SCOPE: This Privacy Policy applies to all BWL departments, employees, contractors, and third-party vendors that collect, use, process, record, store, transfer, disclose, or delete BWL Personal Confidential Information.
PURPOSE: The purpose of this Data Privacy Policy (“Privacy Policy”) is to establish guidelines for collection processing, storage, transfer, disclosure, deletion, safe-guarding and use of confidential personal data (defined below) at the Lansing Board of Water & Light (BWL).
POLICY: See below which begins with “Definitions”
DEFINITIONS:
“Personal Confidential Information (PCI)” means Customer Information, Personal Information and Protected Health Information as defined below.
“Customer Information” means customer-specific information received and stored by the BWL for purposes of participating in utility services or programs (bill payment assistance, shutoff protection, renewable energy, demand-side management, load management or energy efficiency) including payment data, credit history, driver’s license or state ID number, social security number and Consumption Data.
“Consumption Data” means customer-specific BWL utility usage data, including, but not limited to customer-specific kW, kWh, voltage, kvar, power factor, ccf, Mlbs, temperature, ton hours and other consumption data stored in the BWL’s systems.
"Personal Information" (PI) means information that, when used alone or combined with other personal or identifying information, can be used to distinguish or derive the identity of an employee or customer such as name, address, social security number or date of birth.
“Protected Health Information (PHI)” means health data created, received, stored, or transmitted by the BWL, as a covered entity, or its business associates, in relation to a person’s state of health, the provision of healthcare or payment for healthcare services.
Collection and Usage:
BWL respects the privacy of its employees and customers and takes its responsibility regarding the security of Personal Confidential Information seriously. The release or loss of Personal Confidential Information can result in harm to individuals, including identity theft or other fraudulent use of the information. Because BWL employees, departments, agents, and contractors may have access to Personal Confidential Information, adherence to BWL security and safe-guarding procedures is critical.
The BWL uses commercially reasonable administrative, technical, contractual, and physical security measures to ensure the integrity of its information systems and to protect Personal Confidential Information. Such protection measures include an enterprise security program based upon industry standard frameworks, security awareness for employees, a dedicated team to detect and respond to threats, and collaboration with peers and state and federal partners.
In some instances, the BWL may be required to disclose certain Personal Confidential Information in accordance with Customer authorization or when required by law (which includes law enforcement requests supported by warrants or court orders that specifically name the Customer, and judicially enforceable subpoenas). Disclosure will be limited to that reasonably necessary to that required to fulfill the request. The BWL will not sell Personal Confidential Information to a third party.
Examples of scenarios where BWL collects Personal Confidential Information, include, but are not limited to:
- Customer Information that allows BWL and its customer to enter in to a utility service relationship.
- Consumption Data such as kW, kWh, voltage, kvar, power factor, ccf, Mlbs, temperature, ton hours and other related data.
- Personally Identifiable Information and Personal Health Information is collected from BWL employees and contractors for employment purposes, benefits associated with employment or pursuant to a contractual employment relationship.
Requests to Release Information
All Privacy issues and resolutions are to be addressed through the BWL Privacy Officer.
You may request that your Personal Confidential Information be released to you or a third party of your choice by written consent. The BWL is not responsible for a third party's unauthorized disclosure or use of Personal Confidential Information that you authorize BWL to release. The following method may be used to make these requests:
In Writing:
Attn: BWL Privacy Officer
Privacy Disclosure Request
1201 S. Washington
Lansing, MI 48901
Retention and Disposition
THE BWL WILL KEEP PERSONAL CONFIDENTIAL INFORMATION FOR AS LONG AS NECESSARY CONSISTENT WITH THE LEGITIMATE PURPOSE FOR WHICH IT WAS ORIGINALLY COLLECTED AND IN ACCORDANCE WITH ITS RECORD RETENTION PLAN.
Visiting BWL’s Website and Links
BWL does not collect Personal Information about persons who visit BWL’s website, unless the user chooses to provide such information.
All BWL computer systems are subject to monitoring to assure proper functioning of the systems, to provide security for the computer system operations and information, to prevent unauthorized use, and to deter and investigate unauthorized intrusions and violations of the law.
The BWL provides links to other organizations through its website. These links are provided for additional information as a service to our customers. In providing these links, the BWL does not endorse the content, products, services or viewpoints expressed by external sites. Once a user leaves the BWL's website and links to an external site, the BWL's privacy policy no longer applies and users will be subject to the new site's policy. BWL does not supervise or regularly review these linked sites. BWL specifically disavows any responsibility for what a user may find on another site.
BWL provides links to the following types of organizations:
- Governmental Units: BWL provides links to other state and local government units that provide additional services and information that users of the BWL's site may find of interest.
- Private Organizations: BWL provides links to private organizations if these organizations offer services that complement information or services offered by the BWL. The BWL does not favor one group over another. The determination of whether to establish links to a private organization's website is made on a case-by-case basis.
Approved 1/27/2020
View the website privacy policy page here: https://www.lbwl.com/website-privacy-policy.