Effective January 1, 2004; date of last revision January 9, 2009
At Enbridge Gas Distribution, we are committed to providing excellent service and to ensuring that our relationship with you is conducted with integrity and in a responsible, fair, honest and ethical manner. Consistent with these objectives we maintain high standards of confidentiality with respect to the personal information in our possession.
1.0 Collection, Use and Disclosure of Personal Information
1.1 What personal information do we collect?
Personal information is information about you as an individual customer or potential customer and relates specifically to you (such as your name and address). When you first become a customer or whenever you require or renew a service or product from us, we need to collect some of your personal information. However, the personal information that we collect from you is always limited to the purposes that we have identified to you.
1.2 Purposes: Why do we collect personal information?
We ask you to provide us with your personal information for the following purposes:
- to provide you with natural gas and related energy services
- to bill and collect payment for products and services we bill you for
- to meet legal and regulatory requirements relating to the services or products provided to you
- to provide you with information about using energy safely and efficiently, and
- to understand your energy needs and preferences and tell you about energy services or products that may be of interest to you
If we identify a new purpose for the personal information that we have collected from you, we will obtain your consent before using your personal information for the new purpose.
We use the information you submit to us to communicate with you if and when necessary in connection with your use of our Applications, to respond to your questions, or to send you material and information you request. We may use the information to:
- Personalize your user experience.
- Consider your suggestions.
- Respond directly to you for clarification.
- Try to answer your questions if you ask them.
- Provide you with email messages and other information regarding upcoming events, new services and general information about our products and services, if you have opted in for that.
We may use any information we collect to analyze statistical trends, use patterns and demographic data (for example, where our visitors come from and what general demographic characteristics they have), to improve our Applications to better serve our customers, and to develop new products and services."
1.3 Consent: Why do we require your permission?
We collect, use or disclose your personal information only with your consent. Your consent may be express or implied, and you may give it to us in writing, verbally, electronically, or through your authorized representative. When you use our products and services we consider that you have implied your consent for us to collect, use and disclose your personal information for the purposes identified above. You may withdraw your consent at any time, subject to legal and regulatory restrictions and reasonable notice.
We do not provide or sell customer lists to any outside company for marketing, solicitation or any other such purpose. We will not use or disclose your personal information without your consent except in the following circumstances:
- When required by law or law enforcement purposes.
- For an emergency that threatens life, health or security.
- To bill for or collect a debt that you owe us or a third party on whose behalf we provide billing and collection services, or to evaluate your credit worthiness.
- To a third party that we have contracted with to provide you with services on our behalf or to assist us in understanding your energy needs and preferences.
2.0 Protecting Your Personal Information
2.1 Security safeguards and employee awareness
Keeping your personal information confidential and secure is a priority for us. In order to ensure protection of your personal information and right to privacy, we have developed security procedures to safeguard and protect your personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification.
Our employees are trained to maintain the security and confidentiality of your personal information.
2.2 Agents and third party service providers
Enbridge Gas Distribution contracts with agents, contractors and other third parties for services related to gas distribution, such as billing, call centre support, maintenance and repair. From time to time, we may need to share some of your personal information with these third parties further to the purposes identified above and in order to serve your needs. To a limited extent, Enbridge Gas Distribution contracts with foreign service providers for services such as data processing. These third parties may be required to disclose personal information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities.
Any third party that we share your personal information with is contractually bound to keep the information confidential and secure and to refrain from using it in any way other than is necessary to perform the services.
3.0 Your Rights
3.1 Accessing your personal information
You have the right to ask whether we hold any personal information about you and to see that information. We will respond to your request for access within 30 days of the request being made.
You could refuse to allow us to obtain, use or share your personal information or you could also withdraw a previously given consent at any time. However, by doing so, depending on the situation, you may be limiting or even preventing our ability to provide you with the service or product you desire.
3.2 Requesting an update or correction
If you believe that any of your personal information is inaccurate, you may ask us to correct it. We will respond to your request to update or correct your personal information within 30 days of the request being made.
3.3 Registering complaints
In the event of any conflict or other concern regarding access to, or the accuracy or our use of, your personal information, you may register a question or complaint with our Privacy Officer.
4.0 Contact Information and Resources
- By Mail: Enbridge Gas Distribution P.O. Box 650, Scarborough, Ontario, M1K 5E3
- By Email: firstname.lastname@example.org
- By Telephone: see the billing number on the front of your bill.
- By Facsimile: 1–888–711–1211
To find out more about federal privacy laws, including the PIPEDA (the law applicable to Enbridge Gas Distribution), contact the Office of the Privacy Commissioner at 1–800–282–1376 or visit its website at www.privcom.gc.ca.
6.0 Visiting the Enbridge Gas Distribution Website
A visitor to Enbridge Gas Distribution’s website, www.enbridgegas.com, is not required to reveal any personal information, such as name, address, or telephone number. Nor is such information collected passively by electronic means, except as outlined below.
Your personal information is collected when you voluntarily complete an online application, request form, or survey and used in the same manner as any other personal information we collect in the course of providing services to you.
Our website collects visitor information in the form of the visitor’s domain or Internet Protocol (“IP”) address, and information regarding which pages are accessed. This information is used to better serve you by helping us manage and improve the content of our website and to diagnose technical problems.
Enbridge Gas Distribution may store a ‘cookie’ on your computer when you visit the website if needed to help display the web pages. It will not be used to collect any form of personal information.
7.0 Enbridge Gas Distribution’s Commitment to the Ten Privacy Principles
Enbridge Gas Distribution is responsible for personal information under its control and has designated a Privacy Officer who is accountable for Enbridge Gas Distribution’s compliance with the ten privacy principles.
Enbridge Gas Distribution shall identify the purposes for which personal information is collected at or before the time of collection.
The knowledge and consent of a customer are required for the collection, use, or disclosure of personal information, except where inappropriate.
The collection of personal information shall be limited to that which is necessary for the purposes identified by Enbridge Gas Distribution. Personal information shall be collected by fair and lawful means.
Limiting Use, Disclosure and Retention
Enbridge Gas Distribution shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Enbridge Gas Distribution shall retain personal information only for as long as necessary to achieve fulfillment of the identified purposes.
Keeping Personal Information Accurate
Enbridge Gas Distribution shall keep personal information as accurate, complete, and up–to–date as is necessary for the purposes for which it is to be used.
Safeguarding Personal Information
Enbridge Gas Distribution shall protect personal information by security safeguards appropriate to the sensitivity of the information.
Openness Concerning our Privacy Practices
Enbridge Gas Distribution shall ensure that specific information about its policies and practices relating to the management of personal information is made readily available to customers and potential customers.
Enbridge Gas Distribution shall, upon request, inform a customer of the existence, use, and disclosure of his or her personal information and shall give such customer access to that information.
A customer shall be able to address a challenge concerning Enbridge Gas Distribution’s compliance with PIPEDA to Enbridge Gas Distribution’s Privacy Officer.