Board of Directors

PREAMBLE
Brantford Power Inc. is committed to keeping the personal information of its customers accurate, confidential, secure and private. Our privacy policy has been designed to inform employees, customers, contractors and subcontractors of Brantford Power Inc. of our commitment to and recognition of our obligation to meet he spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

SCOPE OF POLICY
Our Privacy Policy describes the principles by which Brantford Power Inc. protects the privacy of personal information in its possession. It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines customersí rights with respect to this information.

Our privacy policy incorporates and expands the 10 principles for the protection of personal information as devised by the Canadian Standards Association [CSA].

The Privacy Policy does not apply to information about business customers that carry on business as corporations, partnerships or other forms of business association. Brantford Power Inc. does, however, protect the confidentiality of such information in accordance with the law and regulatory codes.

PERSONAL INFORMATION PROTECTION PRINCIPLES

Accountability
Brantford Power Inc. is accountable for the protection of all personal information within the organizationís possession or control, including information that has been transferred to a third party for regulatory, legal or processing reasons. Brantford Power Inc. will require a comparable level of protection of this information from its third party relations. The Board Secretary has overall responsibility for protection of personal information and Brantford Power Inc.ís compliance with this privacy policy.
Identifying Purposes
Personal information that Brantford Power Inc. collects from customers includes:
- Customer name and address and other contact information such as telephone number, e-mail address
- Meter number
- Facts about consumption of power, both historic and current
- Information about a customerís transactions such as account numbers, account balances, payment history
- Credit and reference information including but not limited to date of birth, employment information, drivers licence, previous addresses and general financial information
- Medical information to be used in case of emergency power outages
- Bank information for pre-authorized payments.
When an individual arranges for service, Brantford Power Inc. will make the individual aware of the purposes for which Brantford Power Inc. is requesting personal information. If Brantford Power Inc. identifies other purposes for which the personal information may be used, Brantford Power Inc. will seek the individualís consent prior to such use. Brantford Power Inc. will advise that it is the individualís right to refuse permission for Brantford Power inc. to use personal information for any new purposes.

Additional purposes for collecting personal information may be identified to an individual before or at the time of collection. However, at a minimum, Brantford Power Inc. will collect personal information for the following purposes:
- Billing and collection of payments for electric service
- Pre-authorized payment for services
- Priority restoration of electric service to the correct address and meter, required by medical circumstances
- Energy sector legal, regulatory and settlement requirements
- Law enforcement.
Consent
Brantford Power Inc. will obtain consent before or when it collects, uses or discloses personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information about them either expressly or implicitly. Brantford Power Inc. will collect, use or disclose personal information without an individualís consent only in limited circumstances as permitted by law. Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time.

All existing customers will be informed of the types of personal information that have been collected, the purpose of the collection and the procedures for contacting Brantford Power Inc. with any inquiries.

All new customers will be requested to provide consent with an accompanying explanation about the collection, use and disclosure of personal information when requesting service.
Limiting Collection
Brantford Power Inc. limits the amount and type of personal information that it collects to that which is necessary for the business of the utility. Information will be collected only in fair, transparent and lawful ways.
Limiting Use, Disclosure and Retention
Brantford Power Inc. will only use the personal information for the purpose for which it was collected as identified in principle #2, unless consent is given by the individual to use or disclose it for another purpose.

Brantford Power Inc. has developed explicit retention periods for closed accounts with zero balances, after which the personal information will be destroyed or made anonymous.

Under certain exceptional circumstances, Brantford Power Inc. may have a legal duty or right to disclose personal information without the individualís knowledge or consent.
Accuracy
In order to ensure the reliable delivery of electric service and the correct billing for such service, all personal information should be accurate, complete and up to date.

Individuals may challenge the accuracy and completeness of personal information about them and have it amended as appropriate.
Safeguards
In executing its responsibilities with respect to the confidentiality of personal information, Brantford Power Inc. will employ safeguards appropriate to the sensitivity of the information, to protect the information against loss, left, unauthorized access, disclosure, copying, use or modification. Such modifications will include physical measures, organizational measures and technological measures. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.
Openness
Brantford Power Inc. will make its policies and practices relating to the protection of personal information available to its customers. Brantford Power Inc. will keep its customers informed of these policies and practices via its web page at brantfordpower.com and bill inserts. The information will be available in a format that is easy to understand.
Individual Access
Any customer of Brantford Power Inc. can have access to personal information about them that Brantford Power Inc. has in its possession or control. Any customer may request that their personal information be amended for purposes of accuracy and completeness.

Customers can make their requests by telephone [519 751-3522 Ext. 3269], via e-mail [hwyatt@brantford.ca] or in writing [Brantford Power Inc., 84 Market Street, Box 308, Brantford ON, N3T 5N8, Attín: Board Secretary]
Challenging Compliance
Any customer of Brantford Power Inc. can challenge Brantford Power Inc.ís compliance with this privacy policy by contacting Brantford Power Inc. directly. Brantford Power Inc. has procedures to receive investigate and respond to an individualís complaints and questions.

If the customer is not satisfied with the way Brantford Power Inc. has responded to the complaint, the customer can contact the Privacy Commissioner of Canada.