Privacy Policy

Purpose

Lakefront Utility Services Inc. (LUSI), is committed to providing its customers with exceptional service. While LUSI has always respected its customers’ privacy and safe-guarded their personal information, LUSI has strengthened its commitment to protecting personal information as a result of its obligations under the Municipal Freedom of Information and Protection of Privacy Act, which sets out the rules for how public institutions may collect, use and disclose personal information.

As providing this service involves the collection, use and disclosure of some personal information about its customers, protecting their personal information is one of LUSI’s highest priorities.

Contents

This Privacy Policy describes the principles by which LUSI protects the privacy of personal information in its possession. It addresses the reason why such information is collected, how it is used, how its confidentiality is protected and outlines the customers’ rights in respect to this information. This privacy policy incorporates and expands on the 10 principles for the protection of personal information, as devised by the Canadian Standards Association (CSA).

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

Personal Information Protection Principles

  1. Accountability

LUSI 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. LUSI will require a comparable level of protection of this information from its third parties.

  1. Identifying Purposes

LUSI collects 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.

Additional purposes for collecting personal information will be identified to an individual before or at the time of collection.

Personal information that LUSI collects from customers includes:

  • Customer’s name, address, and other contact information such as phone numbers and e-mail address;
  • Meter numbers;
  • Facts about consumption of power, both historic and current;
  • Information about a customer’s transactions, such as account numbers, account balances, and payment history;
  • Credit and reference information, such as date of birth, employment information, driver’s licence, previous addresses and general financial information;
  • Medical information to be used in case of emergency power outages; and
  • Bank information for pre-authorized payments
  1. Consent

LUSI will obtain consent to collect, use or disclose personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information about them expressly or implicitly. LUSI 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.

All existing customers will be informed of what types of personal information have been collected, the purpose for the collection and the procedures available for contacting LUSI 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.

  1. Limiting Collection

LUSI limits the amount and type of personal information it collects to that which is necessary for the business of the utility. Each affiliate of LUSI will be responsible for its own collection, use and disclosure of information. Personal information will be collected using procedures that are fair, transparent and lawful.

  1. Limiting Use, Disclosure and Retention

LUSI will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection.

LUSI will not use or disclose personal information for any additional purpose unless consent is obtained to do so.

Under certain exceptional circumstances, LUSI may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.

LUSI will maintain explicit retention periods for closed accounts, after which the personal information will be destroyed or made anonymous.

  1. 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.

  1. Safeguards

LUSI is committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. Such safeguards will include physical measures, organizational measures and technological measures. Methods of protection and safeguards include, but are not limited to: locked filing cabinets, restricted access to offices, security clearances, need-to-know access and technological measures including the use of passwords, encryption and firewalls. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.

  1. Openness

LUSI will make this policy relating to the protection of personal information available to its customers. LUSI will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via LUSI’s web page and bill inserts. The information will be available in a format that is easy to read.

  1. Individual Access

Any customer may request their personal information be amended for purposes of accuracy and completeness.

Customers can make their requests by telephone 905-372-2193, via email hr@lusi.on.ca or in writing to Lakefront Utility Services Inc., 207 Division Street, PO Box 577, Cobourg, ON K9A 4L3, Attention: Privacy Officer. Response to an individual’s request will be made within 30 days.

  1. Challenging Compliance

Any customer of LUSI may challenge LUSI’s compliance with this Privacy Policy by contacting LUSI directly. LUSI has policies and procedures to receive, investigate and respond to individuals’ complaints and questions. If the customer is not satisfied with the way LUSI has responded to a complaint, the customer can contact the Information and Privacy Commissioner of Ontario at https://www.ipc.on.ca/