Privacy Policy

1. Applicability and Collection of Information

This policy is applicable to customers of Indianola Municipal Utilities (IMU).

IMU collects personal information from customers for the purpose and to the extent necessary to enable provision of services and secure payment for services.

The collection of personally identifiable customer information shall be limited to name, social security number, service address, billing address, personal telephone numbers, business telephone numbers, emergency contact information, employer, IMU account number, bank account number, credit card number, installation information, billings, payments, deposits, complaints, service records and equipment records. IMU shall take reasonable precautions to prevent unauthorized access to this information in full compliance with the Fair and Accurate Credit Transactions Act of 2003.

Personal information we collect will be maintained as long as it is needed to serve the purpose for which it was collected. Generally, customer records will be maintained for no more than five years after service is discontinued.

2. Disclosure of Information

A. Except as described in this policy, the disclosure of personally identifiable customer information to a third party shall only occur if the customer provides written or electronic consent in advance.

B. Customer records may be available to employees or agents of IMU to market, provide, or audit communications services, to measure viewership and customer satisfaction, to settle disputes, and to provide customers with information concerning communications related products.

C. Information may be provided to contractors acting on behalf of IMU for the purpose of installing or repairing services.

D. Information may be released to collection services if required to collect past due bills.

E. The most recent 12-month high, low and average usage and bill amounts for IMU electric services at a property are disclosed upon request; the identity of the account holder is not part of such disclosure.

F. IMU may be required to disclose information or provide documents, including e-mails or other documents subscribers have stored on our network, in order to comply with a request from a law enforcement agency or a court order. The disclosure of information shall be limited as follows:

1. Payment Assistance Agencies: Information will be disclosed to the agency as necessary to assist the customer in obtaining financial assistance to pay his or her utility bill. (Note: this may include the disclosure of social security number.)

2. City of Indianola, Warren County, State of Iowa and any subdivision or agency thereof: Disclosure of name, address and forwarding address only. Any other information will be provided only upon the receipt of a subpoena or court order (other information may include phone number or Social Security Number).

3. Law enforcement agencies and emergency responders: Disclosure of name, address, phone numbers, and emergency contacts will be made upon a bona fide request. Bona fide means that IMU is certain of the source of the request. Any other information will be provided only upon
the receipt of a subpoena or court order (other information may include SSN). These agencies include the FBI, Police, Fire Department and similar entities.

3. Records Inspection by Customers

By providing adequate personal identification, a customer may review his or her account information and inspect personally identifiable customer information during office hours. Customers shall have the right to correct any inaccurate information in their account records.

4. Remedy for Improper Disclosure of Information about Cable TV Service Subscribers

IMU complies with the cable TV privacy rules established by the Federal Communications Commission. A customer who believes IMU has disclosed information in violation of these rules may file suit in United States District Court.

5. Internet and E-mail Privacy Practices

A. IMU does not monitor the content of information packets passing over our network or information stored on our network.

B. IMU does not monitor the content of e-mail passing over our network, and respects the privacy
of users’ e-mail.

C. IMU cautions users that electronic communication, including e-mail, is not completely private on any network.

D. A limited number of IMU employees have access to individual e-mail accounts for the purpose of providing technical support and assistance. IMU treats requests for assistance (for example, calls to our technical support Help Desk) as implied consent to inspect e-mail. Inspection is limited to that necessary to provide the requested assistance. Additionally, e-mail messages are typically routed through many external systems outside of IMU’s control. IMU accepts no liability for the actions of other providers.

E. IMU may access customer e-mail accounts or inspect information packets in order to investigate a report of network abuse or a condition on the network that indicates possible abuse.

F. If IMU is required by court order, subpoena or similar law enforcement action to provide customer e-mails or other information customers have stored on the network, staff members may review the materials to determine whether or not they are covered by the order.