Privacy Policy

Effective date: March 26, 2019

Version: 5.0

Preface

Toronto Hydro is committed to keeping the personal information of its customers and members of the public accurate, confidential, and secure. This Privacy Policy Statement has been designed to inform Toronto Hydro’s customers and members of the public of Toronto Hydro’s commitment to and recognition of Toronto Hydro’s obligation to protect the personal information in its custody or control and meet the terms of applicable privacy laws, such as the Municipal Freedom of Information and Protection of Privacy Act (Ontario) (MFIPPA).

Contents

This Policy applies to individuals only; it does not apply to information about businesses. Toronto Hydro does, however, protect the confidentiality of business customer information in accordance with applicable law, including regulatory codes of conduct issued by the Ontario Energy Board, and contractual arrangements.

This Privacy Policy addresses how and why Toronto Hydro collects, uses, discloses, handles and protects the privacy of the personal information of its customers or members of the public. It further addresses the reasons why this personal information is collected, used, or disclosed, how the information is safeguarded, and outlines the individuals' rights in respect of this information. This Privacy Policy incorporates principles for the protection of personal information, as established by the Canadian Standards Association (CSA). This Privacy Policy also provides details with respect to your use of Toronto Hydro’s Website by customers and members of the public.

For the purposes of this Privacy Policy, "personal information" means information about an identifiable individual, but does not include an individual’s business contact information or work product. Personal information does not include information that has been aggregated or de-identified, such that an individual's information cannot be identified.

In this Privacy Policy, "Toronto Hydro", "we", "us" or "our" means Toronto Hydro Corporation and its wholly owned subsidiaries, including Toronto Hydro-Electric System Limited, and "customer", "you", and "your" means an individual customer, prospective customer, or other individual member of the public whose personal information is in our custody or control.

By accepting service from us, visiting or using our Website, or otherwise providing us with your personal information after having been given notice of this Policy, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time. We will endeavour to bring any policy changes to your attention, but you should periodically review the Policy for changes on our Website at torontohydro.com/myprivacy.

Personal information protection principles

Table of contents

1. Accountability
2. Identifying Purposes
3. Consent, Limiting Use, Disclosure and Retention
4. Limiting Collection
5. Limiting Use, Disclosure and Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance
11. Toronto Hydro Website

1. Accountability

Toronto Hydro is accountable for the protection of personal information within its custody or control, including any personal information that Toronto Hydro has transferred to a third party for processing purposes. Toronto Hydro may engage third parties from time to time to perform services for Toronto Hydro that involve access to personal information. Such third parties may be located outside of Ontario or Canada and, in such instances, the information might be accessed according to the laws in those jurisdictions. Toronto Hydro shall use contractual or other means to provide a comparable level of protection of this information while the information is being processed by such third parties.

Toronto Hydro has privacy and security standards, guidelines, and procedures to support this Policy and improve the protection of personal information.

Toronto Hydro’s Chief Privacy Officer is accountable for Toronto Hydro’s compliance with this Privacy Policy Statement. Toronto Hydro’s Chief Privacy Officer is the Executive Vice-President, Public and Regulatory Affairs Chief Legal Officer. The Chief Privacy Officer may be contacted as follows for additional information on Toronto Hydro’s collection and use of personal information:

2. Identifying Purposes

Toronto Hydro will identify the purposes for which it collects personal information at or before the time the information is collected, such as when you apply for service from us (for example, purposes may be identified on Toronto Hydro forms or by reference to this Privacy Policy Statement). Toronto Hydro collects, uses and discloses personal information as authorized or required by applicable law (including MFIPPA) and for purposes such as:

• To authenticate identity;
• To contact customers (at mailing and/or service address), respond to customer inquiries or service issues, and to otherwise maintain business relations with customers;
• To deliver, monitor and maintain electricity service;
• To monitor and assess quality of service (for example, Toronto Hydro may monitor and/or record telephone communication with you for quality assurance and training purposes);
• To bill and collect payment and maintain records of same (including arrangements for pre-authorized payments through bank account or credit card);
• To determine account eligibility and creditworthiness (for example, through employment and reference checks);
• To provide information to credit bureaus and other utility providers to update credit information;
• To address and respond to issues related to the usage of critical, power dependant, medical equipment during an outage;
• To provide information to third party service providers, such as an electricity retailer with whom you have contracted;
• To minimize, investigate and/or report potentially dangerous use of electricity, error, fraud, theft of power or other breach of law or contract;
• To assist Toronto Hydro with legal matters or proceedings, including preparation for same;
• To facilitate a business transaction involving Toronto Hydro assets, such as a transfer, sale or financing of assets (see further detail below under Limiting Use, Disclosure and Retention);
• To provide customers or members of the public with information about Toronto Hydro services, the electricity industry, rates and energy conservation;
• To facilitate the development, communication, delivery, review or analysis of climate change, conservation and demand management programs by Toronto Hydro or its contractors;
• To request customer or public participation in surveys, contests or other similar activities and initiatives;
• To notify customers or members of the public about events, causes or programs sponsored by Toronto Hydro and to keep track of participation levels and interest in such events;
• To provide individuals with information they have requested, such as financial quarterly reports or news releases;
• To prepare financial records for Toronto Hydro; and
• To meet other legal, regulatory and electricity market operation authorizations and requirements.

The above collections, uses and disclosures, which are not exhaustive, are a necessary part of your relationship with Toronto Hydro.

3. Consent

Toronto Hydro will obtain your consent before, or when, it collects, uses or discloses your personal information, except where collection, use or disclosure is authorized or required by law. For example, by accepting distribution and related services from us, your consent to the collection, use and disclosure of your personal information for the purposes of providing you with such distribution and related services is implied.

Consent may be provided orally, in writing, electronically, or implied (such as when you fail to notify Toronto Hydro that you do not consent to collection/use/disclosure for certain purposes after you have received notice of those purposes, for example, through this Privacy Policy Statement) or otherwise.

Consent may be obtained directly from you or from a third party that has obtained your consent to disclose your personal information to Toronto Hydro. For example, if you sign a separate contract with a retailer, Toronto Hydro may obtain your personal information from the retailer and Toronto Hydro may provide your billing and consumption information to the retailer. Consent may also be given by an authorized representative such as a legal guardian or person with power of attorney.

Subject to certain legal and contractual restrictions and reasonable notice, you can refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time. However, refusal to provide such consent, or withdrawal of such consent, may prevent us from providing you with certain products or services for which information is necessary.

In certain circumstances under the laws of Canada and Ontario, Toronto Hydro may have a duty or right to collect, use or disclose your personal information without your knowledge or consent.

4. Limiting Collection and Access

Toronto Hydro will not collect personal information indiscriminately and will limit collection of personal information to that which is reasonable and necessary for the purposes outlined in this Privacy Policy Statement or as otherwise consented to by you, and as authorized or required by applicable law.

Likewise, access to personal information will be restricted to only those Employees of Toronto Hydro who require access in order to perform their duties in fulfilling the purposes outlined in this Privacy Policy Statement, and as authorized or required by applicable law.

Section 34 of MFIPPA requires Toronto Hydro to keep an updated Personal Information Bank, which is defined as “a collection of personal information that is organized and capable of being retrieved using an individual’s name or an identifying number or particular assigned to the individual.” You can contact Toronto Hydro to obtain a copy of the Personal Information Bank at privacy@torontohydro.com.

5. Limiting Use, Disclosure and Retention

Toronto Hydro will use and disclose personal information as reasonable and necessary for the purposes outlined above as otherwise consented to by you, and as authorized or required by applicable law. For example, MFIPPA lists general categories of circumstances where the use and disclosure of personal information is permitted by law under sections 31 and 32 of that statute.

Further, because of the structure of the electricity sector in Ontario, it may be necessary to share your billing and consumption information with third party billing and settlement agencies, such as where you have signed a separate contract with a retailer. Our billing, settlement and regulatory relationships with third parties are governed by our license and regulatory codes that are established by the Ontario Energy Board. In accordance with the Affiliates Relationship Code, Toronto Hydro will not disclose any consumer information (which may include personal information) to any of its affiliates without the consumer's written consent except where consumer information is required to be disclosed:

1. for billing or market operation purposes;
2. for law enforcement purposes; or
3. for the purpose of complying with a legal requirement.

Toronto Hydro will retain personal information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. Toronto Hydro will not trade, rent or sell your personal information. However, in the course of a business transaction, such as a proposed sale of Toronto Hydro's business or assets (or a part thereof), or a merger or amalgamation of Toronto Hydro with another company, we may disclose (with appropriate safeguards) your personal information to third parties such as prospective purchasers of Toronto Hydro's shares, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction.

6. Accuracy

Toronto Hydro maintains procedures to ensure that the personal information we collect, use and disclose is kept as accurate, complete and up-to-date as necessary for the purpose for which it is to be used. However, we rely on you to disclose all material information to us and to inform us of any errors or changes in such information.

Individuals may challenge the accuracy and completeness of personal information about them and have it amended or annotated, as appropriate, as set out in Section 9 below.

7. Safeguards

In fulfilling its responsibilities with respect to the confidentiality of personal information, Toronto Hydro will employ a number of safeguards, appropriate to the sensitivity of the specific information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, such as locked filing cabinets, restricted access to offices, security clearances, limiting access on a "need to know" basis, use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and relevant third parties to ensure compliance. It is also important for you to take precautions to protect your personal information such as keeping your user name and passwords confidential.

8. Openness

This Privacy Policy Statement is effective as of the Effective Date set forth at the beginning of this Privacy Policy Statement. Toronto Hydro will review this Privacy Policy Statement annually and may make revisions to this Privacy Policy Statement from time to time. Toronto Hydro will endeavour to bring such revisions to the attention of its customers and members of the public by such means as Toronto Hydro's Website and bill inserts.

9. Individual Access

Upon request and with satisfactory proof of the customer's identity, any customer of Toronto Hydro may obtain information regarding the type, use and disclosure, of his, or her, personal information that Toronto Hydro has in its custody or control. Any customer may request that his, or her, personal information be amended for purposes of accuracy and completeness. Where a disagreement regarding the accuracy of a customer’s information cannot be resolved, Toronto Hydro will annotate the information to reflect the disagreement. Toronto Hydro may require the customer to provide access or correction requests in writing. We may also charge a nominal fee for responding to such requests, and, if so, will advise you in advance of such costs. This right of access, however, is not absolute. For instance, Toronto Hydro may refuse to provide you with access to your personal information where such refusal is authorized or required by law or regulatory authorities.

Customers can make their requests by contacting Toronto Hydro by telephone at 416-542-8000, by fax to 416-542-3452, or in writing to Toronto Hydro, Customer Care, 500 Commissioners Street, Toronto, Ontario M4M 3N7, and our customer service representatives will assist you. Response to a customer's request will be made within a reasonable time provided the request is made in writing and the customer provides satisfactory proof of the customer's identity.

10. Challenging Compliance

Any customer of Toronto Hydro may challenge Toronto Hydro's compliance with this Privacy Policy Statement in respect of his or her personal information by contacting Toronto Hydro's Chief Privacy Officer, in writing, at the address set forth in Section 1.

The Chief Privacy Officer will be responsible for investigating all allegations of non-compliance with this Privacy Policy Statement. To the extent possible, the investigation will be conducted in a timely manner. After the investigation is completed, the customer will be advised of the outcome, and a resolution will be implemented, if necessary, as soon as practicable. If it is determined that a breach of this Privacy Policy Statement has occurred, appropriate corrective action will be taken. Confidentiality will be maintained throughout the investigation to the extent possible and consistent with the goal of a full and fair investigation.

If the Chief Privacy Officer does not resolve the issue to the customer's satisfaction, the customer may contact the Privacy Commissioner of Ontario.

11. Toronto Hydro Website

(a) Visiting the Toronto Hydro Website

Toronto Hydro may collect Personal Information that you voluntarily provide to us when you visit our Website. Personal Information provided by visitors to Toronto Hydro's Website will be collected, used and disclosed in the same manner as information collected by other means, and in a manner consistent with this Privacy Policy Statement. Since this Privacy Policy Statement may be amended from time to time, we recommend that you check the latest version of our Privacy Policy Statement each time you visit our Website.

(b) Security

Personal information submitted through Toronto Hydro's Website will be encrypted using a minimum 128 bit encryption with 1024 bit public key technology to help protect and enable its arrival in an unread and unaltered state to Toronto Hydro's technology infrastructure. However, users should be aware that personal information could be intercepted over the Internet. Toronto Hydro is not responsible for the interception, collection, use or alteration of information transmitted over the Internet, such as by email.

(c) Automatic Data Collection

As is the case with Websites generally, when visitors access the Toronto Hydro Website, the site software automatically collects the Internet Protocol (IP) address of the computer through which the user is connected to the Internet. The Toronto Hydro Website also automatically collects information about the user's Internet browser software, operating system, the date and time of the user's visit, the URL of the last page visited by the user before entering the Toronto Hydro Corporation family of Websites, and the pages accessed while on our site. This information is not used to gain personal information on individual users but is aggregated with that of other visitors to help us understand how the site is being used and how to make it better.

(d) Cookies

When a visitor accesses the Toronto Hydro Website, a cookie is automatically installed on the visitor's computer hard-drive. A cookie is a small text file that contains a unique identification number, which can be used to identify the user's browser, but not the user. Cookies form an essential part of the Internet today by allowing Websites to recognize users' browsers when the users return to previously visited Websites. Since cookies are only text files, they cannot "run" on your computer and have no ability to search your computer for information or to transmit information to anyone. Toronto Hydro uses cookies to provide certain features on its Website. We do not use cookies to retain personal information. Users are free to prevent the installation of cookies on their computer hard-drive, including the Toronto Hydro cookie, by simply disabling the feature in their browser's options. Some browsers allow users to accept or reject cookies as they are presented to the user. Please note that users will not be able to access some features and services of the Toronto Hydro Website if they disable cookies.

(e) Email Communications

Toronto Hydro adheres to a no spam policy. Therefore, you will not receive regular, unsolicited e-mail communications from Toronto Hydro unless you have agreed otherwise or such communications are required for the purposes identified in this Privacy Policy Statement above or to otherwise provide a product, service or information to you that you have requested.

Please note that Toronto Hydro reserves the right to contact you, by e-mail or otherwise, if permitted or required by law or regulatory authorities or if there has been a violation of Toronto Hydro's Website Terms of Use.

(f) Response Tracking

Toronto Hydro uses Website usage information about visitors to our Website who have responded to a promotional campaign about Toronto Hydro's services for the purpose of future promotional campaigns, and evaluating usage statistics. For this purpose, we collect information about the campaigns and some of the pages you visit on our Website through the use of tracking numbers passed through URL's transferred to our information technology as well as pixels tags (also known as clear GIFs).

As well, Toronto Hydro may use third-party companies to host and serve online advertisements for Toronto Hydro promotional campaigns. Pixel tags may be used in connection with online advertisements, for example, to allow us to count the number of times the advertisement was viewed versus the number of individuals who enrolled in the product or service advertised.

Personal information about you is not collected by any such third-party companies, nor is any tracking information generated from the pixel tag used by them for any purpose other than to report advertising response and Website activity to us.

(g) Links to Third-Party Sites

Toronto Hydro's Website contains links to third-party Websites. Toronto Hydro is not responsible for (a) any information you provide to other Websites outside of TorontoHydro’s domain that you access through a link on our Website or (b) the privacy practices or the content of such Websites outside of Toronto Hydro’s domain.

(h) Questions

Questions about personal information collected through Toronto Hydro-Electric System Limited's Website should be addressed to privacy@torontohydro.com and will be addressed in accordance with this Privacy Policy Statement.