1.1 Our Commitment to Protecting Your Privacy
We, at FortisBC, value your privacy and we strive to ensure that our customers are aware that their privacy is of the utmost importance to us. We collect, use and disclose personal information about our customers to enable us to establish and manage the relationship necessary to provide services to you. While FortisBC places a high priority on the protection of personal information shared with us by our customers, legislation is in place that governs how personal information must be managed and protected. We are committed to complying with the legislation. We want you to understand why and how we collect, use, disclose, retain and secure your information.
“collection” – the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including sources other than the Individual to whom the Personal Information belongs, by any means.
“Consent” – voluntary agreement to the collection, use or disclosure of Personal Information for defined purposes.
“disclosure” – making Personal Information available outside FortisBC.
“Employee” – means an employee or ex-employee of FortisBC.
“FortisBC” means the group of FortisBC companies and their affiliates, including but not limited to, FortisBC Inc., FortisBC Energy Inc., FortisBC Energy (Vancouver Island) Inc., FortisBC Energy (Whistler) Inc. and FortisBC Holdings Inc.
“identified purposes” – means the purposes identified in this Policy.
“Individual” – any person, who directly or indirectly provides his or her Personal Information to FortisBC as described in the Policy.
“Personal Information” – means information about an identifiable Individual, and therefore does not include information that cannot be associated with a specific individual.
“Privacy Legislation” – means, the British Columbia Personal Information Protection Act and associated regulations as amended from time to time; and the Canada Personal Information Protection and Electronic Documents Act and associated regulations as amended from time to time, as applicable.
“Privacy Officer” – means the privacy officer of FortisBC.
“use” – the treatment, handling, management and retention of Personal Information.
FortisBC provides electricity, natural gas, piped propane and integrated energy solutions throughout the province of British Columbia. This Policy applies to each of the entities which are collectively defined as “FortisBC” in section 1.2 above.
The Policy does not impose any limits on the collection, use or disclosure of the name, title, business address, business email address, business telephone number or business fax number, of any employee at FortisBC or any other organization, if that information is collected, used or disclosed for the purpose of contacting individuals in that person’s capacity as an employee of FortisBC or any other organization.
This Policy does not impose limits on the collection, use or disclosure of personal information without consent where that collection, use or disclosure is in accordance with the Privacy Legislation.
1.4 Scope of Accountability
FortisBC is responsible for Personal Information in its custody and under its control, and have designated a Privacy Officer who is generally accountable within the organization and is responsible for our compliance with this Policy, and for ensuring that the Policy complies with the Privacy Legislation.
2. PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
2.1 Purposes Identified at Time of Collection
2.2 New Purposes
When we wish to use or disclose the Personal Information for a new purpose, we will identify the new purpose prior to such use or disclosure and obtain consent at that time, unless such use or disclosure without consent is permitted or required by law. In certain circumstances, Consent for the use or disclosure for a particular purpose may be sought after the information has been collected, but before it is used or disclosed (for example, when we want to use the Personal Information for a new purpose).
2.3 Purposes Limited
We ensure that the purposes for collection, use and disclosure are limited to purposes that a reasonable person would consider appropriate in the circumstances.
Some of the purposes for which we collect, use and disclose or communicate Personal Information are:
- To create and maintain an effective business relationship;
- For quality assurance purposes such as the recording of telephone calls to our call centers;
- To facilitate account, billing, credit, collections and customer services, this may include the collection of contact information, emergency contact information, consent to complete a credit check for new customers;
- To provide ongoing electricity, natural gas, propane and various other services to its customers;
- To avoid and investigate fraud and identity theft;
- To enable energy efficiency and enhanced customer energy consumption feedback, including the collection of hourly consumption data;
- To reduce energy and revenue theft which may include the collection of outage, voltage, load profile and consumption information;
- To further develop, enhance and market products and services offered by FortisBC, which may include contacting our customers to offer them energy efficiency rebates or other programs;
- To understand customer needs and preferences, which may include contacting our customers to ask them to participate in a survey regarding our programs and services;
- To meet legal and regulatory requirements;
- To manage FortisBC’s business and operations.
3. CONSENT FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
3.1 Types of Consent
We may seek Consent in various ways, depending on the circumstances and the type of information collected, including, for example, using an application form and/or a check-off box, or collecting oral consent - in particular, when information is collected over the telephone.
3.2 Withdrawal of Consent
An Individual may withdraw Consent at any time, on reasonable notice, subject to legal or contractual restrictions. We will inform the Individual of the implications of such withdrawal, which in some cases may be an inability for FortisBC to continue to provide services to the Individual.
3.3 Exceptions to Requirement for Consent
The Privacy Legislation set out specific circumstances under which FortisBC may collect, use or disclose personal information without the knowledge or Consent of the individual.
4. LIMITING COLLECTION, USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION
FortisBC limits both the amount and type of Personal Information collected to that which is necessary to fulfil the identified purposes.
With your consent, we may collect Personal Information from you in person, at one of our offices, over the telephone or by corresponding with you via mail, email or the Internet. By providing your Personal Information to or otherwise corresponding with FortisBC via email you acknowledge that you are aware that email is not a secure form of communication. Furthermore, with your consent, we may collect Personal Information from other sources including, but not limited to credit bureaus.
The type of Personal Information we collect and maintain in your customer file, may include, but is not limited to your: name, mailing and property address, email address, telephone number, social insurance number, date of birth, credit history, transaction history, electricity consumption, driver’s license number and other payment and billing information.
4.2 Use and Disclosure
FortisBC limits the use and disclosure of Personal Information for purposes other than those identified purposes, unless the Consent of the Individual has been obtained or if the use and disclosure is permitted or required by law.
Unless we have your explicit consent to do so, we will not sell, rent or lease your personal information to third parties.
There are some instances where FortisBC may disclose your Personal Information to fulfill regulatory and legislative obligations and to conduct our business in the ordinary course. In those instances where we do provide information to third parties, we provide only that Personal Information that is required in the circumstances and we include various provisions in our contracts that have been designed to protect privacy and security of your Personal Information. Third parties may include, but are not limited to:
(a) a collection agency for the purpose of collection of accounts payable; and
(b) a service provider that has been engaged by FortisBC to perform certain services for us, which may include partners, consultants and suppliers to FortisBC.
We may further disclose your Personal Information without your consent, in the following circumstances:
(a) as permitted or required by applicable law or regulatory requirements;
(b) to comply with valid legal processes such as search warrants, subpoenas or court orders;
(c) during emergency situations or where necessary to protect the safety of a person or group of persons; or
(d) any other circumstances permitted or required under PIPA.
4.3 Retention Limited
FortisBC has developed guidelines for the retention of Personal Information, which include minimum and maximum retention periods in compliance with the Privacy Legislation. The underlying principle of these retention guidelines is to keep Personal Information only as long as remains necessary or relevant for the identified purposes; and as required by law.
5. ACCURACY, CORRECTION, AND ACCESS
We endeavor to keep Personal Information in our custody and control accurate, complete, and up-to-date as this will allow us to provide the best service to our customers. Our customers can assist us by ensuring that the information they provide to FortisBC is current and accurate.
5.2 Correction Requests
Individuals may make a request to correct or rectify Personal Information held by FortisBC. The request must be made in writing and provide sufficient detail to allow FortisBC to identify the Personal Information, and the correction being sought. If the Individual successfully demonstrates that the Personal Information is inaccurate or incomplete, we will correct the Personal Information, as required, and send the corrected Personal Information to any third party to which we disclosed the Personal
Information in the prior year. If no correction is required to be made, we will note the request for correction and annotate the file accordingly.
For clarity, the requirement for a correction request to be made in writing does not pertain to requests to change contact information such as address, telephone number or email address. These changes may still be made over the telephone by contacting one of our customer service representatives.
5.3 Access Requests
An Individual may make a request for access to his or her Personal Information in the custody or control of FortisBC. The request must be made in writing and provide sufficient detail to allow FortisBC to identify the Personal Information they desire access to.
a) inform the Individual of the existence, use and disclosure of his or her Personal Information, as requested;
b) provide the Individual with access to the requested Personal Information, subject to statutory exemptions; and
c) respond to the Individual within the time limits prescribed by the Privacy Legislation.
5.4 Fees for Access
Where we are entitled to charge a fee in order to implement the access request, we will advise the Individual of the amount of the fee and the statutory entitlement to challenge the amount of the fee or request a fee waiver.
6.1 Security Safeguards
To protect Personal Information, regardless of the format in which it is held, against loss or theft, unauthorized access, collection, disclosure, copying, use, or modification, we have implemented security safeguards which are appropriate to the sensitivity of the information that has been collected, the amount, distribution, format of the information, and the method of storage.
The methods of protection used include, but are not limited to:
- physical measures, for example, locked filing cabinets and restricted access to offices and data centres;
- organizational measures, for example, limiting access on a “need-to-know” basis; and
- technological measures, for example, the use of passwords and encryption.
From time to time, we may store your Personal Information outside of Canada, where it may be subject to the lawful access requirements of the jurisdiction in which it is being held.
8. COMPLIANCE AND CONTACTS
8.1 Complaint to Privacy Officer
An Individual can submit a complaint in writing to the Privacy Officer concerning our compliance with the above principles. We will receive and respond to inquiries or concerns/complaints about our policies and practices relating to the handling of Personal Information.
8.2 Privacy Officer Contact Information
All inquiries should be in writing and addressed to the Privacy Officer as follows:
Chief Privacy Officer
Suite 100, 1975 Springfield Road
Kelowna, British Columbia