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Policy on Privacy and Confidentiality  

I.          Objective

 To establish fair information principles for HILCO Cooperative in carrying out its responsibility to respect the privacy and confidentiality of member information. 

II.          Policy

             A. Notice

 1.      HILCO Electric Cooperative discloses to its members its policies and practices for the collection, maintenance, use, and disclosure of identifiable information about its members.

2.      HILCO Electric Cooperative collects and maintains appropriate information about its members as a routine part of its operations. 

3.      When providing electricity and related services, HILCO Electric Cooperative collects information from members, including name, address, telephone number, Social Security number, credit information, and payment and usage history.  Usage history may include information on a member’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, etc.).

4.      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.

5.      HILCO Electric Cooperative may survey a sample of its members to collect information to identify needs or improve service. 

6.      Other activities by HILCO Electric Cooperative or its affiliates, either now or in the future, will result in the collection of additional information about a member’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 HILCO Electric Cooperative’s privacy and confidentiality policies.  The policy is not a formal limitation on the ability of HILCO Electric Cooperative to use, manage, and disclose its records as HILCO Electric Cooperative determines to be necessary, appropriate, or as required by law.  It is subject to change without notice.

            B. Trust

1.      General Practices:  HILCO Electric Cooperative maintains information about members for purposes that are suitable to its operations and management.  Information is collected only through lawful and fair means and for appropriate purposes.  HILCO Electric Cooperative is committed to maintaining accurate, complete, timely, relevant, and appropriate information about members as necessary for the purpose for which the information is to be used.

2.      Access and Correction:  HILCO Electric Cooperative generally permits its members to access and seek correction of records about themselves that are used by HILCO Electric Cooperative to provide service, for billing, and to manage capital accounts.  Any person who wants to identify personal records maintained by HILCO Electric Cooperative, access the records, or correct the records should contact HILCO Electric Cooperative.

C. Security

1.      HILCO Electric Cooperative maintains member 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.  HILCO Electric Cooperative provides reasonable and appropriate security to protect against foreseeable hazards.

2.      HILCO Electric Cooperative requires its employees and, when practicable and appropriate, its affiliates and contractors who have access to identifiable member information to 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.

             D. Use and Disclosure

1.      HILCO Electric Cooperative uses and discloses identifiable information about members in defined and responsible ways in order to carry out its operations.  This section describes how identifiable information about members may be used and disclosed.

2.      Records may be disclosed to affiliates or contractors hired by HILCO Electric Cooperative to assist in carrying out operations, such as service, billing, and management functions including legal, audit, and collection services. 

3.      Member-consumer information may be disclosed to and shared with commercial and consumer credit reporting agencies for credit-related activities (e.g., the reporting of bad debts). 

4.      Members may access information about their specific accounts, minutes from past Board of Director meetings, minutes from past Annual Meetings, or other records pertaining to the Cooperative that are not specific in nature to another member’s personal information by making an appointment for no more than four members in each meeting with the General Manager/CEO and viewing the documents in the presence of the General Manager/CEO or a delegate of the General Manager/CEO.  Information from documents may be hand-copied, but photographic images or copies are not allowed.  When Cooperative staff assistance is required to interpret the data, the requesting member will be responsible for reimbursing the Cooperative for the employee(s) time.

5.      Records may be disclosed to government regulators and other government agencies when authorized or required by law. 

6.      Records may also be compiled in aggregate form for the HILCO Electric Cooperative management

7.      Records may be disclosed when required by law, such as in response to a search warrant, subpoena, or court order.  HILCO Electric Cooperative 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 HILCO Electric Cooperative’s legal rights or during emergencies if physical safety is believed to be at risk.  These events are unlikely, but they are possible.  HILCO Electric Cooperative will take reasonable steps to limit the scope and consequences of any of these disclosures.

8.      Records may be shared with other utilities under shared service agreements or to meet operational requirements.

9.      Records about a member may be disclosed at the request of or with the permission of the member.

10. In addition, member information may be shared with affiliates and partners of HILCO Electric Cooperative that offer products and services to members.

 11. HILCO Electric Cooperative does not sell, rent, loan, exchange, or otherwise release mailing lists or telephone lists of members.  HILCO Electric Cooperative does not disclose any information about a member to nonaffiliated third parties without the prior, written consent of the member. 

 12. Requests for information about members must be in writing disclosing a proper purpose for which the information that will benefit the cooperative and its members.  Any information disclosed must be used only for the stated purpose.  Information will not be released in violation of this policy.

 13. A member requesting information must provide identification, appear in person to the general manager for receipt of the literature, and pay all costs of labor and materials for provision of the information.

 14. 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.  Disclosures of membership lists will only be made following a specific policy adopted by the Board of the membership, and further uses of any lists so disclosed will be subject to that policy, and for no other purpose.

 15. Any person or entity receiving any information from the Cooperative shall be required to verify that the information will not be used for any purpose other than the proper purpose for which it was released, and the information will not be sold, loaned, exchanged or otherwise released or used.

 16. HILCO Electric Cooperative does not sell, rent, loan, exchange or otherwise release mailing lists or telephone lists of member-consumers.  HILCO Electric Cooperative does not disclose any information about a member-consumer to nonaffiliated third parties without the prior, written consent of the member-consumer.

 17. The members of the Cooperative have the right to vote to authorize other uses and disclosures of information.

 18. Member-consumers may request that their information not be shared with affiliates for the offering of new products and services by informing the cooperative and having those instructions on its member records by notification of:

 19. Employees and directors may respond to communications from members without violating this policy.

             E. Questions and Disputes

 1.      This policy is maintained and supervised by

Questions about the policy may be directed to the main office.  Any disputes over access, correction, or other matters may also be directed to that office.  HILCO Electric Cooperative will do its best to resolve any questions or problems that arise regarding the use of member-consumers information.

III.         Responsibility

A.     The board shall ensure that this policy reflects current practices for personal information about members.

B.     The General Manager/CEO is responsible for the administration of this policy.

APPROVED BY THE BOARD OF DIRECTORS 

Steve Sawyer, President 

DATE ADOPTED:  June 20, 2000 

DATE REVISED:      February 22, 2007     

DATE REVISED:      March 29, 2007 

DATE REVISED:      September 27, 2007