Last Updated: December 18, 2018
Your privacy is paramount
Who are we exactly?
407 ETR operates and manages Highway 407 ETR, and we also provide tolling and back office services for the Province of Ontario's Highway 407 and Highway 412, (altogether, the "Toll Highways"). This means that two privacy laws can apply when we collect, use or disclose your Personal Information: Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) for Highway 407 ETR, and Ontario's Freedom of Information and Protection of Privacy Act (FIPPA) for the Province of Ontario's Highway 407 and Highway 412.
We're here to help
We want to be open with you about your Personal Information. So, if you ever have a question or comment, feel free to read our helpful FAQ section or just give our Customer Service Department a call at 1-888-407-0407. You can also call us to update or access your Personal Information, or to request other account information or changes. Our customer service representatives will be happy to help you, and can also provide you with more information about the policies, practices and procedures we follow to properly manage your Personal Information.
Our Privacy Officer, Randy Luyk, is responsible for ensuring that we are compliant with this Policy and our privacy laws. If you have any privacy-related questions or comments, wish to challenge our compliance with the privacy principles described in this Policy, or have concerns over the policy decisions we make, Randy can be reached at 905-265-4070 x 5216 or firstname.lastname@example.org.
You can also write to us at:
Customer Advocacy & Privacy Office
6300 Steeles Avenue West,
Woodbridge, Ontario L4H 1J1
What's Personal Information?
Personal Information is any information about an identifiable individual where the information, alone or with other information that's reasonably available, can be used to identify that person. Certain information is exempted, however, like somebody's business contact information that's used to communicate about his or her employment, business or profession.
Types of Personal Information we collect
We collect the Personal Information listed below mainly to bill customers, and also to fulfill the other purposes described in, "How we use your Personal Information".
- Mailing address
- Other contact details like phone numbers and e-mail addresses
- Transaction history
- Driver's licence information
- Date of birth
- Vehicle information
- Registrant identification number (RIN)
- Vehicle identification number (VIN)
- Credit history
- Trip details on the Toll Highways
- Customer communications with us like call centre, contest or survey responses that describe your experiences, opinions or preferences
- Website cookies that help gather technical and usage data on visitors to www.407etr.com
- Camera images of vehicles to capture front and rear licence plates*
- If you choose to participate in 407 ETR’s Transponder Location Program and expressly consent, we will collect the location of your transponder at specific points on other major GTA roadways.
- If you decide to download and install 407 ETR’s mobile app (the “Mobile App”) and expressly consent, we will collect location, travel and route information based on your in-app privacy settings, as well as mobile device ID and metadata that provides information about your device, browser and app use. The Mobile App is further described in, “407 ETR’s Mobile App”, below***
* To protect your privacy, we automatically blur camera images of the front windshield portion of your vehicle. In limited situations, the blurring of images may be imperfect, or temporarily suspended so we can test, maintain and improve our tolling technology. Any Personal Information collected as a result will be promptly destroyed after we fulfill such purposes.
** Nonvehicle geolocation data may be collected by the Mobile App strictly for the purposes of testing and calibration, and to trouble-shoot tools used to monitor vehicle driving patterns.
Where your Personal Information comes from?
We collect Personal Information from you when, for example, you:
- create an online account
- apply for a transponder
- sign up for and use the Mobile App
- participate in our contests, promotions or surveys
- otherwise exchange information with us
- travel on the Toll Highways, using transponder and front and rear camera technology
- choose to participate in 407 ETR’s Transponder Location Program and travel to specific points on other major GTA roadways
Note that you may choose to limit the Personal Information disclosed to us by opening an "Anonymous Account" for travel on the Toll Highways.
We also collect Personal Information from third parties for the purposes described in, "How we use your personal information", below. For example, we may collect Personal Information from the Ontario Ministry of Transportation (MTO), other toll road operators, motor transport administrators, credit reporting agencies and collection agencies in order to collect and enforce amounts owing.
How we use your Personal Information
With respect to the Toll Highways, we may use your Personal Information to help us achieve the purposes described below, or as explained to you in future communications.
- Collecting and enforcing tolls, fees and other charges owing
- Traffic planning and revenue management
- Responding to or exchanging information with third parties, government agencies, or toll road operators with whom we, or the MTO, have an agreement relating to collecting and enforcing tolls, fees and other charges owing incurred in a Province of Canada or a State of the United States
- Communicating with customers to promote the use of the Toll Highways
- Communicating with customers to:
- Manage, share or consolidate account information, such as through One-Simple-Bill and account linking, as well as administering accounts where a licence plate has been transferred and Personal Information may be shared between related customers
- Manage overdue balances, invoices and payments. For example, when investigating overdue balances, we may contact you, request a credit investigation or a consumer report about you, or exchange or disclose your Personal Information with, or to, government agencies, credit reporting agencies, collection agencies or other relevant service providers in Ontario or other jurisdictions
- Advise on leasing, billing and payment options, as well as programs or services that may add value or meet their needs
- Assess customer satisfaction and obtain feedback on service quality or offerings, such as through online surveys or in-person focus groups
- Developing offers suited to customer needs and preferences
- Training and testing for the internal purpose of designing, maintaining and improving the quality and/or scope of services we provide to you
- Complying with corporate policies, procedures and other business requirements
- With respect to website cookies, using technical and usage data gathered to improve the functionality and content of www.407etr.com so that you can have a great online experience!
- As it relates to the Mobile App:
- Providing marketing offers and promotions
- Ensuring the Mobile App is working properly, such as tracking outages or trouble-shooting issues reported to us
- Improving the Mobile App or developing new features or services related to the Mobile App or mobile device
- Verifying and improving customer account management
- Under privacy law, we may, if necessary, use or disclose your Personal Information in:
- Aiding an emergency where a person's life, health or security is at stake
- Responding to a subpoena, warrant, court order, or the request of a government institution with lawful authority for the purpose of enforcing or investigating a violation of law
- Complying with, or supporting compliance with, relevant laws and regulations
Limits to our collection, use, disclosure and retention
We'll only collect, use and disclose the Personal Information we need to achieve the identified purposes. For example, only Personal Information required to achieve a particular purpose will be disclosed to those who are responsible for helping us achieve that purpose, and these recipients must have already agreed to treat your Personal Information confidentially and securely, in accordance with our privacy laws. Rest assured, we'll never disclose your Personal Information to other parties for other purposes, unless required by law, nor will we trade or sell your Personal Information. We'll also keep your Personal Information only as long as it's needed to achieve the identified purpose or as required by law. After that, we'll delete it and require anyone else with your Personal Information to delete it too.
How we get your consent
Subject to applicable laws like the Highway 407 Act and Highway 407 East Act, we won't collect, use or disclose your Personal Information without your consent. In such cases, we'll clearly explain to you the reasons why we need your Personal Information so that you can make an informed decision, whether to consent or not. Based on our explanation, you should be able to understand the nature, purpose and consequences of the collection, use or disclosure of your Personal Information. If not, please let us know so we can clarify or elaborate.
Your consent can be express (written, verbal and/or electronic) or implied (through your action or inaction). When necessary, we'll ask for your express or "opt-in" consent with respect to more sensitive Personal Information and/or where a new purpose is identified, such as for purposes of the Mobile App described in part 10 of, “How we use your Personal Information”, above.
In other cases, we'll rely on implied or "opt-out" consent, such as by your travel of the Toll Highways or your use of our online services, in order to collect, use and disclose Personal Information to help achieve the purposes described in parts 5 through 9 of, "How we use your Personal Information".
In limited circumstances, the law allows us to forgo obtaining consent, such as when the use or disclosure of Personal Information is for the purposes described in parts 1 through 4 or 11 of, "How we use your Personal Information".
Withdrawing your consent
Where consent was required to use your Personal Information, you may withdraw it at any time by informing us through email, phone, mail, or in person. In the case of the Mobile App, you may withdraw your consent to our collection of Personal Information by deleting the Mobile App. If you would like to request that Personal Information already collected by the Mobile App not be used or that such information be deleted, please contact us with your request and we'll delete or render unidentifiable your Personal Information. Withdrawing your consent may limit the services we can provide to you. Further, if you have a balance owing or continue to travel on the Toll Highways we will still need to retain and use your Personal Information to continue providing services to you.
Protecting your Personal Information
We protect your Personal Information in a number of ways:
- Physically - Drawers, cabinets and offices are locked when not in use
- Technologically - Passwords, encryption and other technological safeguards are used to prevent unauthorized access
- Organizationally - Security clearance and verification procedures are followed so that those employees who need access to your Personal Information to do their job have access. All employees undergo regular data security training
- Contractually - Vendors that need access your Personal Information must agree to comply with the principles in this Policy, our privacy laws, and appropriate data security requirements so that, wherever your Personal Information is, there will be a comparable level of protection
In most cases, your Personal Information is used, disclosed and retained in Ontario, Canada. In some situations, however, we may disclose your Personal Information outside of Ontario or Canada in order to achieve the identified purposes, such as for collecting tolls or to comply with a legal request. Since outside jurisdictions may have different privacy standards, we try to limit such disclosure. Where disclosure is required, we ensure there is a comparable level of protection over your Personal Information.
Accessing your Personal Information
You have the right to know about the specific Personal Information we have about you. So, at your written request (with satisfactory identification), we'll be glad to provide you access to your Personal Information. There may be a small processing fee for this and we'll let you know ahead of time if there is. There may be times when we, unfortunately, cannot give you access to the Personal Information you're asking for, such as if giving you access would reveal another person's Personal Information, or if access would be harmful in a legal, security or commercial sense. We'll definitely write and let you know if this is the case and the reason(s) why we had to refuse your request. If you disagree with us, you can challenge our decision by responding back to us.
Updating your Personal Information
While we try to make sure that your Personal Information is up-to-date, you would know best if it were. From time to time, please review the Personal Information we have about you and, if a change or correction is needed, let us know right away! We'll make the needed updates to keep things running smoothly. You can review your Personal Information by looking at the correspondence we send to you, like your invoice, or simply request access to your Personal Information, as we've described above.
Note that while the law requires you to notify the MTO of a change in address within six days of moving, we're not provided these updates from the MTO. So, please let us know directly if you've moved.
We're accountable to you
We're accountable to you for your Personal Information, and that means we're responsible for the actions of anybody we've disclosed Personal Information to, including our employees, contractors and other third party representatives. As mentioned above, these parties are not provided your Personal Information unless it's necessary to achieve the identified purposes, and then only after they agree to follow the principles in this Policy, our privacy laws, and appropriate data security requirements.
407 ETR’s Mobile App
Logins made easier
We may provide you with the option to sign-on to our services (e.g., through the Mobile App) using existing information from social networking services such as Facebook, Twitter or Google. By choosing this single sign-on option, you agree that we may use certain Personal Information to simplify the login process for you and avoid the need to create a new account with us.
We may collect aggregated data using 407 ETR technology or from third parties. Aggregated data refers to data from multiple sources that can show us group-based trends. This data does not identify you or anyone else but, for example, relates to the driving patterns of hundreds or thousands of commuters who use Highway 407 ETR. These patterns may be attributed to individual customers, allowing us to better manage traffic, respond to customer needs or preferences, and promote our services.
Since both PIPEDA and FIPPA apply to our collection, use and disclosure of Personal Information, we've listed the relevant contact information of our privacy commissioners just in case you have any questions or concerns that we can't address:
For PIPEDA issues relating to Highway 407 ETR, contact the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca):
30 Victoria Street
Gatineau, Quebec, K1A 1H3
Phone: (819) 994-5444
Fax: (819) 994-5424
TTY: (819) 994-6591
For FIPPA issues relating to the Province of Ontario's Highway 407 and Highway 412, contact the Information and Privacy Commissioner of Ontario (https://www.ipc.on.ca):
2 Bloor Street East, Suite 1400
Toronto, Ontario, M4W 1A8
Toronto Area: 416-326-3333
Long Distance: 1-800-387-0073 (within Ontario)