Sioux Lookout Hydro Privacy/Policy Code
Introduction
At Sioux Lookout Hydro, customer privacy is a high priority. We have long‐standing practices
employed that protect the privacy of customers in all our business operations. The Sioux Lookout
Hydro Privacy Code is a formal statement of principles and guidelines concerning the minimum
requirements for the protection of personal information provided by Sioux Lookout Hydro to its
customers and employees. The objective of the Sioux lookout Hydro Privacy Code is to promote
responsible and transparent practices in the management of personal information, in accordance
with the provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA).
Sioux Lookout Hydro will continue to review its Privacy Code to ensure it is relevant and remains
current with changing technologies and laws. Most importantly, Sioux Lookout Hydro wants to
ensure it continues to meet the evolving needs of our customers and employees.
Deanne Kulchyski
Chief Privacy Officer
President/CEO
Summary of Principles
Principle 1: Accountability
Sioux Lookout Hydro is accountable for the protection of all personal information within the
organizations’ possession or control, including any personal information that has been transferred
to a third party for regulatory, legal or processing purposes. Sioux Lookout Hydro will require a
comparable level of protection of this information from its third party relations.
Ms. Deanne Kulchyski, President/CEO, is designated as Sioux Lookout Hydro’s Chief Privacy Officer,
and has overall responsibility for our protection of personal information and for Sioux Lookout
Hydro’s compliance with this Privacy Policy.
Principle 2: Identifying Purposes
Personal information that Sioux Lookout Hydro collects from customers includes: the customer’s
name and address and other contact information; the meter number; facts about consumption of
power, both historic and current; facts about payment for electric service, including general
financial information, credit and reference information, such as date of birth, employment
information, drivers licence, previous addresses, telephone numbers, e‐mail addresses, medical
information to be used in case of emergency power outages, and bank and credit card information
requested for pre‐authorized payments.
When an individual applies for service, Sioux Lookout Hydro will make the individual aware of the
purposes for which Sioux Lookout Hydro is requesting the personal information. If Sioux Lookout
Hydro identifies other purposes for which the personal information may be used, Sioux Lookout
Hydro will seek the individual’s consent prior to such use. Sioux Lookout Hydro will advise that it is
the individual’s right to refuse permission for Sioux Lookout 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, Sioux Lookout 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
Principle 3: Consent
Sioux Lookout 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. Sioux Lookout 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. 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 Sioux Lookout Hydro with any inquiries. All new customers will be provided with a consent form and an accompanying explanation about the collection use and disclosure of their personal information when requesting
service.
Principle 4: Limiting Collection
Sioux Lookout 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.
Principle 5: Limiting Use, Disclosure and Retention
Sioux Lookout 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.
Sioux Lookout Hydro will develop explicit retention periods for closed accounts (zero balance),
after which the personal information will be destroyed or made anonymous.
Under certain exceptional circumstances, Sioux Lookout Hydro may have a legal duty or right to
disclose personal information without the individual’s knowledge or consent.
Principle 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.
Principle 7: Safeguards
In executing its responsibilities with respect to the confidentiality of personal information, Sioux
Lookout 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 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.
Principle 8: Openness
Sioux Lookout Hydro will make its policies and practices relating to the protection of personal
information available to its customers. Sioux Lookout Hydro will keep its customers informed of
these policies and practices and customers shall be provided access to all related policies and procedures via Sioux Lookout Hydro’s web page and bill inserts. The information will be available
in a format that is easy to understand.
Principle 9: Individual Access
Any customer of Sioux Lookout Hydro can have access to the personal information about them that
Sioux Lookout 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 request by telephone, via e‐mail, or in writing. Contact information is
provided under Principle 10.
Response to an individual’s request will be made in a timely and efficient manner.
Principle 10: Challenging and Compliance
Any customer of Sioux Lookout Hydro may challenge Sioux Lookout Hydro’s compliance with this
Privacy Policy by contacting our Chief Privacy Officer directly. Sioux Lookout Hydro has policies
and procedures to receive, investigate and respond to individuals’ complaints and questions. If the
customer is not satisfied with the way Sioux Lookout Hydro has responded to a complaint, the
customer can contact the Privacy Commission of Canada.
Contact information for Sioux Lookout Hydro’s Chief Privacy Officer:
Ms. Deanne Kulchyski, President/CEO
Sioux Lookout Hydro Inc.
25 Fifth Ave., PO Box 908
Sioux Lookout, ON P8T 1B3
Ms. Kulchyski’s direct contact information:
Phone: (807)737‐3800
Fax: (807)737‐2832
E‐mail: dkulchyski@siouxlookouthydro.com
If using e‐mail as a point of contact, please ensure that you identify “Privacy” in your subject
line.