Comprehensive Energy Management Solutions Program
TRC Solutions, Inc. (“TRC” or “we” or “our”) is acting as the implementer of the Comprehensive Energy Management Solutions Program (“Program”) for San Diego Gas & Electric Company (SDG&E). This role involves the collection of certain personal information to facilitate your involvement in the Program. TRC takes the privacy and security of your personal information seriously. This Notice is effective January 1, 2023 and describes how we collect, use, and disclose personal information relating to California residents under the California Consumer Privacy Act of 2018 (“CCPA”), including the California Privacy Rights Act of 2020 (“CPRA”) and under the California Public Utilities Commission Privacy Rules (“Rules”).
What is Personal Information?
The “CCPA” describes “Personal Information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. However, the CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act or the Health Information Portability Accountability Act.
What is Covered Information?
The Rules describe “Covered Information” as any usage information obtained through the use of the capabilities of advanced metering infrastructure when associated with any information that can reasonably be used to identify an individual, family, household, residence, or non-residential customer, except that Covered Information does not include usage information from which identifying information has been removed such that an individual, family, household or residence, or nonresidential customer cannot reasonably be identified or re-identified. Covered information, however, does not include information provided to the Commission pursuant to its oversight responsibilities.
Notice at Collection (Collection, Use, and Disclosure of Personal Information)
TRC anticipates collection of the following categories of Personal Information or Covered Information about California residents and may disclose certain Personal Information to third parties or service providers for the business purposes listed.
As part of our implementation of the Program we may collect, or, in the past 12 months, we may have, collected the following categories of Personal Information or Covered Information:
- Identifiers, such as name and contact information,
- Personal information, as defined in the California safeguards law, such as financial information,
- Protected classifications under California or federal law, such as disability status or other attributes,
- Customer records, such as transaction, account and energy use,
- Internet or network activity, such as browsing history and interactions with our website,
- Geolocation data, such as equipment location, and
- Audio, electronic, visual, or similar information, such as call and video recordings, and
We will retain your Personal Information and Covered Information until the later of either the conclusion of the Program, or as required by our contract with SDG&E.
We may use your Personal Information or Covered Information for the following business purposes:
- to communicate with you and manage your Program incentive or Trade Professional Network membership,
- to determine your eligibility for and participation in certain programs,
- for our employment and vendor management purposes,
- to personalize, advertise, develop, improve, and market our products and services,
- for quality, safety, and data analysis,
- to perform accounting, auditing, and other internal functions, necessary to the Program,
- to maintain business records,
- to conduct investigations and comply with legal obligations, pertaining to the Program,
- to exercise and defend legal claims,
- for uses we notify you of or obtain your consent, and
- for use in a lawful manner compatible with the context in which it was provided.