Privacy

Guelph Hydro Privacy Policy

At Guelph Hydro Electric Systems Inc. (Guelph Hydro), protecting our customer's privacy and personal information is of paramount importance and fundamental to the way we do business.

Guelph Hydro's Privacy Policy describes the principles Guelph Hydro uses to protect the privacy of personal information of customers and other individuals in its possession or control.

This policy applies to any person who has accepted services from us, visited our website, or provided us with personal information.

The terms in this Privacy Policy may change from time to time, so you should review it for changes periodically.

This Privacy Policy explains our commitment to and recognition of our obligation to meet the spirit and terms of applicable privacy laws and regulations including, but not limited to, 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 Guelph Hydro Electric Systems Inc. (Distribution License).

This Privacy Policy incorporates the 10 principles for the protection of personal information, as established by the Canadian Standards Association (CSA) and as adopted and amended by PIPEDA.

As used in this Privacy Policy, personal information is information about an identified or identifiable individual. Personal information may include such information as your name, email address, mailing address, financial information, birth date 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 Policy, "Guelph Hydro", "we", "us", or "our" means Guelph Hydro Electric Systems Inc. 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 Policy does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. Guelph Hydro 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.

The following are 10 principles that Guelph Hydro follows for the protection of personal information:

1. Accountability

Guelph Hydro 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 legal, regulatory, processing, storage or other purposes. We have employees who are accountable for compliance with these privacy principles and we require a comparable level of accountability from third party relations.

If you have questions or concerns regarding your personal information or this Privacy Policy, please address them to:

Privacy Officer
Guelph Hydro Electric Systems Inc.
395 Southgate Drive
Guelph, Ontario
N1G 4Y1

Email: Privacy Officer
Telephone: 519-822-3010 - Customer Service Department
Fax: 519-822-0960

2. Identifying Purposes

Guelph Hydro will identify the purpose for which your personal information is collected as well as how it will be used or disclosed. If that purpose is not listed below, we will do this before or at the time the information is being collected.

Unless required by law, Guelph Hydro 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 the consent from the customer.

All personal information collected by Guelph Hydro is collected for the following purposes:

  • To establish, deliver and maintain electricity services;
  • To identify our customers, respond to customer inquiries and otherwise maintain a responsible business relationship with customers;
  • To bill and collect payment;
  • To perform credit reviews to determine creditworthiness;
  • To establish and administer pre-authorized, equal payment or other payment plans
  • To manage and develop Guelph Hydro business and operations;
  • For legal, regulatory and electricity market operation requirements;
  • To provide a competitive energy retailer, designated by the customer, validated meter usage information according to the standards, Retail Settlement Code and electricity market rules.
  • To complete socioeconomic statistical reports for Statistics Canada
  • To develop, enhance, promote or provide Guelph Hydro products and services;
  • To determine eligibility for and to recommend products and services;
  • To provide customers with information about the electricity industry, rates and energy conservation programs;
  • To request customer participation in surveys or contests;
  • To notify customers about new and existing programs, events, causes or any other matters sponsored by Guelph Hydro;
  • To develop or enhance the Guelph Hydro website or social media sites;
  • To prepare financial records; and
  • To help prevent or investigate fraud, theft of power or other breaches of the law.

We may monitor and/or record any telephone conversation with you for quality assurance and training purposes.

3. Consent

In obtaining consent, Guelph Hydro shall use reasonable efforts to ensure that a customer is 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 by the customer.

Generally, Guelph Hydro shall obtain your consent to use and disclose personal information at the same time it collects the information. However, Guelph Hydro may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.

Guelph Hydro will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfil the identified purposes.

In determining the appropriate form of consent, Guelph Hydro shall take into account the sensitivity of the personal information and the reasonable expectations of its customers.

In general, the use of products and services by a customer constitutes implied consent for Guelph Hydro to collect, use and disclose personal information for all identified purposes. By accepting service from us, using the website, or otherwise providing us with your personal information, you will be deemed to consent to our use of your personal information for the purposes outlined above.  Otherwise, Guelph Hydro will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your personal information. 

Consent may be given by an authorized representative such as a legal guardian or person with power of attorney. Consent may also be obtained directly from you or from a third party that has obtained your consent to disclose your personal information to Guelph Hydro.  For example, if you sign a contract with a third party for electricity services (a "retail provider"), Guelph Hydro may obtain your personal information from such retail provider and may provide your billing and consumption information to them.

A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers may contact Guelph Hydro for more information regarding the implications of withdrawing consent.

4. Limited Collection

Guelph Hydro collects personal information primarily from their customers. Guelph Hydro 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 fulfil the specified, legitimate purpose.

The types of personal information that Guelph Hydro usually collects from individual customers include:

  • Customer name and address (mailing and service address) and other contact information;
  • Facts about historic and current consumption of electricity and water for your home or business;
  • Customer transactions with Guelph Hydro (i.e. account number, account balances, payment history, and account activity);
  • General financial information (i.e. credit card number, credit and reference information);
  • Identifying information (i.e. date of birth, driver's licence number);
  • Medical information to be used in case of planned power outages;
  • Financial institution information requested for pre-authorized payments; and
  • Information we receive from you through your correspondence or communications with us.

Depending on the circumstances, we may collect some or all of the foregoing personal information listed above from you.

Guelph Hydro 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.

5. Limited Use, Disclosure, and Retention

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.

Only those employees of Guelph Hydro who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers.

Guelph Hydro may engage employees, contractors or other companies and third parties to perform services for Guelph Hydro that involve access to, processing of or storage of personal information. These third parties may be located outside of Ontario or Canada and therefore may be subject to disclosure under the laws of those jurisdictions.

Under certain exceptional circumstances, Guelph Hydro may have a legal duty or right to collect, use or disclose your personal information without your knowledge or consent; for example, in the case of an emergency where the life, health or security of an individual is threatened. Guelph Hydro may also disclose personal information without knowledge or consent to a lawyer representing the company, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.

In the event of a proposed sale of Guelph Hydro's business or assets (or a part thereof), or a merger or amalgamation of Guelph Hydro with another company, we may disclose your personal information to third parties such as prospective purchasers of Guelph Hydro's shares, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction and upon completion of such a transaction, your information will be one of the transferred assets.

In accordance with the Distribution License, Guelph Hydro will not disclose any customer information (which may include personal information) to any of its affiliates without the customer's written consent except where a customer's 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.

If your personal information is shared with third parties, those third parties are bound by appropriate agreements with Guelph Hydro to secure and protect the confidentiality of your personal information.

Guelph Hydro 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, Guelph Hydro 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.

Guelph Hydro shall maintain 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.

​6. Accuracy

Personal information used by Guelph Hydro shall 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. Guelph Hydro shall update personal information about customers as and when necessary to fulfil the identified purposes or upon notification by the individual.

You may request access to the personal information we have on record in order to review and amend the information, as appropriate.  To access your personal information, refer to the "How to Contact Us" section below.

7. Safeguards

Guelph Hydro shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Guelph Hydro shall protect the information regardless of the format in which it is held.

Guelph Hydro shall protect personal information lawfully disclosed to third parties by communicating the confidentiality of the information, the purposes for which it is to be used, limits on the number of persons whose job function requires access to the information, and the physical and procedural security measures required to safeguard that information.

Guelph Hydro is accountable for ensuring that all employees of Guelph Hydro with access to personal information are properly trained on the treatment of personal information. All Guelph Hydro employees shall be required to respect the confidentiality of personal information as a condition of employment.

8. Openness

We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information.  This policy and any related information is available at all times on the company website or on request. 

9. Individual Access

Upon request, customers may obtain information regarding the type, use and disclosure of his, or her, personal information that Guelph Hydro has in its possession and control. Guelph Hydro may require that a customer provide satisfactory proof of identity prior to obtaining access to his or her personal information. Guelph Hydro may refuse to provide you with access to your personal information where such refusal is permitted or required by law or regulatory authorities.

10. Challenging Compliance

Any customer may challenge Guelph Hydro's compliance with this Privacy Policy in regard to such customer's personal information by contacting the contact information set out above under the heading "Accountability".

Guelph Hydro shall investigate all complaints concerning compliance with this Privacy Policy. If a complaint is found to be justified, the company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer shall be informed of the outcome of the investigation regarding his or her complaint.

 

Privacy and Our Websites

Website Analysis Tools and the Collection of Personal Information

In addition to the 10 principles highlighted above, Guelph Hydro's website, online services, interactive applications, email messages, and advertisements may use "cookies" and other analytical technologies. These technologies help Guelph Hydro 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".

For example, "cookies" may be associated with Guelph Hydro's online forms that customers may wish to submit on a regular basis. Our goal is to make your experience with Guelph Hydro more convenient and personal. Customers are free to prevent the installation of cookies by simply disabling this feature in your browser option.

In addition, Guelph Hydro employs software programs that monitor network traffic.  These programs record the Internet Protocol ("IP") addresses of computers, mobile and other devices that visit Guelph Hydro's website.  They also may record the date and time of visits, the pages viewed, and the browsers and operating systems used by visitors. We do not attempt to link this information to the identities of individual users, unless an attempt to damage Guelph Hydro's website has been detected.

The information generated by the cookies about your use of the Guelph Hydro website (including your IP address) will be transmitted to and stored on servers located outside of Ontario including, but not limited to, the United States, by the applicable third party provider of an Analytical Tool.  This information will be used for the purpose of evaluating your use of our website, compiling reports on the activities on the website and providing other services relating to the activity of Guelph Hydro's website and Internet usage.  The third-party providers of Analytical Tools may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf.  By using Guelph Hydro's website, you consent to the processing of data about you by third party providers of Analytical Tools in the manner and for the purposes set out above.

 
Links to Other Websites
Guelph Hydro's website has links to third party websites that Guelph Hydro does not own or maintain.  Links to other websites or other resources ("Linked Sites") which are not created or controlled by Guelph Hydro are intended for convenience only.  Linked Sites are wholly independent from Guelph Hydro; therefore, Guelph Hydro has no control over any products, services, materials, or other information contained in or available through these third-party websites. We make no representations or warranties about the privacy practices of those websites. Therefore, access to any third-party websites through Guelph Hydro's website, regardless of whether the third-party website is a Linked Site or not, is entirely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive devices, programs.