal information is restricted to only those employees of Milton Hydro who require access in order to perform their duties in fulfilling the purposes outlined in this Privacy Policy and as authorized or required by applicable law.
 
5. Limiting Use, Disclosure, and Retention: 
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information must be retained only as long as necessary for the fulfillment of those purposes.
 
Milton Hydro does not use or disclose personal information for purposes other than those for which it was collected, unless consent is given by the individual to use or disclose it for another purpose, or as required by law. Milton Hydro retains personal information only as long as necessary for the identified purposes.
 
Personal information that is no longer required to fulfill the identified purposes for which it was collected will be destroyed, erased or made anonymous. Milton Hydro has developed guidelines and implemented procedures to govern the destruction of personal information.  Only those employees of Milton Hydro who require access for business reasons or whose duties require it, are granted access to personal information about customers.
 
6. Accuracy:
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
 
Milton Hydro maintains procedures to ensure all personal information we collect and use is kept as accurate, complete and up to date as necessary. Milton Hydro will update personal information about customers upon notification by the individual requesting that their personal information be updated or amended. Milton Hydro relies on you to tell us about any errors or changes in your information.
 
7. Safeguards: 
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
 
In executing its responsibilities with respect to the confidentiality of personal information, Milton Hydro employs 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 include physical measures, organizational measures and technological measures.  These include: locked filing cabinets, restricted access to offices, security clearances, limiting access on a “need to know” basis and use of passwords and encryption.  Procedures for implementing these measures are 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.
  • tell us about any errors or changes in your information
8. Openness: 
An organization shall make readily available to individuals, specific information about its policies and practices relating to the management of personal information.
 
Milton Hydro will make its policies and practices relating to the management of personal information readily available to customers.  Milton Hydro’s Privacy Policy is available at its office and on its website.

 
9.Individual Access: 
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

MFIPPA provides you with the right to request access to your personal information. You can request access to the personal information that we have about you and get information about how we use your personal information. You can also challenge the accuracy and completeness of your personal information and have it corrected where necessary. 
 
Customers can make their formal requests by:
 
10. Challenging Compliance: 
  • An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.
     
    Any customer of Milton Hydro may challenge Milton Hydro's compliance with this Privacy Policy by contacting Milton Hydro directly.  Milton Hydro has policies and procedures to receive, investigate and respond to individuals' complaints and questions.  If the customer is not satisfied with the way Milton Hydro has responded to a complaint, the customer can contact the Information and Privacy Commissioner of Ontario at:
     
    Information and Privacy Commissioner, Ontario
    2 Bloor Street East, Suite 1400,
    Toronto, ON M4W 1A8
     
    Telephone:     1-800-387-0073 or (416) 326-3333
    Fax:                 (416) 325-9195
    Website:         www.ipc.on.ca
    E-Mail:             info@ipc.on.ca
     

WATER AND WASTEWATER
Milton Hydro provides water and wastewater billing service to customers in the Town of Milton on behalf of the Regional Municipality of Halton (“Halton Region”).
 
Milton Hydro’s privacy policy also applies to those customers of the Halton Region, with the addition of the following stipulations as set out by Halton Region and legislation:
 
  1. A customer’s personal information, as defined in the Municipal Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. M. 56, as amended, is collected under the authority of the Municipal Act, 2001, S.O. 2001 c.25, as amended, and will be used for the purposes of billing for water and wastewater use and collecting water and wastewater charges;
  2. A customer’s personal information will be disclosed to Halton Region, who may also disclose the information to the property owner, for the purposes of collecting unpaid water and wastewater charges, including collection through the addition of the unpaid charges to the property’s tax roll.


Inquiries to Halton Region may be directed to:

Freedom of Information and Privacy Coordinator
Legislative & Planning Services Department, Regional Clerk's Office
The Regional Municipality of Halton
1151 Bronte Road 
Oakville, Ontario, L6M 3L1

Tel: 905-825-6000
Toll Free: 1-800-442-5866
 TTY: 905-827-9833


 

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