The policy applies to and protects all personal information collected, used or disclosed by Bluewater Power. Personal information that may fall under this policy may include:
- Name and Address
- Details of current consumption
- Details of past consumption
- Drivers license number
- User names and passwords
- Credit history
- Health conditions relevant to shut-off of electricity
- Age date of birth, gender, income
- Credit card information
- Language preferences
- Internet protocol address
- Bank information
- Special needs
- Customer complaint records
- Service support records
This information may be collected when:
- a person subscribes to or uses our services;
- a person makes any inquiries by telephone or in person, inquires about his/her services, receives technical support, or when he/she makes a complaint; and
- a supplier provides a quote, bid or enters into a contract with Bluewater Power.
The Privacy Principles Bluewater Power Follows
To better understand our policy, Bluewater Power has set out some basic definitions to use when reading and interpreting the principles below:
Collection – the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
Disclosure – making personal information available to a third party, not including agents acting on behalf of Bluewater Power.
Personal information – information about an identifiable individual that is recorded in any form, but does not include aggregated information that cannot be associated with an identifiable individual.
Use – the treatment, handling, and management of personal information by and withinBluewater Power.
Principle 1 – Accountability
Bluewater Power accepts responsibility for personal information under its control. We have designated Alex Palimaka as our Chief Privacy Officer to monitor and encourage compliance with these principles. This position has been created to ensure customers and suppliers have a designated avenue to answer their privacy-related inquiries and to ensure that we implement policies and practices through our training program to give effect to the principles of this policy.
Bluewater Power will ensure a comparable level of protection when personal information is sent outside of the corporation for processing by our agents or third parties.
Principle 2 – Identifying Purposes for Collection of Personal Information
Personal information that Bluewater Power collects from its customers and suppliers will only be used for the purposes of Bluewater Power. The purposes for which we collect information are as follows:
- to understand and respond to customer needs;
- to manage the supply and demand of Bluewater Power’s customers;
- to extend credit to our customers;
- to facilitate collection;
- to facilitate customer relations with their chosen retailer, if any;
- to manage system maintenance; and
- to keep our customers informed about changes in the electricity market;
Bluewater Power staff that collect personal information will explain these identified purposes at the time of collection, or upon inquiry. Unless required by law, Bluewater Power will not use or disclose for any new purpose, personal information that has been collected without first identifying the new purpose and obtaining the consent of the customer.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer is required for the collection, use, or disclosure of personal information.
All existing customers of Bluewater Power will be informed of the types of personal information we have collected and the purposes for the collection of that information. Generally, the information that we collect, use and disclose is essential to our ability to provide our customers with service. Therefore, our collection, use and disclosure of that information is a condition of the customer receiving, or continuing to receive, our service.
All new customers will be advised of the purposes for which we are collecting their personal information. These new customer’s will be asked to provide their consent to our collection of personal information in writing as part of their application for service. However, all new customers signing up for service by telephone will be asked to provide their verbal consent by the Bluewater Power customer service representative.
A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Most of the information that we collect is necessary for the provision of service and is a condition of receiving, or continuing to receive, service However, any customer can contact Bluewater Power for more information regarding their options.
These principles are applied to the extent possible and necessary to supplies who are individuals, or from whom we have received personal information about their employees or individuals acting on their behalf.
Principle 4 – Limiting Collection of Personal Information
Bluewater Power is committed to limiting the collection of personal information to that which is necessary for the purposes set out in this policy. Personal information will be collected using procedures that are fair, transparent and lawful.
In addition to collecting information directly, Bluewater Power may also collect personal information from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Bluewater Power will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Bluewater Power will retain personal information only as long as necessary for the fulfillment of those purposes, or as required by law.
In addition to those purposes set out above, Bluewater Power may disclose a customer or supplier’s personal information as follows:
- to the Independent Market Operator, a customer’s retailers, if applicable, and any other entity necessary for the efficient provision of electricity;
- to another person or corporation as part of conducting business or negotiating a relationship for a legitimate business purpose related to the distribution of electricity or the provision of default supply to our customers;
- to a person who, in the reasonable judgment of Bluewater Power, is seeking the information as an agent of the customer; and
Bluewater Power does not provide or sell its customer lists, or other personal information, to any outside company for use in its marketing or solicitation.
Only Bluewater Power’s employees who need to know for legitimate business reasons are granted access to personal information about customers or suppliers.
Bluewater Power will develop and maintain reasonable and systematic controls, schedules and practices for the retention and destruction of personal information that is no longer required.
Principle 6 – Accuracy of Personal Information
Bluewater Power has an obligation to ensure the accuracy of information that it collects, uses and discloses. Personal information shall be as accurate, complete, and up-to-date as is reasonably possible. Bluewater Power will update personal information as and when necessary, or upon notification by the individual. Therefore, you may be contacted at any time regarding account status, changes to services and other matters relevant to underlying services and/or personal information.
Principle 7 – Security Safeguards
Bluewater Power protects personal information by security safeguards appropriate to the sensitivity of the information. Bluewater Power will protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures.
Bluewater Power will protect personal information it discloses to third parties by contractual agreements that stipulate the confidentiality of the information and the purposes for which it is to be used
All of Bluewater Power’s employees with access to personal information are required as a condition of employment to respect the confidentiality of personal information.
Principle 8 – Openness Concerning Policies and Practices
Bluewater Power will make available to employees, customers and suppliers specific information about its policies and practices relating to the management of personal information, including:
- the title and address of the person accountable for Bluewater Power’s compliance with the policy and to whom inquiries or complaints can be forwarded;
- the means of gaining access to personal information; and
- a description of the type of personal information held, including a reasonable description of its purposes.
Principle 9 – Customer Access to Personal Information
Bluewater Power will inform an individual of the existence, use, and disclosure of his or her personal information upon request and shall give the individual reasonable access to that information. An individual is able to challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain situations, Bluewater Power may not be able to provide access to all of the personal information it holds about a customer. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that is subject to solicitor-client or litigation privilege, or, in certain circumstances, information of a medical nature. Bluewater Power shall provide the reasons for denying access.
Upon request, Bluewater Power will individuals a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in understandable form within the timelines spelled out in PIPEDA, and at a minimal cost to the individual.
In order to safeguard personal information, a customer may be required to provide sufficient identification information to permit Bluewater Power to authorize access to the individual’s file.
Bluewater Power shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Bluewater Power shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
Principle 10 – Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the Chief Privacy Officer for Bluewater Power
Bluewater Power shall maintain procedures for addressing and responding to all inquiries or complaints about its handling of personal information. Bluewater Power shall inform its customers and suppliers about the existence of these procedures as well as the availability of complaint procedures.
Bluewater Power is committed to investigate all complaints concerning compliance with the policy. If a complaint is found to be justified, Bluewater Power shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures.
For more information:
Please contact through any of our Websites or directly through our Privacy Office as follows by:
Telephone: (519) 337-8201 ext. 2292
Mail: Chief Privacy Officer, Bluewater Power, P.O. Box 2140, 855 Confederation Street, Sarnia, Ontario, N7T 7L6