Preface

North Bay Hydro Distribution Limited (North Bay Hydro) is committed to keeping the personal information of its customers accurate, confidential, secure and private. This Privacy Policy has been designed to inform employees, customers, subcontractors and customers of North Bay Hydro of our commitment and recognition to our obligation to meet the spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Contents

This Privacy Policy describes the principles North Bay Hydro will use to protect 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 the customers’ rights in respect of this information. This Privacy Policy incorporates and expands the 10 principles for the protection of personal information, as devised by the Canadian Standards Association (CSA).

This Privacy Code does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. North Bay Hydro does, however, protect the confidentiality of such information in accordance with the law and our own policies.

Personal Information Protection Principles

1.Accountability

North Bay Hydro is accountable for the protection of all personal information within the organization’s possession or control, including any personal information that has been transferred to a third party for regulatory, legal or processing purposes. North Bay Hydro will require a comparable level of protection of this information from its third party relations.

Our Privacy Officer, has overall responsibility for our protection of personal information and for North Bay Hydro’s compliance with this Privacy Policy.

2.Identifying Purposes

Personal information that North Bay Hydro collects from customers includes: the customer’s name and address and other contact information; facts about consumption of power, both historic and current; facts about payment for electric service, including general financial information; credit and reference information, such as date of birth, employment information, drivers license, previous addresses, telephone numbers, e-mail address, medical information to be used in case of emergency power outages, and bank information requested for pre-authorized payments.

When an individual applies for service, North Bay Hydro will make the individual aware of the purposes for which North Bay Hydro is requesting the personal information. If North Bay Hydro identifies other purposes for which the personal information may be used, North Bay Hydro will seek the individuals consent prior to such use. North Bay Hydro will advise that it is the individual’s right to refuse permission for North Bay Hydro 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 North Bay Hydro 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, as may be required for medical circumstances

• Energy sector legal, regulatory and settlement requirements

3.Consent

North Bay Hydro 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 expressly or implicitly.North Bay Hydro will collect, use or disclose personal information without an individual’s 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 what types of information have been collected, the purpose for the collection and the procedures available for contacting North Bay Hydro with any inquiries.All new customers will be provided with a consent form and an accompanying explanation about the collection, use and disclosure of their personal information when requesting service.

4.Limited Collection

North Bay Hydro limits the amount and type of personal information it collects to that which is necessary for the business of the utility. Each affiliate of North Bay Hydro (such as North Bay Hydro Services Inc.) will be responsible for its own collection, use and disclosure of information.Personal Information will be collected using procedures which are fair, transparent and lawful.

5.Limited Use, Disclosure and Retention

North Bay Hydro 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. North Bay Hydro will not exchange any information among its affiliated companies, except for billing and settlement purposes.

North Bay Hydro will develop explicit retention periods for closed accounts (zero balance), after which the personal information will be destroyed or made anonymous.

Under certain exceptional circumstances, North Bay Hydro may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.

6.Accuracy

In order to ensure the reliable delivery of electric service and the correct billing for such service, all personal information will be kept accurate, complete and up to date.

Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.

7.Safeguards

In executing its responsibilities with respect to the confidentiality of personal information, North Bay Hydro will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, securityclearances and limiting access on a “need to know” basis and use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.

8.Openness

North Bay Hydro will make its policies and practices relating to the protection of personal information available to it customers.North Bay Hydro will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via North Bay Hydro’s web page and bill inserts.The information will be available in a format that is east to understand.

9.Individual Access

Any customer of North Bay Hydro can have access to the personal information about them that North Bay Hydro 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 (705) 474-8100, via email privacyofficer@northbayhydro.com or in writing at PO Box 3240, North Bay, Ontario P1B 8Y5.Response to an individual’s request will be made in a timely and efficient manner.

10.Challenging Compliance

Any customer of North Bay Hydro may challenge North Bay Hydro’s compliance with this Privacy Policy by contacting North Bay Hydro directly.North Bay Hydro has policies and procedures to receive, investigate and respond to individual’s complaints and questions.If the customer is not satisfied with the way North Bay Hydro has responded to a complaint, the customer can contact the Privacy Commissioner of Canada.