Privacy policy

Policy statement

Utilities Kingston is committed to keeping the personal information of its customers and employees accurate, confidential, and secure. This Privacy Policy Statement has been designed to inform Utilities Kingston’s customers and employees of our commitment to meeting the terms and spirit of the privacy laws that apply to us: such as the Personal Information and Electronic Documents Act (Canada) (PIPEDA) and the Municipal Freedom of Information and Protection of Privacy Act (Ontario) (MFIPPA).

We have put rules in place across Utilities Kingston to make sure the personal information of our customers and employees is kept secure, confidential and accurate.

Personal information means any information that would identify a customer or employee: for example, name and address and phone number; financial or credit information; an employee’s employment history or information about a customer’s electricity use.  Personal information does not include information that has been anonymized or combined with other details in such a way that it is impossible to identify any individual.

Further details about how we protect our customers’ and employees’ privacy can be found below. We have developed our privacy policy based on Schedule 1 of PIPEDA and the rules found in MFIPPA. The privacy rules in these two laws originated with international privacy standards that are the basis of privacy rules around the world.

If you have any questions about how we protect personal information at Utilities Kingston, or questions or comments about how your own personal information was collected, used or shared, please contact Utilities Kingston’s Privacy Officer:

  • By telephone at 613-546-1181, extension 2492
  • By e-mail to yourprivacy@utilitieskingston.com
  • Or, in writing to Privacy Officer, Utilities Kingston, P.O. Box 790, Kingston ON K7L 4X7

Scope

This Privacy Policy describes how Utilities Kingston protects the personal information of its customers and employees.  The policy explains why we collect certain kinds of personal information, how we use this information and how we look after it while it is with us. This policy also explains customers' rights of access to their own information and/or its correction.

In this Privacy Policy, "Utilities Kingston", "we", "us" or "our" means Utilities Kingston "Customer", "you" and "your" mean the individual who is a customer or prospective customer. “Employee”, “you” and “your” mean the individual who is an employee or potential employee.

However, this Privacy Policy does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. We protect the confidentiality of such information in accordance with the law, regulatory codes of conduct issued by the Ontario Energy Board, contractual arrangements and our own policies.

By accepting service from us, using our website, or otherwise providing us with your personal information, you are accepting the practices described in this Privacy Policy, and as they may be changed by us from time to time. Since we may change the terms in this Privacy Policy occasionally, we recommend you review it periodically.

Personal information protection principles in PIPEDA and MFIPPA

Accountability:  An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with privacy principles.

Identifying purposes:  An organization shall identify the purposes for which personal information is collected at or before the time the information is collected.

Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Limiting collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Limiting use, disclosure, and retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information must be retained only as long as necessary for the fulfilment of those purposes.

Accuracy: Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

Openness:  An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Individual access: Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Challenging compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.

Accountability

At Utilities Kingston, the President and CEO has ultimate responsibility for protecting the privacy of our customers and employees. While they have delegated the day-to-day responsibilities to Utilities Kingston’s Privacy Officer, all employees must meet Utilities Kingston’s privacy rules.

Utilities Kingston’s Privacy Officer is the person who makes sure the privacy rules are established and followed across the organization. They are responsible for keeping Utilities Kingston’s privacy rules current and up-to-date. They are also the person who should receive any privacy complaints or inquiries about privacy at Utilities Kingston. If you have questions or concerns, please contact by e-mail at yourprivacy@utilitieskingston.com.

Utilities Kingston is responsible for protecting the personal information that it holds about its customers and employees, or that it discloses to third parties (i.e., service providers, banks, credit unions) about those individuals for various reasons. Utilities Kingston has a number of contracts and agreements with third parties. Those contracts hold the third party to the same level of privacy protection as Utilities Kingston provides.

We have trained our staff so they understand the privacy rules and why they must protect customer information. There are also policies and procedures in place across the organization to make sure all staff comply with the privacy rules in PIPEDA and MFIPPA.

Identifying purposes

When we ask you for any personal information, we will explain the reason for the request: why we are collecting your personal information and what we will do with it.  For example, when a customer opens an account with us and apply for service, we will tell you why we are asking for certain pieces of information and what we will do with them.

After that point, if we need to use your personal information for any other reason, we will explain the new use and ask for consent before we use it. A customer may refuse to allow us to use their personal information for this new purpose, unless the new purpose is required by law or our regulatory authorities. However, if you refuse we may not be able to provide you with some services since we need certain kinds of personal information in order to provide utility services to you.

Generally, we will use your personal information for the following reasons:

  • To contact you, to answer questions about your account and to give you information about Utilities Kingston programs and services;
  • To provide you with electricity, water, wastewater,  natural gas services or services related to appliance rentals, or networking services;
  • To bill you for the services you use;
  • To establish your credit worthiness;
  • To enrol you for pre-authorized payment plans;
  • For legal, regulatory market operation requirements;
  • To help prevent or investigate fraud, theft of power or other illegal activities
  • To ask you to take part in contests, surveys or research.

We monitor customers’ telephone conversations with staff for quality assurance purposes and we use surveillance cameras on our property. There are signs on our buildings regarding video surveillance; and recorded messages when you call our offices so customers and visitors are aware of these activities.

If a Utilities Kingston employee asks a customer for personal information, that employee should be able to explain how the information will be used. In some cases, privacy questions may be referred to our Privacy Officer, who can provide additional information and answer customers’ questions.

Consent

Utilities Kingston will ask for your consent for the collection, use and/or disclosure of your personal information when we collect it from you. In most cases, your consent will be express. For example, when you open an account and complete an Application for Service you are providing express consent for Utilities Kingston to use your personal information to provide you with services and bill you for them.

Sometimes your consent will be implied. For example, if Utilities Kingston contracts repair work to another company, in the event of a power outage some of your personal information (your name and address) would be disclosed to allow that company to restore service to your home.

You may give your consent directly to Utilities Kingston or you may give it through a third party who has your consent. For example, if you sign a separate contract with an electricity or natural gas retailer, the retailer may give your personal information to Utilities Kingston. We might also give your billing and energy use to that retailer. Someone acting for you, such as a legal guardian or person with power of attorney, may also give consent on your behalf.

There are only limited circumstances when we might collect, use or disclose your personal information without your knowledge or consent. These circumstances are permitted or required by law or by our regulatory authorities.

You can refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time. However, Utilities Kingston may require you to give notice of your intent, or we may tell you that your refusal or withdrawal of consent is not possible for certain reasons. You need to be aware that your refusal to consent, or your withdrawal of consent, may mean that Utilities Kingston cannot provide you with some services. In such circumstances, we will explain the effects of your withdrawal or refusal to provide consent.

Limiting collection

Utilities Kingston will not ask for any more of your personal information than we need for the reason(s) we have explained.

The kind of information we usually ask for includes:

  • Your name and address (mailing and service address) and other contact information (i.e., home and work telephone numbers and e-mail addresses).
  • Facts about past and current electricity use at your home.
  • Your account history with a previous hydro utility if you are opening an account with us (i.e., account number, account balances, payment history, and account activity).
  • Identifying information (i.e., date of birth, driver's licence number).
  • Bank information for pre-authorized payments (i.e., name and address of bank, your account type and number).
  • Information related to a letter, e-mail or phone call from you.

Limiting use, disclosure and retention

Because of the structure of the electricity and natural gas distribution sector in Ontario, we may have to share your billing and consumption information with third party billing and settlement agencies; for example, if you have signed a separate contract with an energy retailer.

We may also share your personal information with other agencies or organizations as required or permitted by law or regulatory authorities. For example, our billing, settlement and regulatory relationships with third parties are governed by our license and regulatory codes. These are established by the Ontario Energy Board.

Utilities Kingston has a service agreement with the City of Kingston, where City of Kingston employees provide services for us, including front-line customer service. When you call or email Utilities Kingston to set up or discuss your account, you are actually speaking to a City of Kingston employee. Our agreement with the City of Kingston holds those employees to the same privacy standards that are set out in this policy and your privacy is protected at all times.

Utilities Kingston will not disclose any personal information to any of its affiliates without your written consent except where such a disclosure is required. This might include:

  • For billing or market operation purposes.
  • For law enforcement purposes.
  • To  comply with a legal requirement.
  • To process a customer's past due account which is now with a third party for collection.

Under other certain circumstances, Utilities Kingston may have a legal duty or right to collect, use or disclose your personal information without your knowledge or consent.

We will keep your personal information only as long we need it for the reasons we gave you when we collected it in the first place and to meet legal and contractual obligations. We will not trade, rent or sell your personal information to anyone for any reason.

We will protect your personal information while we have it. We will apply our records retention policies and schedules to your personal information. Once we no longer need to keep your information, we will destroy it in a secure manner so it cannot be reassembled and used by anyone else. 

The only employees at Utilities Kingston who will see your personal information are those whose jobs require access to customers’ personal information.

Accuracy

We make every effort to keep your personal information as accurate and up-to-date as possible. From time to time, we may ask you for additional information about your account or your consumption, particularly if you are signing up for a new program or service. For example, if you join our electronic billing service, we will ask you for your email address and a password.

However, we also rely on our customers to make us aware of any change that might be important to maintaining a good working relationship. This includes: changes to contact information such as phone or email; changes to financial information such as a new bank account or credit card number; and obvious changes such as a move to a new address. We only use this personal information for the reasons we explained when we asked for it in the first place (please see limiting collection above) and it is important that we keep your information accurate.

If you feel we may be using information about you that is out-of-date or incorrect, you may ask to see the information we have on file about you and ask for a correction, if that is required. Further details about that process are included in the individual access section below.

Safeguards

While we have your personal information, we take great care to protect it from loss or theft or any unauthorized access. This means we have rules in place to make sure your information is not copied or changed in any way, or used or disclosed in a way that is not consistent with the consent you gave us.

The way we protect your personal information depends on the format in which we hold it. Paper files are held in locked filing cabinets and only accessible to employees who need the information to do their jobs.

Electronic files are protected behind firewalls and are password-protected. Only employees whose access has been approved by their manager and our Privacy Officer have password access. Personal information that must be disclosed to third parties for billing purposes is encrypted.

All employees at Utilities Kingston are aware of their responsibility to protect personal information.

Openness

We have policies and procedures in place to protect the personal information we hold about customers.  We have prepared this Privacy Policy to ensure you understand what we do with the personal information we hold.

Individual access

Anyone can request to see their personal information and request a correction if that information is wrong or out-of-date. There may be some situations where we may not be able to provide access to all the personal information we hold about someone. These exceptions are limited and specific. They include situations where one individual’s personal information contains references to other people, where the information was supplied in confidence, or it is information that cannot be disclosed for legal, security or proprietary commercial reasons.

In making a request to see your own personal information, you will be asked to provide identifying information so that we can confirm your identity. This identifying information will only be used to confirm your right of access to your own information.

If a correction or amendment is required, we will correct your personal information as quickly as possible. If there is a difference of opinion as to the need for a correction, a statement of disagreement will be attached to your file. In either event, we will share the correction or the statement of disagreement with any third parties who have used the personal information within the past year.

Challenging compliance

Anyone who wishes to question our compliance with this privacy policy or any of the privacy rules found in PIPEDA or MFIPPA can do so by contacting our Privacy Officer:

  • By telephone to 613-546-1181, extension 2492
  • In writing to Privacy Officer, Utilities Kingston, P.O. Box 790, Kingston ON K7L 4X7
  • By email yourprivacy@utilitieskingston.com

If you have a complaint about how Utilities Kingston has treated your personal information, you may contact the Information and Privacy Commissioner of Ontario.

By mail: 2 Bloor Street East, Suite 1400 Toronto, ON M4W 1A8

By telephone: Toronto Area: 416-326-3333, Long distance: 1-800-387-0073