Privacy Policy Regarding the Collection and Use of Customer’s Social Security Number

1. How your social security number is collected.

We obtain your social security number when you apply for service. Additionally, we may obtain a social security number at the time of processing Capital Credits.

2. How your social security number is used.

Your social security number is obtained because we will be extending credit to you by billing you after the services have been provided to you. We also use your social security number as an additional means to verify your identity and distinguish you from other customers with the same or similar name and to administer the Lifeline and LITE-UP Texas Program.

3. How do we protect your social security number?

We are sensitive to your concerns that your social security number might fall into the wrong hands, which could result in identity theft or general access to your personal information by unauthorized persons.

Your Application for service, and any other documents containing your social security number, are filed in a secure location to which only authorized personnel have access. Personnel who receive your Application have strict instructions to immediately transport such documents to the secure area and to not permit such documents to remain on desks, in baskets or elsewhere in public work areas where they could be seen by unauthorized individuals. Personnel are prohibited from copying or in any way duplicating documents containing your social security number except duplication for an authorized purpose.

Your social security number does not appear in electronic form accessible on our network by any individuals not authorized to have access to your social security numbers. Firewalls, passwords and other safeguards have been installed in our network to restrict access to your social security number to those employees so authorized. Employees authorized to have access to your social security numbers are prohibited from saving your social security number, in any fashion, on a the hard drive of any laptop or other stand alone computer not saving data on our network.

We will not include your social security number on any documents, such as monthly statements, for which it serves no purpose. We need your social security number on file for the purposes stated but will not use it unnecessarily so as to limit the opportunity for it to be inadvertently disseminated.

All employees who will come in contact with your social security number are provided initial training before they are permitted to handle any document containing social security numbers and will be reminded, through periodical updated training, of the importance of protecting the privacy of social security numbers and our policies which have been designed to insure such protection, asserting the need to safeguard customers’ social security numbers. Before discarding any customer records, employees are to shred any portion of the records which contain a customer’s social security number.

4. Who can access your social security number?

Authorized employees will have access to documents containing your social security number.

If your account is turned over for collection purposes and the attorney/collection agency requests your social security number to assist in collection proceedings, we will provide your number to them as our agent.

If we receive a subpoena or Court order compelling us to turn your records over to a law enforcement agency or investigator or to a party in connection with a legal proceeding, then we will release them, including your social security number, as required by law. If the subpoena is issued in a civil matter, you should have the opportunity to seek a protective order or to quash the subpoena to protect the confidentiality of your information.

5. How will we eventually dispose of your social security number?

Even after you terminate service and pay all amounts owed to us on your account, we will retain your records in accordance with our record retention policy and this privacy policy. We may need your information for processing Capital Credits and will need to retain this information for a number of years. If we elect to destroy your records in accordance with our policy, the records containing your social security number will be shredded and any electronic records containing your social security number will be permanently deleted.