POLICY BULLETIN NO. 84
To establish policies
and procedures that ensure fair
information principles for Washington Electric Cooperative, Inc. (“WEC”) in
carrying out its responsibility to respect the privacy and
confidentiality of nonpublic member-consumer information obtained
by Washington Electric Cooperative, Inc. (“
A. Notice
1.In compliance with
federal and state laws, WEC is required to provide
notice to shall
inform its member-consumers that
it hasof its privacy and confidentiality
policies relating to the discloses to its
member-consumers its policies and practices for the collection,
maintenance, use, and disclosure of identifiable information about its
member-consumers, shall make a copy of such policies available on
its website, and shall furnish a copy to any member upon request.
2.1.WEC
Electric Cooperative collects and maintains appropriate information about its
member-consumers as a routine part of its operations.
B.
Trust Nature of
Member-Consumer Information Collected by
WEC
1. General
Practices: WEC maintains information
about member-consumers for purposes related to its operations and management. Information is collected only through lawful
means and for appropriate purposes. WEC
is committed to maintaining accurate, complete, timely, relevant, and
appropriate information about member-consumers as necessary for the purpose for
which the information is to be used.
3.When
providing electricity and related services, WEC collects and maintains
information from member-consumers, including name, address, telephone number,
e-mail address, Social Security number, credit information, billing, usage
and payment history, , patronage capital
account information for members and former members, participation
in energy efficiency programs, and
purchase of non-electric products and services,
billing, and usage history. Additional
personal information may pertain to may include information on a
member-consumer’s property and appliances, health information for lifeline
service, service history, and information maintained for meter reading purposes
(e.g., warning about a dog in the yard).
4.1.Membership
and governance activities may result in the maintenance of capital and
patronage account information for members and former members, and contact
information for former members.
2. Occasionally, WEC may
survey a sample of its member-consumers to collect information to identify
needs or improve service. This
information will be collected and maintained only when and to the extent
appropriate to provide services.
5.
6.Other
activities by WEC or its affiliates will result in the collection of additional
information about a member-consumer’s property, appliances, and activities. This information
will be collected and maintained only when and to the extent appropriate to
provide the services.
7.This
notice describes generally WEC’s privacy and confidentiality policies. The policy is not a formal limitation on the
ability of WEC to use, manage, and disclose its records as WEC determines to be
necessary, appropriate, or as required by law.
It is subject to change without notice.
BC.
TrustNature
of Member-Consumer Information Collected by WEC
1.
When providing
electricity and other products and services, WEC collects
and maintains information from member-consumers, including name, address,
telephone number, e-mail address, Social Security number, and
other credit information, billing, usage and payment
history, patronage capital account information for members and former members, participation
in energy efficiency programs, and/or purchase
of products and services other than
electricity. Additional
personal information collected may
pertain to a member-consumer’s property and appliances, health information for emergency
and outage restoration purposes, service history, and
information maintained for meter reading purposes (e.g., warning about a dog in
the yard).
2. Occasionally, WEC may
survey a sample of its member-consumers to collect information to identify
needs or improve service. This
information will be collected and maintained only when necessary
and to the extent appropriate to provide services.
1.General
Practices: WEC maintains information
about member-consumers for purposes that are suitable related to
its operations and management.
Information is collected only through lawful and fair means and for
appropriate purposes. WEC is committed
to maintaining accurate, complete, timely, relevant, and appropriate
information about member-consumers as necessary for the purpose for which the
information is to be used.
2.Access
and Correction: WEC generally permits
its member-consumers to access and seek correction of records about themselves
that are used by WEC to provide service, for billing, and to manage patronage
capital accounts. Any
person who wants to identify personal records maintained by WEC, access the
records, or correct the records should contact: a
WEC Member Service Representative.
[Add
point of contact information for access/correction requests]
CD.
Security
1. WEC maintains
member-consumer information with technical, administrative, and physical
safeguards to protect against loss, unauthorized access, destruction, misuse,
modification, and improper disclosure.
No record or computer system can ever be fully protected against every
possible hazard. , hHowever, . WEC provides reasonable and
appropriate security to protect against foreseeable hazards.
2.1.requires its
employees and, when practicable, requires assurances
from its affiliates and contractors who have access to
identifiable member-consumer information that they and
their employees are aware of WEC’s to
sign a statement acknowledging that they have read this privacy
and confidentiality policy and agreeing to maintain
strong confidentiality protections and limit the use of the information
provided by WEC pursuant to this policy. comply with it. Any employee or contractor who fails to
comply with these rules may be subject to disciplinary action up to and
including dismissal.
DE.
Use
and Disclosure
1.WEC uses and discloses identifiable
information about member-consumers in defined and
responsible ways in the
day-to-day
operation of itsnormal course businessof
business. [in order to carry
out its operations]. This
section describes how identifiable information about member-consumers may be
used and disclosed.
2.1. Records
Information may be used by WEC and/or disclosed
to affiliates or contractors hired by WEC to assist in carrying out operations,
such as maintaining or restoring electric service, right of
way maintenance, service, billing, energy audits and
other efficiency and loan management activities, newsletter and other communications,
and , mailings, and management
functions including legal, audit, and collection services.
3.2. Member-consumer
information may be disclosed to and shared with consumer credit reporting
agencies for credit-related activities (e.g., the reporting of bad debts).
4.3. Records
Information may be disclosed to
government regulators and other government agencies when authorized by
the member or required by law, including requests
for information in response to a search warrant, subpoena, or court order.
5.3.Records
may also be compiled in aggregate form for WEC’s management activities.
6.4. Records
may be disclosed when required by law, such as in response to a search warrant,
subpoena, or court order. WEC may use
and disclose records for investigations into employee misconduct or for law
enforcement investigations related to our
business. Disclosures
may also be made when appropriate to protect WEC’s
legal rights or during emergencies if physical safety is believed to be at
risk. These events are unlikely, but
they are possible. WEC will take
reasonable steps to limit the scope and consequences of any of these
disclosures.
7.5. Records
Information may be shared with other
utilities under shared service agreements or to meet operational
requirements.
8.6. RecordsInformation
about a member-consumer may be disclosed at the request of or with the
permission of the member-consumer, such as a request
for a credit reference. In accordance with WEC’s
Bylaws Article V Section 7 (i), membership lists may
be disclosed to a member of the cooperative for a proper purpose relating to Cooperative
business, such as in connection with Cooperative election activities. Misuse of such information is subject to
legal action.
7.
WEC does not sell,
rent, loan, exchange, or otherwise release mailing lists, email addresses, or
telephone numbers of member-consumers for marketing purposes. However, the Cooperative may undertake a
mailing to its members on behalf of an affiliated entity for the purpose of or
in connection with offering products and services to its member-consumers.
9.In
addition, member-consumer information may be shared with affiliates and
partners of WEC that offer products and services to member-consumers. (This
may not apply today because no such affiliate exists at this time).
8. Access and
Correction: WEC generally permits its
member-consumers to access and seek correction of records about themselves that
are used by WEC to provide service, for billing, and to manage patronage capital
accounts. Any person who wants to
identify personal records maintained by WEC, access the records, or correct the
records should contact a WEC Member Service Representative.
In
accordance with WEC’s Bylaws, Mmembership
lists of the Cooperative may be disclosed to a member of the cooperative for a
proper purpose relating to cooperative business, such as in connection with
Cooperative election activities.
7.
In some instances, lists may be made available
for appropriate uses without disclosing the list to a third party. For example, the Cooperative may undertake a
mailing on behalf of and at the expense of a third party.
11.9. WEC
does not sell, rent, loan, exchange, or otherwise release mailing lists,
email addresses, or telephone listsnumbers
of member-consumers for marketing purposes. However, the Cooperative
may undertake a mailing to its members on behalf of an
affiliated entity for the purpose of offering products and services to
its member-consumers. to non-affiliated entities. WEC does not disclose any information about a
member-consumer to nonaffiliated third parties without the prior, written
consent of the member-consumer.
12.7.Member-consumers
may request that their information not be shared with affiliates for the
offering of new products and services. (This may not be applicable…see number 9 above
nor required by GLB).
[Add
instructions on opt-out procedures]
EF.
Questions
and Disputes
This policy is maintained and
supervised by [office, address, email telephone] may be directed to that officeposition
in writing to Washington
Electric Cooperative, Any disputes over access, correction, or other
matters may also be directed to that positionoffice. WEC will do its best
to resolve any questions or problems that arise regarding the use of
member-consumer information.
BOARD
APPROVAL:
Date Secretary