Privacy Policy Statement

Purpose

Centre Wellington Hydro (CWH) is committed to keeping the personal information of its customers accurate, confidential, secure and private. This Privacy Policy has been designed to inform customers, employees, suppliers, and subcontractors of CWH of our commitment and recognition of our obligation to meet the spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Policy

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

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

Personal Information Protection Principles

1. Accountability

CWH 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. CWH will require a comparable level of protection of this information from its third-party relations.

2. Identifying Purposes

Personal information that CWH collects from customers includes: the customer’s name and address and other contact information; the meter number; facts about consumption of power and water, both historic and current; facts about payment history, including general financial information; credit and reference information, such as date of birth, employment information, driver’s licence, previous addresses, telephone numbers, e-mail address, medical information to be used in case of emergency power outages, and bank information requested for pre-authorized payments.

When an individual applies for service, CWH will make the individual aware of the purposes for which CWH is requesting the personal information. If CWH identifies other purposes for which the personal information may be used, CWH will seek the individual’s consent prior to such use. CWH will advise that it is the individual’s right to refuse permission for CWH 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, CWH will collect personal information for the following purposes:

• Billing and collection of payments
• Pre-authorized payment for services
• Priority restoration of electric service to the correct address and meter, as may be required by medical circumstances
• Energy and water sector legal, regulatory and settlement requirements
• Conducting customer surveys including customer satisfaction surveys

3. Consent

CWH 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. CWH 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 reduce or withdraw their consent to the collection, use or disclosure of personal information about them at any time. Should a customer withdraw consent, other forms of security, including but not limited to security deposits, may be required.

All existing customers will be informed of the types of personal information that have been collected, the purpose for the collection and the procedures available for contacting CWH with any inquiries. All new customers will be provided with a verbal and/or written explanation about the collection, use and disclosure of personal information when requesting service. CWH will obtain verbal and/or written consent before it collects personal information from all new customers.

4. Limiting Collection

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

5. Limiting Use, Disclosure and Retention

CWH 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. In accordance with the Affiliate Relationship Code, created under the provincial Electricity Act, no customer information will be disclosed by one affiliate to another.

CWH will develop explicit retention periods for closed accounts (zero balance), after which the personal information is destroyed or made anonymous. Under certain exceptional circumstances, CWH may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.

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.

7. Safeguards

In executing its responsibilities with respect to the confidentiality of personal information, CWH 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 measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances, 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.

8. Openness

CWH will develop and make available to its customers policies and practices relating to the protection of personal information. CWH will keep its customers informed of these policies and practices via CWH’s web page and bill inserts. The information  will  be  available  in  a  format  that  is  easy  to  understand.

9. Individual Access

Any customer of CWH can have access to the personal information about them that CWH 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 requests by telephone (519-843-2900), via email (enquiries@cwhydro.ca) or in writing ( P.O. Box 217, Fergus, Ontario, N1M 2W8). Response to an individual’s request will be made in a timely and efficient manner.

10. Challenging Compliance

Any customer of CWH may challenge CWH’s compliance with this Privacy Policy by contacting CWH directly.

CWH will investigate all complaints concerning compliance with this Privacy Notice. If a complaint is found to be justified, CWH shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer will be informed of the outcome of the investigation regarding the complaint within thirty (30) business days.

If the customer is not satisfied with the way CWH has responded to a complaint, the customer can contact the Office of the Privacy Commissioner of Canada.

Dated: September 2025, Rev.1