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. This Act and the Ontario Energy Board Act give the 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?
We collect, use and may disclose information about you to administer our programs, to assist in our goals of encouraging energy conservation and to plan and provide for electricity needs in Ontario. We may also use information about you to communicate with you about our programs and services.
The following programs and activities describe 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.
Conservation Programs. When you participate in an OPA conservation program, you may be required to give us certain information such as contact information, your local distribution company (“LDC”) and account information, product information and historical energy usage so we may process your application or rebate and administer the program.
Contests. When you enter an OPA contest, you provide us with contact information, such as your name, address, phone number, email address and electricity service account number. We also may ask you to provide us with information such as the name of your LDC, your historical energy usage and other information required to administer the contest. We will use such information to learn about your energy-using activities and needs and, if you choose to receive further communications from the OPA, to provide you with information about our programs.
If you are an applicant to become a supplier under the microFIT Program, the OPA and your LDC will collect information required to complete your application and, if approved, to prepare your microFIT contract. This information includes contact information, information respecting your LDC and particulars of the generating project including capacity and price of power purchased. As settlement agent for you and the OPA, your LDC collects and maintains generation and payment information respecting the electricity purchased under the Program. This generation and payment information is maintained by the LDC and is not provided to the OPA. However, the OPA may audit the LDC’s records containing such information or otherwise request the LDC to provide it with specific generation and payment information respecting your supply of electricity. Except pursuant to such audits or requests, the OPA does not collect generation or payment information relating to individual suppliers. If you are not an applicant but are an LDC customer and have entered into an arrangement with an applicant to supply power from a generation facility located on your property, the OPA will obtain from the applicant or from the LDC your name and LDC account number and the address of your property. The OPA does receive from each LDC aggregate generation and payment information for all suppliers, which does not contain personal information. The OPA and the LDC collect your information for purposes of administering the microFIT Program, including making connection arrangements for the generation facility, purchasing electricity and providing reports to regulatory agencies and other government entities and for other regulatory purposes, or as required by law. Information disclosed to such agencies and entities for such purposes may be provided to the public pursuant to regulatory requirements and in accordance with the provisions of FIPPA.
Evaluation, Measurement, Verification and Research. OPA uses personal information obtained from you or from third parties (such as local electricity distributors) to enable it to evaluate its programs and measure the results of those programs. 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. In connection with your use of electricity, your LDC collects and maintains certain personal information, including your contact information, electricity consumption and historical usage. If you are a supplier under the microFIT Program, your LDC also collects certain personal information for purposes of its role in the Program including contact information, particulars of the generation facility and electricity generation and payment information. The OPA may request your LDC to provide this information to it for the purposes of administering its programs and for audit and regulatory purposes.
Website. On our website, we collect information that may be provided by you in connection with your participation in a program such as your completion of an application form. In addition, 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. If there is personal information that we need to collect from a third party, such as your LCD, in order to run or administer a program, we will make this clear to you when you sign up for that program. 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. Sometimes you will be asked to give your consent expressly (such as by checking a box or clicking on a web page). Other times we may obtain your consent implicitly by asking you to provide information with stated purposes but without any express statement of consent, such as when you apply for a rebate, enter a contest, respond to a survey or apply to participate in a program. In those cases your consent will be understood if you provide us with the requested information.
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 a transaction (such as a rebate) by contacting us in any of the way 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 internal audit, regulatory or quality control purposes.
Does the OPA share the information it obtains about me with third parties?
The OPA may provide certain of your personal information to your LDC, in connection with the administration of its programs. In addition, we may disclose information about you and your participation in its programs for regulatory purposes or otherwise as requested by law, including to other provincial government agencies and other entities such as the Ontario Energy Board and the Ministry of Energy and Infrastructure.
In order to administer our rebates, contests and other energy conservation programs, the OPA may authorize 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 provide certain of your personal information to other third parties, such as a technician or contractor in order to administer a 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.
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 website 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.
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
Toronto, ON M5H 1T1
Fax: 416- 969-6383
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’s Information and Privacy Commissioner at:
Information and Privacy Commissioner/Ontario
2 Bloor Street East
Toll-free: 1-800-387-0073 (within Ontario)
DATED: April 9, 2010