Privacy Policy

Effective date: July 2, 2024

Version: 6.0

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 Privacy 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 handles personal information. It also describes individuals' rights in respect of their personal information and how individuals can submit questions, requests and complaints. 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 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" and “individual” means an individual customer, prospective customer or other individual member of the public whose personal information is in our custody or control.

This Privacy Policy applies when an individual accepts service from us, visits or uses our website, or otherwise interacts with us, as it may be amended from time to time.

Personal Information Protection Principles

Table of Contents

1. How and Why We Collect Personal Information
2. Sharing Personal Information
3. Individual Consent
4. Our Practices
5. Accuracy
6. Safeguards and Employee Training
7. Cookies and Website Privacy
8. Questions, Requests and Concerns
9. Contact Us Compliance
10. Updates to This Privacy Policy

1. How and Why We Collect Personal Information

Toronto Hydro collects personal information under the authority of the Electricity Act, 1998, and the Ontario Energy Board Act, 1998.

Information we collect and purposes for doing so:

Most of the information we collect is obtained directly from individuals. The types of information we collect depends on the circumstances, including what information individuals choose to provide us and the service or request in question. Usually, we collect the following types of information:

• Contact information, such as name, address, phone number and email, to communicate with individuals about Toronto Hydro services, the electricity industry, rates and energy conservation, respond to requests, and open and administer accounts (including billing). We may also use contact information to promote and track participation in customer or public surveys, events, contests or other similar activities and initiatives;
• Account information, such as account number, service address, date of birth, government ID number, employer, and login information, to authenticate an individual’s identity, confirm eligibility for services, open and administer accounts and to provide individuals with a copy of their personal information, upon request;
• Interactions with us, such as recordings of calls, to keep track of requests, perform quality assurance, resolve disputes and train employees;
• Customer energy usage and service address, to deliver, monitor and maintain electricity services, meet our legal obligations, and bill appropriately;
• Payment information, such as credit card or other banking information, to bill and collect payment;
• Credit information of business customers, such as a credit score, to respond to business customer requests for a waiver or reduction of a security deposit, and to help us manage our risk. We do not collect this information about residential customers;
• Medical device power requirements, such as type of device, its power needs, and whether it is critical to health. We collect this information when individuals submit a form for our Life Support Notification Program, which helps us prioritize critical power-dependent medical equipment during an outage and inform participants of planned outages;
• Geolocation, if an individual uses our app to report an outage;
• Image may be captured by security cameras in our offices or other facilities.

Information collected from others:

In some cases, we also collect information about individuals from other sources, including where the individual provides authorization to do so, or where we are authorized by law to do so. These sources include:

• Energy retailers may provide us with the types of information listed above if the customer contracted with them to receive energy services;
• Credit bureaus and other utilities provide us with credit-related information about business customers to help us determine eligibility for a waiver or reduction of a security deposit;
• The City of Toronto, including the Mayor’s Office and city councillors, may provide us with information when they refer requests and concerns to us;
• Doctors or other healthcare providers, if the individual authorizes them to provide us with information in connection with medical device power requirements;
• Public websites, databases and other sources, to gather data to support internal initiatives or joint programs with third-party partners, such as information about municipal properties from publicly available property listings;
• In addition, if an individual applies for a job with us, we may perform background, reference and criminal record checks as part of assessing and processing the application.

Other uses of information we collect:

In addition, we may collect or use the types of information listed above to:

• Authenticate identity;
• Respond to service issues;
• Provide individuals with information about power outages in their area and allow them to report outages;
• Enable individuals to communicate with Toronto Hydro regarding the installation and discontinuance of their services;
• Prepare and maintain internal files, such as customer service and payment records;
• Perform analytics, with the goals of improving how Toronto Hydro operates and sharing statistical information regarding the electricity industry, rates and energy conservation;
• Help develop, deliver, and review climate change, conservation and demand management programs by Toronto Hydro, its contractors or partners (such as municipal, provincial or federal governments);
• Minimize, investigate and/or report potentially dangerous use of electricity, error, fraud, theft of power, or other breach of law or contract;
• Collect overdue payments;
• Protect us, our employees, our interests, and our property, including in security and legal matters;
• Meet our legal and regulatory obligations as they relate to the operation of Toronto Hydro and the electricity market.

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

2. Sharing Personal Information

We may transfer or disclose personal information to third parties for four main reasons:

1. Operating Toronto Hydro
2. Doing our part in the electricity sector
3. Protecting our legal interests
4. Protecting individuals

I. Operating Toronto Hydro

We transfer and disclose personal information as part of operating Toronto Hydro and its electricity distribution system.

Service providers. We use service providers to help us operate Toronto Hydro. For example, we rely on service providers to provide electricity, process payments and collect overdue payments, translate communications and maintain meters. If our service providers handle personal information, we require them to protect it through contractual requirements and other means.

Managing financial risk. To help us and the utility sector manage risk, we exchange information about business customers with credit bureaus and other utility providers to update credit information.

Other authorized parties. Depending on the situation, we may share information with others that are authorized to access information about the customer’s account. This could be a second person listed on the account, or someone with the legal authority to review the account on their behalf (such as a guardian or power of attorney). The information we provide them depends on the scope of authorization.

Working with partners. We also work with partners to ensure that requests and concerns regarding electricity services are addressed. For example:

• If an individual has contracted with an electricity retailer, we may exchange information with them in order for the customer to receive the services contracted for.
• If a city councillor or the Mayor’s Office refers a question, request or concern to us, we may inform them of the outcome.

II. Doing our part in the electricity sector

We exchange information with different parties within the electricity sector to help ensure the system runs smoothly, that customers receive the services they request, support socially beneficial initiatives, and to meet legal obligations.

Because of the structure of the electricity sector in Ontario, it may be necessary to share billing and consumption information with third party billing and settlement agencies, such as where the customer has 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 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.

We may also share consumption information with trusted third-party partners for the purposes of joint programs and initiatives involving the electricity sector, including climate change, conservation and demand management programs. Where required by law, individuals will be asked to consent to this information sharing.

III. Protecting our legal interests

We may disclose personal information in order to meet legal obligations, protect Toronto Hydro, or as part of a potential business transaction.

Meeting legal requirements. We may be required to disclose personal information to meet legal obligations, such as in response to a valid regulatory or law enforcement request, warrant or legal demand or request.

Protecting Toronto Hydro. We may disclose personal information to protect Toronto Hydro, our employees, our interests, and our property. This includes:

• As part of an investigation into a breach of law or contract;
• Protecting individuals and us against fraud, error or malicious activity;
• As part of a legal dispute;
• In response to an emergency that appears to create imminent danger to an individual.

Business transactions. In the course of a business transaction, such as a proposed sale of Toronto Hydro or its assets (or a part thereof), or a merger or amalgamation of Toronto Hydro with another entity, we may disclose (with appropriate safeguards) personal information to third parties as necessary for the purposes of such transaction.

IV. Protecting individuals

If an individual is part of the Life Support Notification Program, Toronto Hydro may, with prior consent, disclose personal information to relevant agencies, such as police and fire departments and community care access centers, to assist the individual in an emergency situation.

3. Individual Consent

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

Consent may be provided orally, in writing, electronically, implied, or otherwise. For example, by accepting distribution and related services from us, individual consent to the collection, use, and disclosure of personal information for the purposes of providing such distribution and related services is implied.

Consent may be obtained directly from individuals or from a third party that has obtained the individual’s consent to disclose the individual’s personal information to Toronto Hydro. For example, if you sign a separate contract with a retailer, Toronto Hydro may obtain personal information from the retailer and Toronto Hydro may provide 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, individuals can refuse or withdraw consent to the collection, use or disclosure of personal information at any time. However, refusal to provide such consent, or withdrawal of such consent, may prevent us from providing certain products or services for which information is necessary.

In certain circumstances, Toronto Hydro may have a duty or right to collect, use or disclose personal information without knowledge or consent.

4. Our Practices

This section describes our general practices when we are handling personal information.

Toronto Hydro will use and disclose personal information as reasonable and necessary for the purposes outlined above or as otherwise consented to by the individual, 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.

Retention

Retention Toronto Hydro will retain personal information only for so long as is reasonably necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations.

International transfers

Sometimes the parties that we transfer personal information to (such as service providers) may be located outside of Ontario or Canada. Just like in Canada, personal information might be accessed by law enforcement according to the laws in those jurisdictions. We use contractual or other measures to provide a comparable level of protection of this information while the information is being processed by these third parties.

No sale

Toronto Hydro will not trade, rent or sell personal information.

5. 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 individuals to disclose all material information to us and to inform us of any errors or changes in such information.

6. Safeguards and Employee Training

Toronto Hydro has privacy and security standards, guidelines and procedures to support this Privacy Policy and improve the protection of personal information. 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 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. However, it is also important for individuals to take precautions to protect personal information such as keeping usernames and passwords confidential.

Personal information submitted through Toronto Hydro’s website will be encrypted to help protect it. However, it is still possible that personal information could be intercepted over the internet, including by website submission or email. Toronto Hydro is not responsible for the interception, collection, use or alteration of information transmitted over the internet.

All Toronto Hydro employees will be required to comply with this Privacy Policy, review this Privacy Policy annually and receive mandatory privacy training.

7. Cookies and Website Privacy

As is the case with websites generally, when visitors access our website, the site software automatically collects the internet protocol (IP) address of the computer through which the user is connected to the internet. Our 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 accessing our website, and the pages accessed while on our site. This information is aggregated with that of other visitors to help us understand how the site is being used and how to make it better.

When a visitor accesses the Toronto Hydro website, a cookie is automatically placed on the visitor's computer. A cookie is a small text file that contains a unique identification number, which can be used to identify the user's browser. We use cookies to provide certain features on our website. Users are free to block cookies through their browser's options. If a user chooses to block or disable cookies, they may not be able to access some features and services on our website.

We also collect and use 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 individuals visit on our website through the use of tracking numbers passed through URLs 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.

8. Questions, Requests and Concerns

We are always happy to respond to questions, requests or concerns about privacy or this Policy.

Requests

Requesting access to personal information. Individuals can request information regarding the type, use and disclosure of personal information. They can also request access to an index of our personal information banks, which provides information about each personal information bank we maintain, such as the types of personal information stored and how the information is used, the legal authority for doing so, and the groups of people whose information may be stored there.

Correcting and updating personal information. Individuals can request that their personal information be updated or corrected for purposes of accuracy and completeness. Where a disagreement regarding the accuracy of personal information cannot be resolved, we will annotate the information to reflect the disagreement.

We may require individuals to submit access or correction requests in writing. We will require individuals to provide information to confirm their identity before we provide a response.

Individuals can make an access or correction request using the information under “Contact us” below, or by contacting Customer Care at 416-542-8000. They can also use the information under “Contact us” below to request access to an index of our personal information banks. We may also charge a fee for responding to such requests, and, if so, will advise the individual in advance of such costs.

Concerns

Our Chief Privacy Officer is responsible for investigating all concerns regarding the handling of personal information. Any privacy-related concerns should be submitted in writing to Toronto Hydro's Chief Privacy Officer using the following information:

To the extent possible, the investigation will be conducted in a timely manner. After the investigation is completed, individuals will be advised of the outcome, and a resolution will be implemented, if appropriate, as soon as practicable. 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 an individual’s satisfaction, they may contact the Information and Privacy Commissioner of Ontario.

9. Contact Us

The Chief Privacy Officer may be contacted as follows for additional information on Toronto Hydro’s collection and use of personal information:

10. Updates to This Privacy Policy

This Privacy Policy is effective as of the Effective Date set forth at the beginning of this Privacy Policy. We will regularly review this Privacy Policy and we may make revisions to it on occasion.