POLICY BULLETIN NO. 84
To establish policies and procedures that ensure
the privacy and confidentiality of nonpublic member-consumer information obtained
by Washington Electric Cooperative, Inc. (“WEC”) in the normal course of
business.
A. Notice
WEC shall inform its member-consumers that it
has privacy and confidentiality policies relating to 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.
B. Trust
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.
C. Nature
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.
D. 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. However, WEC provides
reasonable and appropriate security to protect against foreseeable hazards.
2. WEC 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 privacy
and confidentiality policy and agree to maintain strong confidentiality
protections and limit the use of the information provided by WEC pursuant to
this policy.
E. Use and Disclosure
WEC uses and discloses identifiable information
about member-consumers in the normal course of business. This section describes how identifiable
information about member-consumers may be used and disclosed.
1. 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, billing, energy audits and other efficiency and loan management
activities, newsletter and other communications, and management functions
including legal, audit, and collection services.
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).
3. 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.
4. Disclosures may
also be made 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.
5. Information may
be shared with other utilities under shared service agreements or to meet
operational requirements.
6. Information
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.
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.
F. Questions and Disputes
This
policy is maintained and supervised by WEC’s Manager of Information Systems. Questions about the policy or any disputes
over access, correction, or other matters may be directed to that position in
writing Washington Electric Cooperative, P. O. Box 8, East Montpelier, VT 05651, email [email protected], or telephone
(802) 223-5245.
BOARD APPROVAL: August 31, 2005 Attest,
________________________
Date Secretary