Privacy Statement

HPP EMPLOYEES MULTIPURPOSE COOPERATIVE

Subject: Privacy and Confidentiality

OBJECTIVE

To establish fair information principles for HPP EMPLOYEES MULTIPURPOSE COOPERATIVE (HPPEMC) in carrying out its responsibility to respect the privacy and confidentiality of member information.

POLICY

• Notice

1. HPPEMC discloses to its members its policies and practices for the collection, maintenance, use, and disclosure of identifiable information about its members.
2. HPPEMC collects and maintains appropriate information about its members as a routine part of its operations.
3. When providing related services HPPEMC collects information from members, including name, email address and other information. Other information may include information on a member’s property and appliances, health information, and company service history.
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, HPPEMC may survey a sample of its members to collect information to identify needs or improve service.
6. Other activities by HPPEMC 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 HPPEMC’s privacy and confidentiality policies. The policy is not a formal limitation on the ability of HPPEMC to use, manage, and disclose its records as HPPEMC determines to be necessary, appropriate, or as required by law. It is subject to change without notice.

• Trust

1. General Practices: HPPEMC 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. HPPEMC 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: HPPEMC generally permits its members to access and seek correction of records about themselves that are used by HPPEMC to provide service, and to manage capital accounts. Any person who wants to identify personal records maintained by HPPEMC, access the records, or correct the records should contact: This email address is being protected from spambots. You need JavaScript enabled to view it..

• Security

1. HPPEMC 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. HPPEMC provides reasonable and appropriate security to protect against foreseeable hazards.
2. HPPEMC requires its employees and, when practicable, its affiliates and contractors who have access to identifiable member information to sign a statement acknowledging that they have read this privacy and confidentiality policy and agreeing 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.

• Use and Disclosure

1. HPPEMC 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 HPPEMC to assist in carrying out operations, such as service, collection, and management functions including legal, audit, and collection services.
3. Member 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 HPPEMC management activities.
6. Records may be disclosed when required by law, such as in response to a search warrant, subpoena, or court order. HPPEMC may use and disclose records for investigations into employee misconduct or for law enforcement investigation related to our business. Disclosures may also be made when appropriate to protect HPPEMC’s legal rights or during emergencies if physical safety is believed to be at risk. These events are unlikely, but they are possible. HPPEMC will take reasonable steps to limit the scope and consequences of any of these disclosures.
7. Records about a member may be disclosed at the request of or with the permission of the member.
8. In addition, member information may be shared with affiliates and partners of HPPEMC that offer products and services to members.
9. 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. 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 policy adopted by the Board (or the membership), and further uses of any lists so disclosed will be subject to that policy.
10. HPPEMC does not sell, rent, loan, exchange or otherwise release mailing lists or telephone lists of members (for marketing purposes). HPPEMC does not disclose any information about a member to nonaffiliated third parties without the (prior, written) consent of the member.
11. The members of the Cooperative have the right to vote to authorize other uses and disclosures of information.
12. Members may request that their information not be shared with affiliates for the offering of new products and services.

• Questions and Disputes

1. This policy is maintained and supervised by HPPEMC. Questions about the policy may be directed to the HPPEMC Ethics Committee.
2. Any disputes over access, correction or other matters should be directed to HPPEMC. HPPEMC will do its best to resolve any questions or problems that arise regarding the use of member information.

ADMINISTRATION

1. Ethics Committee
2. Chairman
3. Board of Directors

Effective Date: March 31, 2015

Revision Date: 3/31/15

Chairman: Val Hilario