Privacy Policy

You Entrust Us with Your Information and Protecting Your Privacy Is Paramount at Festival Hydro.

Preface

Festival Hydro Inc. and its affiliate, Festival Hydro Services Inc., are 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 Festival Hydro 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 Festival 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 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. Festival Hydro does, however, protect the confidentiality of such information in accordance with the law and our own policies.

Personal Information Protection Principles

1. Accountability

Festival Hydro 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. Festival Hydro will require a comparable level of protection of this information from its third-party relations. Jackie Wheal, our Privacy Officer, has overall responsibility for our protection of personal information and for Festival Hydro's compliance with this Privacy Policy.

2. Identifying Purposes

Personal information that Festival Hydro 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, driver’s 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, Festival Hydro will make the individual aware of the purposes for which Festival Hydro is requesting the personal information. If Festival Hydro identifies other purposes for which the personal information may be used, Festival Hydro will seek the individual's consent prior to such use. Festival Hydro will advise that it is the individual's right to refuse permission for Festival 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 Festival Hydro 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

Festival Hydro 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. Festival Hydro 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.

The nature of personal information we collect may include:

Information we receive from you such as your name, address, contact information and general financial, credit and reference information;
Facts about your historical and current consumption of power;
Information about your transactions with us, such as meter number, account number, account balances, payment history, and account activity;
Information about your past credit history;
Identifying information, such as a driver’s license.

Festival Hydro uses the information we collect for the following purposes:

To provide you with continuous electric service and to bill you for that service;
To assist us in the collection of accounts;
To respond to your inquiries about energy use and billing;
To prevent fraud with respect to both you and our company;
To meet legal and regulatory requirements.

All existing customers will be informed at implementation of what types of personal information have been collected, the purpose for the collection and the procedures available for contacting Festival Hydro with any inquiries. All new customers will be provided with an explanation about the collection, use and disclosure of their personal information when requesting service.

4. Limiting Collection

Festival Hydro limits the amount and type of personal information it collects to that which is necessary for the business of the utility. Personal Information will be collected using procedures which are fair, transparent and lawful.

5. Limiting Use, Disclosure and Retention

Festival Hydro 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. Festival Hydro will develop explicit retention periods, after which the personal information will be destroyed or made anonymous.

Under certain exceptional circumstances, Festival Hydro 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, Festival Hydro 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, 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

Festival Hydro will make its policies and practices relating to the protection of personal information available to its customers. Festival Hydro will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via Festival Hydro'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 Festival Hydro can have access to the personal information about them that Festival Hydro 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 519-271-4700 or 1-866-444-9370, via email jwheal@festivalhydro.com or in writing 187 Erie Street, PO Box 397, Stratford ON N5A 6T5. Response to an individual’s request will be made in a timely and efficient manner.

10. Challenging Compliance

Any customer of Festival Hydro may challenge Festival Hydro's compliance with this Privacy Policy by contacting Festival Hydro directly. Festival Hydro has policies and procedures to receive, investigate and respond to individuals' complaints and questions. If the customer is not satisfied with the way Festival Hydro has responded to a complaint, the customer can contact the Privacy Commissioner of Canada.