Under what authority is the OPA permitted to collect information and what privacy rules does it comply with?
OPA is a not-for-profit corporation established under the Ontario Electricity Act. The Act gives OPA the authority to collect personal information about you and your energy-related activities. OPA complies with the privacy protection rules contained in Ontario’s Freedom of Information and Protection of Personal Information Act (“FIPPA”) and is guided by the Principles set out in the Canadian Standards Association’s Model Code for the Protection of Personal Information.
What types of information does the OPA collect and use about me and how does the OPA use the information?
When you apply for a rebate under the Cool Savings Rebate program, we collect, use and may disclose information about you. This is done to administer your rebate and to assist in our goals of encouraging energy conservation and planning electricity needs in Ontario. We may also use information about you to communicate with you about our programs and services.
The following are the main types of information we collect and our main uses of that information. We may from time to time collect other personal information or use the information that we hold for other purposes. If we do so, we will notify you and, as appropriate, obtain your consent.
Participation in the Program. When you participate in the Cool Savings Rebate program, you are required to give us certain information such as contact information and product information so that we may process your application for rebate and administer the program.
Evaluation, Measurement, Verification and Research. OPA uses personal information obtained from you or from third parties (such as local electricity distributors, contractors and technicians) to enable it to evaluate the Cool Savings Rebate program and to measure the results of the program. It may also collect personal information through its market research initiatives, including information about consumer attributes and preferences. OPA uses this information to assess its own programs and to produce reports. Personally identifiable information collected in connection with these activities is not shared with any third parties except as noted in this Policy.
Customer Service. If you contact one of our customer service representatives or call centres, we will ask you for information such as your name, address and electricity distributor account number so that we can respond to your questions. We will retain this information in order to better assist you the next time you contact us.
Local Electricity Distributors. Your local electricity distributor also collects and maintains certain of your personal information, including contact information, electricity consumption and historical usage. Under the Cool Savings Rebate program, the OPA may be required to obtain this information from your local electricity distributor for the purposes of furthering its goals of energy conservation and planning.
Website. We collect information on our website using transient cookies, sometimes called session cookies. A transient cookie is a small file that contains information about a user, and disappears when the user's browser is closed. Unlike a persistent cookie, a transient cookie is not stored on the user’s hard drive; it is stored only in temporary memory that is erased when the web browser is closed. We use transient cookies to determine, for example, how you use our website so we can improve the design of our site. Transient cookies are not linked to any personally identifiable information about you. Cookies can be disabled in your web browser.
Communicating with you. We may use your personal information to contact you about our current and future programs, including evaluation, measurement, notification and market research. We may also use your information to assess your future needs and to contact you respecting services, programs and products that may be of interest to you.
Other uses of information. In addition, we may use your information for audit and archival purposes, for security purposes, and otherwise as may be permitted or required by law.
How does the OPA tell me why it needs my information?
When we collect your personal information from you, we will tell you why we are asking for it. When you apply for a COOL SAVINGS rebate, your implicit consent to the collection of personal information will be understood because you provided us with the requested information. If we intend to use or disclose any of your personal information for a purpose other than the purpose for which it was originally obtained, we will notify you and obtain your consent to this new use.
You may notify us at any time that you do not wish us to use your information for any purposes that were not identified when we collected the information or are not required to complete the processing of your COOL SAVINGS rebate by contacting us in any of the ways described at the end of this Policy.
How long does the OPA retain my information?
We retain your information as long as it is required for the purposes identified when you provided the information or for any new purposes identified by us and consented to by you, and for any appropriate time thereafter including a sufficient time following to permit you to ask any questions regarding its use. Certain information is retained for longer periods for our internal audit and quality control purposes
Does the OPA share the information it obtains about me with third parties?
In order to administer your Cool Savings rebate, the OPA has authorized its service providers to collect your information on its behalf and may provide other personal information about you to such organizations. The OPA also may share certain of your personal information with third parties, such as your local energy distribution company or a local technician or contractor in order to administer the program. These service providers and third parties are not authorized by us to use or disclose your information except as necessary to perform services on our behalf or to comply with legal requirements. We also may disclose information about you as required by law, including if required by the Ontario Energy Board or the Ontario Ministry of Energy and Infrastructure.
How does the OPA protect personal information?
We maintain administrative, technical and physical safeguards to protect against unauthorized disclosure, use, alteration and destruction of the personal information in our possession. These safeguards vary depending on the sensitivity and nature of the information and involve physical, organizational and technological security measures as are appropriate. OPA requires all of its service providers who collect or process personal information on its behalf to provide security safeguards equivalent to those maintained by OPA.
Does the OPA website contain links to other websites?
The OPA and Cool Savings Rebate websites may contain links to other websites that operate independently of the OPA and are not under our control. We provide links to other websites solely for your convenience and information. Other websites may have their own privacy policies, which we suggest you review if you visit any linked websites. The OPA is not responsible for information that is provided by, or collected through, those websites or for any other use of those websites.
How can I review and update or correct my personal information?
You may review and revise, correct or update any of the information that we have on file about you at any time and you may also learn how we have used it and to whom we have disclosed it. This right is subject to certain limitations under FIPPA such as when disclosure would reveal someone else’s personal information or when the information is subject to legal privilege. If you wish to review or update your information, you may do so by contacting us using one of the options provided below.
How can I contact the OPA?
If you wish us to update or correct your information, or if you have any questions or concerns about the OPA’s privacy practices or about your personal information, please contact our Privacy Office at:
Attention: Freedom of Information and Protection of Privacy Officer
120 Adelaide Street West, Ste. 1600
Phone: 416- 969-6277
Fax: 416- 969-6383
E-mail: [email protected]
We will respond to your inquiry or investigate your concern as quickly as possible.
If you have any concerns about the OPA’s privacy practices or your personal information that are not resolved by contacting our privacy office, you may contact Ontario Information and Privacy Commissioner at:
Information and Privacy Commissioner/Ontario
2 Bloor Street East
Toll-free: 1-800-387-0073 (within Ontario)
DATED: December 23, 2009