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Can I use third-party customer service tools that collect personal information in Michigan? What are the requirements?
Use of Third-Party Customer Service Tools in Michigan
If you are using third-party customer service tools that collect personal information in Michigan, you must comply with the state’s privacy laws. Michigan does not have specific requirements for third-party customer service tools that collect personal information. Nonetheless, you must comply with federal law and industry standards when exchanging customer service information [1.1].
Customer Data Privacy Policy
Each electric and natural gas utility in Michigan must file with the commission, for the commission’s approval, a customer data privacy tariff that contains a customer data privacy policy. The privacy policy must encompass all customer information or data collected or maintained by the utility, clearly define customer information or data that the utility collects or maintains, protect all customer information or data collected for the utility from unauthorized use or disclosure by the utility, its affiliates, or contractors, and ensure that, for secondary purposes, customer usage data, personally identifiable information, and certain other customer information are only disclosed to third parties with the customer’s written consent. The policy must also specify that customer information may be disclosed without consent in response to a warrant or court order, as required for collection activities, or as necessary for primary purposes. The privacy policy must permit a customer to share his or her information with a third party that is not affiliated with the utility. The utility may elect to insert language in the privacy policy stating that the utility is not responsible, in this circumstance, for a third party’s unauthorized disclosure or use of this information. The policy must provide clear instructions regarding the method by which a customer and a third party, authorized by the customer, may obtain customer usage data in a timely manner and a readily accessible format from the utility. The policy must indicate that the policy does not apply to aggregate data, containing general characteristics of a customer group, which is used for analysis, reporting, or program design purposes [3.1].
Conclusion
Michigan does not have specific requirements for third-party customer service tools that collect personal information. Nonetheless, you must comply with federal law and industry standards when exchanging customer service information. Each electric and natural gas utility in Michigan must file with the commission, for the commission’s approval, a customer data privacy tariff that contains a customer data privacy policy. The policy must encompass all customer information or data collected or maintained by the utility, clearly define customer information or data that the utility collects or maintains, protect all customer information or data collected for the utility from unauthorized use or disclosure by the utility, its affiliates, or contractors, and ensure that, for secondary purposes, customer usage data, personally identifiable information, and certain other customer information are only disclosed to third parties with the customer’s written consent.
Source(s):
- [1.1] Exchanging customer service information
- [3.1] Customer access to consumption data and confidentiality
Jurisdiction
Michigan