EfficiencyOne will obtain clients’ understanding and informed consent before collecting, using, or disclosing any Personal Information as and when required by PIPEDA. In addition, a customer may withdraw his or her consent at any time upon notifying EfficiencyOne, subject to any legal or contractual obligations of the customer and as provided for in PIPEDA.
2. Purposes of collection, use, and disclosure
2.1 EfficiencyOne will identify the purposes for collecting Personal Information at the time or before the information is collected. EfficiencyOne collects personal information from its clients for the following purposes:
- To recommend products and/or services to clients and potential clients;
- To market or provide energy saving products and services;
- To manage and develop EfficiencyOne’s business and operations;
- To meet legal and regulatory requirements;
- To provide clients and potential clients with information regarding EfficiencyOne’s products and services; and
- To enable the efficient provision of reasonably available, cost-effective energy efficiency and conservation activities to Nova Scotia Power Incorporated.
2.2 EfficiencyOne will only use clients’ Personal Information for the above-stated purposes unless the client consents to another purpose or as is required by law. The types of Personal Information that EfficiencyOne may collect, retain, and disclose may include, but are not limited to, the following:
- Email Address
- Telephone Number
- Date of Birth
- Credit History
- Transaction History
- Home Assessment Information
- Energy Audit Information
- Notice of Assessment (income)
- Proof of Home Ownership
- Utility Account Number and Service Provider
- Demographic Information
- Other Personal Identifiers, such as Household Identification Number
- Other information relating to building/household characteristics such as age of building, size, number of occupants
- Other information relating to energy consumption such as usage, demand, smart meter/sub-meter data
- EfficiencyOne will occasionally collect Personal Information through its website(s). This Personal Information will be collected, used, and disclosed according to the same policies and procedures as any other Personal Information provided to EfficiencyOne.
- EfficiencyOne may disclose Personal Information to third party agents for the purpose of assisting EfficiencyOne in fulfilling the purposes set out in this Policy. EfficiencyOne may also disclose clients’ Personal Information as required by law. EfficiencyOne will not sell clients’ Personal Information to third parties.
EfficiencyOne has a Personal Information and Privacy Program in place that lays out physical and technological security safeguards and procedures in place to protect clients’ Personal Information from unauthorized access, disclosure, use, or modification. These safeguards include, for example: privacy training for employees, physical access controls to our premises, and standards and procedures for storing and safeguarding paper and electronic Personal Information. Additionally, EfficiencyOne has Information Technology policies, procedures and logical controls in place to ensure the EfficiencyOne information technology environment maintains Personal Information in safe and secure manner. EfficiencyOne audits its procedures and security measures regularly to ensure that they are appropriate and that all Personal Information is protected.
EfficiencyOne acknowledges that it is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. The organization shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
EfficiencyOne will ensure that client Personal Information is accurate and updated, when necessary. EfficiencyOne relies on its clients to inform of any changes to Personal Information.
6. Access and correction
Clients may access their Personal Information, subject to the exceptions listed in PIPEDA, or request a correction of Personal Information. The request must be made in writing and contain sufficient detail to enable EfficiencyOne to identify the client’s Personal Information to either provide the information or to make the correction(s). A minimal fee may be charged for providing access to Personal Information; however, the client will be informed of any applicable fee(s) when the request is received. In most cases, a response will be provided within 30 business days, however, if a longer time is needed, EfficiencyOne will provide the client with written notice stating the reasons for the extension.
7. Retention and destruction
EfficiencyOne will retain Personal Information provided by clients no longer than is necessary for legal or business purposes. When this Personal Information is no longer required, it shall be destroyed, erased, or made anonymous pursuant to the requirements of PIPEDA.
8. Breaches of security safeguards
In the event a breach of EfficiencyOne’s security safeguards involving Personal Information creates a real risk of significant harm to an individual, EfficiencyOne will provide a report to the Privacy Commissioner and will notify the individual(s) involved (unless otherwise prohibited by law) as soon as feasible after EfficiencyOne determines that the breach has occurred. EfficiencyOne will also maintain internal records of every breach of its security safeguards involving Personal Information.
Questions about the Personal Information in EfficiencyOne’s custody or requests to withdraw consent for the collection of Personal Information should be directed to EfficiencyOne’s Privacy Officer by email to firstname.lastname@example.org, or by mail to: 230 Brownlow Avenue, Suite 300, Dartmouth, Nova Scotia, B3B 0G5.
This policy will be amended from time to time as EfficiencyOne regularly reviews and updates its policies and procedures.