Policy Bulletin No. 4.05
Privacy and Confidentiality of Member-Consumer Information
To establish fair information principles for Noble REMC in carrying out its responsibility to respect the privacy and confidentiality of member-consumer information.
1. Noble REMC discloses to its member-consumers its policies and practices for the collection, maintenance, use, and disclosure of identifiable, private and confidential information about its member-consumers.
2. Noble REMC collects and maintains appropriate and necessary information about its member-consumers as a routine part of its operations.
3. When providing electricity and related services, Noble REMC collects information from member-consumers, including name, address, telephone number, Social Security number, credit information, bank account information, payment and usage history. Usage history may include information on a member-consumer’s property and appliances, health information for lifeline service, service history, and information maintained for meter maintenance purposes.
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. At certain times Noble REMC may survey a sample of its member-consumers for the purpose of collecting information to identify needs or improve service.
6. Other activities of Noble REMC or its affiliates, (which may include security and home improvement services), 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 such services.
7. This notice describes generally Noble REMC’s privacy and confidentiality policies. The policy is not a formal limitation on the ability of Noble REMC to use, manage, and disclose its records as Noble REMC determines to be necessary, appropriate, or as required by law and it is subject to change without notice.
1. General Practices: Noble REMC maintains information about member-consumers for purposes that are suitable to its operations and management. Information is collected only through lawful means and for appropriate purposes. Noble REMC 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: Noble REMC generally permits its member-consumers to access and seek correction of records about themselves that are used by Noble REMC to provide service, for billing, and to manage capital accounts. Any person who wants to identify personal records maintained by Noble REMC, access the records, or correct the records should contact: Noble REMC, 300 Weber Road, Albion, IN 46701
1. Noble REMC 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, Noble REMC provides reasonable and appropriate security to protect against foreseeable hazards.
2. Noble REMC requires its employees, agents and, when practicable, its affiliates and contractors who have access to identifiable member-consumer information to sign a statement acknowledging that they have read this privacy and confidentiality policy and agreeing to comply with it. Any agent, 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. Noble REMC uses and discloses identifiable information about member-consumers in defined and responsible ways (in order to carry out its operations). This section describes how identifiable information about member-consumers may be used and disclosed.
2. Records may be disclosed to agents, affiliates or contractors hired by Noble REMC 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.
4. Records may be disclosed to government regulators and other government agencies when authorized or required by law.
5. Records may also be compiled in aggregate form for Noble REMC management activities.
6. Records may be disclosed when required by law, such as in response to a search warrant, subpoena, or court order. Noble REMC may use and disclose records for investigations into employee misconduct or for law enforcement investigations related to its business. Disclosures may also be made to protect Noble REMC’s legal rights or during emergencies when there exists a reasonable belief that physical safety is at risk. These events are unlikely, but they are possible. Noble REMC will take reasonable steps to limit the scope and consequences of any of these disclosures.
7. Records may be shared with other utilities pursuant to shared service agreements or to meet operational requirements, in which case Noble REMC will make reasonable efforts to ensure that such utilities follow a policy to protect the confidentiality of that information.
8. Records about a member-consumer may be disclosed at the request of or with the permission of the member-consumer.
9. In addition, member-consumer information may be shared with affiliates and partners of Noble REMC that offer products and services to member-consumers.
10. Membership lists of the cooperative may be disclosed to a member of the cooperative for a proper purpose, such as in connection with cooperative election activities.
11. Noble REMC does not sell, rent, loan, exchange, or otherwise release mailing lists or telephone lists of member-consumers for any marketing purposes. Noble REMC does not disclose any information about a member-consumer to nonaffiliated third parties without the prior written consent of the member-consumer.
12. The members of the cooperative have the right to vote to authorize other uses and disclosures of information.
E. Questions and Disputes
1. This policy is maintained and supervised by the CEO of Noble REMC. Questions about the policy may be directed to that office. Any disputes over access, correction, or other matters may also be directed to that office. Noble REMC will do its best to resolve any questions or problems that arise regarding the use of member-consumer information.
- The Board of Directors shall ensure that detailed practices and procedures governing the collection, maintenance, use and disclosure of personally identifiable and other confidential information about member-consumers are developed by the cooperative’s management.
- The CEO shall ensure that the practices and procedures developed in accordance with this policy are followed.
Date Adopted: 6/20/00