Last Updated: November 30, 2016
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 (east of Brock Road) 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 (east of Brock Road) 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 formally 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 Personal Information mainly to bill customers, and also to fulfill the other purposes described in, “How we use your Personal Information”, below. This information may include:
- Mailing address
- Other contact details like phone numbers and e-mail addresses
- Licence plate
- 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
- Travel information, preferences and related data
- Customer communications with us like call centre, contest or survey responses
- Customer experiences, opinions or preferences
- Website cookies that help gather technical and usage data on visitors to www.407etr.com
Where your Personal Information comes from?
We collect Personal Information from you when, for example, you travel on either Toll Highway (through our tolling technology), use any apps we might make available, create an online account, sign up for a transponder, participate in our contests, promotions or surveys, or otherwise exchange information with us. Note that you may choose to limit the Personal Information disclosed to us by opening an “Anonymous Account” for travel on the Toll Highways.
In order to bill customers properly, we collect Personal Information from the Ontario Ministry of Transportation (MTO), as well as third party entities that can provide the mailing address of out-of-province customers. We also collect Personal Information from credit reporting agencies or collection agencies, particularly when bills are overdue.
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 third parties that we, or the MTO, have an agreement with relating to collecting and enforcing tolls, fees and other charges owing
- 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 new service offerings suited to customer needs or preferences
- Internal training and testing in support of 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, we may use the technical and usage data gathered to improve the functionality and content of www.407etr.com so that you can have a great online experience!
We may also use or disclose your Personal Information, when necessary, to:
- Aid in an emergency where a person's life, health or security is at stake
- Respond to a subpoena, warrant, court order, or the request of a governmental authority with proper jurisdiction
- Comply, or support or facilitate 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, or otherwise 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 or verbal) 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. 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 5, 6, 7 and 8 of, “How we use your Personal Information”.
In certain cases, the law allows us to forgo obtaining consent, such as when the use of Personal Information is necessary to help:
- Achieve the purposes described in 1, 2, 3 and 4 of, "How we use your Personal Information"
- Aid in an emergency where a person's life, health or security is at stake, and where it's impossible or impractical to seek consent
- Assist in collecting overdue amounts
- Respond to a subpoena, warrant, court order, or the request of a governmental authority with proper jurisdiction
- Comply with relevant laws and regulations
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. We'll then delete or render unidentifiable your Personal Information. Withdrawing your consent may limit the services we can provide to you. If, however, 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.
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, 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, 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)