Privacy Statement


Privacy at ENWIN - What you need to know


Introduction

In this statement, "ENWIN", "we", "us", or "our" means the ENWIN group of companies ("ENWIN") which includes Windsor Canada Utilities, ENWIN Utilities Ltd., ENWIN Energy Ltd., Windsor Utilities Commission, and any other business unit that may be developed under the ENWIN umbrella, “personal information” means information about an identified or identifiable individual, and "you", and "your" means an individual (not a business) whose personal information is in ENWIN’s custody or control.  The individual might be a customer or prospective customer or a member of the public.

This statement sets out: (i) how ENWIN collects, uses, discloses and protects personal information; and (ii) your rights in relation to your personal information that is in the custody or control of ENWIN.

By accepting service from ENWIN, participating in one of ENWIN’s programs, visiting any website operated by ENWIN, you consent to the use, collection and disclosure of your personal information as described in this statement and ENWIN’s Privacy Policy (each as it may be amended from time to time).


Principles and legislation

ENWIN complies with the Municipal Freedom of Information and Protection of Privacy Act ("MFIPPA").

ENWIN has adopted the principles for the protection of personal information set out Personal Information Protection and Electronic Documents Act ("PIPEDA"), and when applicable, ENWIN complies with PIPEDA.


Privacy objectives

ENWIN is committed to: (i) safeguarding all personal information in ENWIN’s custody or control; (ii) acting in a manner that is respectful of the rights of individuals whose personal information is in ENWIN’s custody or control; and (iii) complying with all applicable laws relating to the protection of personal information.


Why we collect personal information

Providing programs, products and services

In relation to the programs, products and services that ENWIN provides, ENWIN may collect and retain personal information for the following reasons:

  • To respond to inquiries
  • To process requests for services or products
  • To provide ENWIN’s products and services
  • To bill and collect payment for ENWIN’s products and services, and to maintain records of bills and payments
  • To report non-payment of bills to credit bureaus
  • To communicate with you regarding ENWIN’s products or services requested by or provided to you and regarding new products and services
  • To verify your identity
  • To encourage customers to check and, if necessary, update their contact and identifying information held by ENWIN
  • To send customers alerts regarding the products and services provided to them (for example, notification of an outage or high consumptions)
  • To monitor and improve upon the quality of ENWIN’s products and services
  • To seek feedback from ENWIN’s customers on the quality of ENWIN’s products and services
  • To respond to outages, especially when an individual identified as being on life support at the service location
  • To investigate and respond to (including reporting) the misuse of ENWIN’s products or services (for example, theft of power) or the breach of your contract(s) with ENWIN
  • Should you contract with a third party with whom ENWIN has an agreement to bill and collect payment, to bill, collect payment and maintain reasonable records of bills and payments and to provide that information to the third party
  • To provide customers with information regarding conservation or other initiatives related to ENWIN’s products and services, to invite customers to participate in those initiatives and track participation
  • To provide customers with information on events or causes sponsored by ENWIN

Websites

In relation to the websites that ENWIN operates, ENWIN may collect and retain personal information for the following reasons:

  • To operate the websites
  • To provide the services that ENWIN provides through the websites
  • To secure the websites
  • To improve upon the websites
  • To respond to inquiries from visitors to the websites

Generally

In general, ENWIN may use personal information in its custody or control for the following reasons:

  • Should ENWIN pursue the sale or other transfer of its assets, to facilitate that transaction
  • To establish, exercise or defend ENWIN’s legal rights
  • To meet legal and regulatory requirements

New purposes

Should ENWIN wish to use your personal information for another purpose, ENWIN will only do so as permitted by law unless ENWIN has your consent. If that consent was not sought at the time of collection, ENWIN will seek that consent prior to use.


What personal information is collected?

Inquiries

ENWIN may request the following types of personal information from its customers and prospective customers who are individuals when they request the provision of information about ENWIN or its programs, products or services. 

  • Identifying information
    • Name
  • Contact information
    • Mailing address
    • Phone number
    • Email address
    • The nature of the request

Requesting services or financial assistance

ENWIN may request the following types of personal information from its customers and prospective customers who are individuals when they request the provision of a product, service or financial assistance. 

  • Identifying information
    • Name
    • The number from a government issued photo ID to confirm name and identity
    • Responses for one or more security questions
    • If a password or a personal ID number (a “PIN”) has been set up for the affected account, the password or PIN
  • Contact information
    • Mailing address
    • Phone number
    • Email address
  • Service address
  • Financial information
    • Information required to conduct a credit check
    • Information to facilitate pre-authorized payment including a voided cheque, if the customer opts for pre-authorized payment
    • Income (only when a request for financial assistance is made)

Provision services and participation in programs

ENWIN collects the following types of personal information in relation to the programs, products and services that ENWIN provides. 

  • Usage information
  • Billing and payment information
  • Participation in conservation and other programs

Request for support or changes to services

ENWIN may request the following types of personal information from its customers who are individuals when they request support for or changes to the products and services that they receive from ENWIN. 

  • Identifying information
    • Name
    • The number from a government issued photo ID to confirm name and identity
    • Responses for one or more security questions
    • If a password or a personal ID number (a “PIN”) has been set up for the affected account, the password or PIN
  • Contact information
    • Mailing address
    • Phone number
    • Email address
  • Service address

Additionally, ENWIN records of the content of customer support interactions (for example, audio from phone calls and transcripts of online chats). 

Updating identifying and contact information

ENWIN may receive the following types of personal information from its customers who are individuals when they opt to check or update their personal information. 

  • Identifying information
    • Name
    • The number from a government issued photo ID to confirm name and identity
    • New responses for one or more security questions
    • If a password or a personal ID number (a “PIN”) has been set up for the affected account, the password or PIN or a replacement password or PIN
  • Contact information
    • Mailing address
    • Phone number
    • Email address

Website

Browsers:
From the browser used by an individual visiting one of ENWIN’s websites, ENWIN requests the following information:

  • Type of browser and version used by the visitor
  • Type of device used by the visitor to access the website and the device’s operating system
  • The IP address of the device and location from which the website is being accessed
  • The URL of the website from which a visitor was referred to ENWIN’s website
  • The date, time and duration of access. 

From this information, it may be possible for ENWIN to identify the service provider used by the visitor when accessing any website. 

Cookies:
Certain features of ENWIN’s websites rely on cookies. A cookie is data that your web browser automatically stores on your device’s hard drive for future reference. Cookies help make your visit to ENWIN’s webpages simpler, more pleasant, and better structured.   For example, a cookie might be used to identify you as a registered user. Also, cookies are necessary for the operation of certain features on the websites. Visitors to the websites may configure the browser they use to prevent the storage of cookies by ENWIN, but without the use of cookies it may not be possible to use all the functions of the websites.

Google Analytics:
ENWIN uses Google Analytics, a web analysis service provided by Google Inc. ("Google"), to optimise and streamline our websites for our users.  This service requires user profiles to be created and stored on your computer as cookies.  This may include the following information about your use of our website:

  • Browser type and version
  • Operating system used
  • Referrer URL (site previously visited)
  • Host name of the accessing computer (IP address), and
  • Time of server request

This data is transmitted to Google servers that may be located outside of Canada and stored there.  This data is used by ENWIN in combination with analytical tools provided by Google to:

  • Evaluate the use of our websites
  • Compile statistics and reports on website activities
  • For purposes of market research, and
  • To further develop the websites

This data can also be transmitted to third parties by Google to process the data to the extent that is prescribed by law.  IP masking us used to prevent IP addresses from being matched.   

If you choose, you may disable collection by Google Analytics by clicking the following link: https://tools.google.com/dlpage/gaoptout. This will download an opt-out cookie to your hard drive that will prevent any future data collection by Google Analytics as long as it remains on your device.

Links

ENWIN's websites may contain links to third party websites that are not governed by ENWIN's Privacy Policy.  ENWIN has no control over the privacy policies and data security standards of other websites.  Only the hosts of liked websites are liable for the related content and data processing activities.

Transmission

When ENWIN uses one of its websites to provide a customer’s personal information to that customer or to request and receive personal information from an individual, ENWIN has put in place safeguards to protect that information (for example, encryption). However, no data transmission over the internet can be guaranteed to be completely secure. Consequently, ENWIN expressly disclaims all representations, warranties and conditions (whether express or implied) that any information transmitted to or by ENWIN over the Internet will be completely secure.

Smart meters

When smart meters are used, usage information is transmitted over the Internet. ENWIN has put in place safeguards to protect that information (for example, encryption). However, no data transmission over the internet can be guaranteed to be completely secure. Consequently, ENWIN expressly disclaims all representations, warranties and conditions (whether express or implied) that any information transmitted to or by ENWIN over the Internet will be completely secure.

Generation

ENWIN may collect the HST number from any customer who is generating and selling electricity back to ENWIN.


Who sees personal information

ENWIN personnel

ENWIN may share personal information in its custody or control with its personnel who need to use that information in connection with one or more of the purposes for which that personal information was collected. 

Service providers

From time to time, ENWIN may engage service providers to provide certain services such as hosting its websites or processing financial transactions. If the provision of those services requires access to personal information in ENWIN’s custody or control, ENWIN will: (i) limit the personal information made accessible; (ii) use contractual means to require those service providers to (A) safeguard such information, (B) maintain its confidentiality and (C) not to use that information for any purpose other than providing the services for which the service provider was retained; and (iii) employ other safeguards as appropriate.

Required by law

ENWIN may access and/or disclose any personal information which it has collected if required or permitted to do so by law (for example, to comply with a legal requirement including but not limited to one imposed by a warrant, subpoena, court order or like instrument served on ENWIN or in urgent circumstances to protect the life, health or security of any person).

Other third parties

Before disclosing personal information relating to an individual to a third party other than as set out in this Privacy Statement or permitted by law, ENWIN will obtain the affected individual’s consent to the disclosure.


How is personal information protected?

To protect personal information from unauthorized access, loss, theft, use, disclosure, modification, or destruction, ENWIN uses technical, physical and administrative security safeguards.  

In determining what safeguards to use, ENWIN is guided by its Information Technology / Operational Technology (IT/OT) Security Policy, industry best practices, the Ontario Cyber Security Framework and the sensitivity of the personal information.


What happens if there is a privacy breach?

ENWIN will respond to privacy breaches in accordance with the following policies and all applicable laws:

  • ENWIN IT Incident Response Plan
  • IT/OT Security Policy

Consent can be implied or express and can be provided by the individual or an authorized representative. Express consent is preferred and can be given electronically, orally, or in writing.  Implied consent may be reasonably inferred from a person's action or inaction.  For example, providing a phone number to be reached at to receive a response to a question.  ENWIN takes into account the sensitivity of the personal information, the reasonable expectations of the person, and the reasons we are collecting it when determining the appropriate form of consent.  ENWIN will document and ask for consent when using personal information for a new purpose.


Retention and destruction of personal information

ENWIN’s Records and Information Management (RIM) Policy sets out ENWIN’s policies regarding the retention of information including personal information. In relation to records that include personal information, the retention periods reflect ENWIN’s commitment to keep personal information while it is required for the purposes for which it was retained and not any longer unless a longer retention period is required or expressly permitted by law. For example, when personal information has been used to make a decision about a customer, ENWIN is required to retain that personal information for a reasonable period of time after making the decision. The additional time is to allow the customer sufficient time to access and, possibly, correct the information.


Access or corrections to personal information

ENWIN’s customer portal may be used by a customer to make certain changes to its account profile at no additional charge (for example, requesting a new password).

Additionally, an individual whose personal information is held by ENWIN may request access to that information, and subject to applicable law and the payment of a $5.00 fee, ENWIN will provide access when requested. An online process for doing so is set out on ENWIN’s primary website. Click here for more information.

An individual whose personal information is held by ENWIN may request that information be corrected, subject to applicable law. In response to a request for correction and the payment of a $5.00 fee, ENWIN will correct any inaccuracies.  An online process for doing so is set out on ENWIN’s primary website. Click here for more information.

Otherwise, all requests for access or correction should be in writing, addressed to the following address and include a $5.00 fee:

Privacy Officer
ENWIN Utilities Ltd.
787 Ouellette Ave.
Windsor, ON N9A 5T7

Telephone: (519) 255-2727

Email: privacy@enwin.com

No request for access or correction will be processed until the fee is received.


Questions or complaints 

If you have any questions about this statement, ENWIN's Privacy Policy, or about how ENWIN manages personal information, contact ENWIN’s Privacy Officer. If you believe that ENWIN has handled your personal information other than in accordance with its Privacy Policy and this statement, send an email or other written document setting out your concern to ENWIN’s Privacy Officer.

The contact information for ENWIN’s Privacy Officer is:

Privacy Officer
ENWIN Utilities Ltd.
787 Ouellette Ave.
Windsor, ON N9A 5T7

Telephone: (519) 255-2727

Email: privacy@enwin.com


Review

It is ENWIN’s practice to review its Privacy Policy once a year. ENWIN will also review its Privacy Policy when significant changes are made to applicable legislation.


Changes

If there are any changes to this statement or ENWIN’s Privacy Policy, ENWIN will post the changes to its websites at least 30 days in advance of when they become effective. ENWIN may notify its customers of the changes by email sent to the email addresses that are part of their contact information or by mail sent to their billing addresses, but ENWIN is not required to do so.


Related References

The following laws, policies and guidelines should be read along with this document: