
CORPORATE POLICY No. 153
SUBJECT: Policy on Privacy and Confidentiality
I.
OBJECTIVE
To
establish fair
info
rmation principles for
HILCO
United Services, Inc., in carrying out its responsibility to respect the
privacy and confidentiality of customer
info
rmation.
II.
POLICY
A.
Notice
1.
HILCO
United Services discloses to its customers its policies and practices for the
collection, maintenance, use, and disclosure of identifiable
info
rmation about its customers.
2.
HILCO
United Services collects and maintains appropriate
info
rmation about its customers as a routine part of its operations.
3.
When providing propane, water, or other services,
HILCO
United Services collects
info
rmation from customers, including name, address, telephone number, Social
Security number, credit
info
rmation, and payment and usage history. Usage
history may include
info
rmation on a customer’s property, health
info
rmation, service history, and
info
rmation maintained for meter reading purposes (e.g., warning about a dog in the
yard, etc.).
4.
Occasionally,
HILCO
United Services may survey a sample of its customers to collect
info
rmation to identify needs or improve service.
5.
Other activities by
HILCO
United Services or its affiliates, either now or in the future, will result in
the collection of additional
info
rmation about a customer’s property and activities.
This
info
rmation will be collected and maintained only when and to the extent appropriate
to provide the services.
6.
This notice describes generally
HILCO
United Service’s privacy and confidentiality policies.
The policy is not a formal limitation on the ability of
HILCO
United Services to use, manage, and disclose its
Policy 153 – 2
records as
HILCO
United Services determines to be necessary, appropriate, or as required by law.
It is subject to change without notice.
B.
Trust
1.
General Practices:
HILCO
United Services maintains
info
rmation about customers for purposes that are suitable to its operations and
management. Information is collected
only through lawful and fair means and for appropriate purposes.
HILCO
United Servicses is committed to maintaining accurate, complete, timely,
relevant, and appropriate
info
rmation about customers as necessary for the purpose for which the
info
rmation is to be used.
2.
Access and Correction:
HILCO
United Services generally permits its customers to access and seek correction
of records about themselves that are used by
HILCO
United Services to provide service and for billing.
Any person who wants to identify personal records maintained by
HILCO
United Services, access the records, or correct the records should contact
HILCO
United Services.
C.
Security
1.
HILCO
United Services maintains customer
info
rmation 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
United Services provides reasonable and appropriate security to protect against
foreseeable hazards.
2.
HILCO
United Services requires its employees and, when practicable and appropriate,
its affiliates and contractors who have access to identifiable customer
info
rmation 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
United Services uses and discloses identifiable
info
rmation about customers in defined and responsible ways in order to carry out
its operations. This section
describes how identifiable
info
rmation about customers may be used and disclosed.
Policy
153 – 3
2.
Records may be disclosed to affiliates or contractors hired by
HILCO
United Services to assist in carrying out operations, such as service, billing,
and management functions including legal, audit, and collection services.
3.
Customer
info
rmation 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
HILCO
United Services management activities.
6.
Records may be disclosed when required by law, such as in response to a
search warrant, subpoena, or court order.
HILCO
United Services 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
United Services’ legal rights or during emergencies if physical safety is
believed to be at risk. These events
are unlikely, but they are possible.
HILCO
United Services 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 customer may be disclosed at the request of or with the
permission of the customer.
9.
In addition, customer
info
rmation may be shared with affiliates and partners of
HILCO
United Services that offer products and services to customers.
10.
HILCO
United Services does not sell, rent, loan, exchange, or otherwise release
mailing lists or telephone lists of customers.
HILCO
United Services does not disclose any
info
rmation about a customer to nonaffiliated third parties without the prior,
written consent of the customer.
Policy 153 – 4
E. Questions
and Disputes
1. This policy is
maintained and supervised by
HILCO
United Services. Questions about
the policy may be directed to the corporate office at
115 E. Main Street
,
Itasca
,
Texas
. Any disputes over access,
correction, or other matters may also be directed to that office.
HILCO
United Services will do its best to resolve any questions or problems that
arise regarding the use of customer
info
rmation.
III.
Responsibility
A. The board shall ensure that
this policy reflects current practices for personal
info
rmation about customers.
B.
The General Manager shall ensure that this policy is adhered to.
APPROVED
BY THE BOARD OF DIRECTORS
Gerald
W. Lemons, President
DATE ADOPTED:
October 27, 2005