GCEC Telecom Policy on Privacy and Confidentiality

Objective

To establish fair information principles for GCEC Telecom in carrying out its responsibility to respect the privacy and confidentiality of member-consumer information.

Policy

1. Notice
   1. The cooperative discloses to its member-consumers its policies and practices for the collection, maintenance, use, and disclosure of identifiable information about its member-consumers.
   2. The cooperative collects and maintains appropriate information about its member-consumers as a routine part of its operations.
   3. When providing electricity and related services, the cooperative collects information from member-consumers, including name, address, telephone number, Social Security number, credit information, and 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 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. Occasionally, the cooperative may survey a sample of its memberconsumers to collect information to identify needs or improve service.
   6. Other activities by the cooperative or its affiliates, either now or in the future, will result in the collection of additional information about a memberconsumer'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 the cooperative's privacy and confidentiality policies. The policy is not a formal limitation on the ability of the cooperative to use, manage, and disclose its records as the cooperative determines to be necessary, appropriate, or as required by law. It is subject to change without notice.
2. Trust
   1. General Practices: The cooperative maintains information about memberconsumers for purposes that are suitable to its operations and management. Information is collected only through lawful and fair means and for appropriate purposes. The cooperative 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: The cooperative generally permits its memberconsumers to access and seek correction of records about themselves that are used by the cooperative to provide service, for billing, and to manage capital accounts. Any person who wants to identify personal records maintained by the cooperative, access the records, or correct the records should contact the cooperative.
3. Security
   1. The cooperative 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. The cooperative provides reasonable and appropriate security to protect against foreseeable hazards.
   2. The cooperative requires its employees and, when practicable and appropriate, its affiliates and contractors who have access to identifiable member-consumer 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.
4. Use and Disclosure
   1. The cooperative uses and discloses identifiable information about memberconsumers 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 affiliates or contractors hired by the 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. 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 the cooperative management activities.
   6. Records may be disclosed when required by law, such as in response to a search warrant, subpoena, or court order. The 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 the cooperative's legal rights or during emergencies if physical safety is believed to be at risk. These events are unlikely, but they are possible. The cooperative will take reasonable steps to limit the scope and consequences of any of these disclosures.
   7. Records may be shared with other utilities under shared service agreements or to meet operational requirements.
   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 the cooperative that offer products and services to memberconsumers.
   10. The cooperative does not sell, rent, loan, exchange, or otherwise release mailing lists or telephone lists of member-consumers. The cooperative does not disclose any information about a member-consumer to nonaffiliated third parties without the prior, written consent of the member-consumer.
5. Questions and Disputes
   1. This policy is maintained and supervised by the cooperative. 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. The cooperative will do its best to resolve any questions or problems that arise regarding the use of member-consumer information.

Responsibility

1. The board shall ensure that this policy reflects current practices for personal information about member-consumers.
2. The General Manager/CEO shall ensure that this policy is adhered to.