Privacy Policy

Updated November 16, 2020

INTRODUCTION

Respecting and protecting the privacy and confidentiality of member Personal Information is essential to CED Co-op. This Privacy Policy was established to ensure a high standard of privacy and protection of Personal Information in fulfilment of the obligations outlined in the Ontario Freedom of Information and Protection of Privacy Act and the federal Personal Information Protection and Electronic Documents Act. Our Privacy Policy ensures that CED Co-op respects the sensitivity of Personal Information of its members, outlining the security processes and procedures we have put in place for their protection. This document is available to all our members upon request for review.

DEFINITIONS

The following lists some terms used within this document along with their associated meaning.

• • References to “CED Co-op”, “we”, “us” and “our” mean Community Energy Development Co-operative Ltd.
  • The words “member” and “membership” refer to the members of CED Co-op as defined in the Ontario Co-operative Corporations Act.
  • CED Co-op may choose to engage other individuals or companies to assist CED Co-op with member management and related services. These other parties are referred to as “External Service Providers”.
  • “Personal Information” means any information about an identifiable individual, including, but not limited to:
    • Age, name, mailing and permanent address, e-mail and telephone numbers
    • Social insurance numbers, banking information and date of birth
    • Opinions, evaluations, and comments

KEY PRINCIPLES

CED Co-op’s Privacy Policy is based on the 10 key principles of privacy from the Personal Information Protection and Electronic Documents Act. The 10 principles are listed here below with accompanying commentary.

1. 1. Accountability  An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.

1. 2. Identifying Purposes  The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

1. 3. Consent  The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

1. 4. Limiting Collection  The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

1. 5. Limiting Use, Disclosure, and Retention  Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

1. 6. Accuracy  Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

1. 7. Safeguards  Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

1. 8. Openness  An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

1. 9. Individual Access  Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

1. 10. Challenging Compliance. An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.

 

IMPLEMENTATION OF PRINCIPLES

1. Accountability  CED Co-op has, at any time, a Privacy Officer who is ultimately responsible for compliance with this Privacy Policy. CED Co-op allows only its directors and authorized representatives of External Service Providers to collect, manage and use Personal Information collected from members as outlined in this Privacy Policy. These directors and representatives engage with Personal Information in order to satisfy responsibilities associated with providing member management and administrative services. Each individual authorized by CED Co-op to access Personal Information is responsible for the Personal Information under their possession and custody, including any information handed out by them to a third-party.

2. Identifying Purposes  CED Co-op will explain to members how we intend to use member Personal Information before or at the time we collect it. CED Co-op will only collect member Personal Information that is relevant to these explained purposes. If CED Co-op wishes to use Personal Information for new purposes not outlined before or at the time of collection, CED Co-op will obtain permission from members for these new uses.

CED Co-op collects member Personal Information on behalf of the members for the following purposes:

• • • For CED Co-op to establish and maintain commercial relations with the member (e.g. to payout bond interest and share dividends);
    • To manage and develop CED Co-op’s business and operations; and
    • To help CED Co-op meet legal and regulatory requirements.

3. Consent

CED Co-op will not use, collect or distribute to a Third Party any Personal Information without prior consent from the member unless required to do so by law or the information could aid in a life-threatening emergency. CED Co-op will use reasonable efforts to advise members on how their Personal Information will be used when asking for consent.

Consent may be expressed in writing or in some cases, verbally, electronically or through an authorized proxy. Consent may also be implied depending on the surrounding circumstances.

CED Co-op will not require members to consent to the use, collection or disclosure of Personal Information beyond the specific purposes in order to use our services. Members may withdraw consent at any time, subject to legal or contractual restrictions and obligations. We will explain the consequences of withdrawal of consent if it will affect our ability to provide service to the co-operative and its members.

4. Limiting Collection

CED Co-op will only collect member Personal Information needed to provide its member management services to the member. This type of information usually includes:

• • Name
  • Mailing and Permanent Address
  • E-mail Address
  • Telephone number (home, business, mobile, etc.)
  • Social Insurance Number
  • Date of Birth
  • Banking information (for purposes of membership fee, purchase of debentures, payment of investment proceeds);
  • Property ownership status (for Independent Electricity System Operator (previously known as “Ontario Power Authority”) community power requirements)
  • Personal Information may be collected from members, with their consent, in person, by mail, in office, over the telephone or digital correspondence.

 

5. Limiting Use, Disclosure and Retention

 

• • Within CED Co-op  Member Personal Information will be collected, used and disclosed internally within CED Co-op as well as by and among individuals affiliated with External Service Providers in order to perform their job and duties in providing member management services to the co-operative to which the member belongs. Use of Personal Information is limited to the purposes to which the member has given consent, except for circumstances required by law.
  • Third Party  There are circumstances that present unavoidable types of disclosure of member Personal Information as part of CED Co-op fulfilling its routine or regulatory obligations. In these circumstances, we provide third parties with only Personal Information that is required. We will ensure that these third parties are made aware of and comply with CED Co-op’s Privacy Policy and CED Co-op will subject third parties to strict confidentiality provisions. Third parties may include:
    • Canada Revenue Agency for tax purposes;
    • Independent Electricity System Operator (previously known as “Ontario Power Authority”) for community power status audits.
  • Selling Personal Information  CED Co-op will note trade or sell your Personal Information to third parties or others.

6. Accuracy

CED Co-op will ensure within reason that Personal Information shall be as accurate, complete and recent as is necessary to provide Member management services to its members. While we do our best to update information from various sources, CED Co-op relies on member disclosure of changes in their Personal Information. We urge members to contact CED Co-op immediately when their Personal Information is to be updated and provide evidence that contains details of this change.

7. Safeguards: Protecting Personal Information

CED Co-op protects member Personal Information by using physical, organization and digital safeguards appropriate to the sensitivity of information. This helps protect Personal Information against unauthorized access, disclosure, copying, modification or use. The level of security varies depending on the sensitivity of the information. CED Co-op reviews its processes periodically to ensure they are properly administered and remain effective. CED Co-op protects all members Personal Information with the methods below:

Physical  Printed and electronic sources containing Personal Information will be secured in locked cabinets and premises with restricted access.

Organizational  Access to member personal information is restricted to those individuals that need to have access in order to perform the member management services for which they are responsible.

Digital and Technical  Electronic access to Personal Information will be restricted through use of individual secure login with designated access permissions according the individual’s roles and responsibilities.

8. Openness

This Policy Policy is written in plain language to be easily understood by all. It is available in paper copy upon request.

9. Individual Access

CED Co-op will provide a member access to the Personal Information relevant to the inquiring member within a reasonable time, conditional on the member providing written request and satisfactory proof of identification. Members also have to the right to know how CED Co-op uses their Personal Information. CED Co-op may charge a nominal fee in response to any request; however the member will be notified of the fee in advance.

If we decline a member’s request for access to Personal Information, the member will be provided a reason in writing by CED Co-op. Typically, Personal Information is not provided if providing access would reveal Personal Information of a third party or if the Personal Information cannot be disclosed for legal, security or proprietary reasons.

10. Challenging Compliance

If a member of the co-operative has a challenge or concern regarding CED Co-op’s compliance with the Privacy Policy, the member should send their challenge or concern to the Privacy Officer at the location below. The Privacy Officer will respond to challenges and concerns and work with the member to find an acceptable solution.

Community Energy Development Co-operative Ltd.
Attention: Privacy Officer
3-5 Forwell Rd.
Kitchener, ON N2B 1W3

Telephone: 519-279-4045

Email: privacy@cedco-op.com