UTL-5.02 - Water Bureau Data Sharing for Financial Assistance Program

1. Purpose

The Portland Water Bureau (PWB) administers a financial assistance program for its water, sewer, and stormwater service customers. Other City bureaus and programs may want to offer similar financial assistance to Portland residents. However, the release of personally identifiable information without the customer’s consent via the waiver is a violation of the Oregon Public Information Law. ORS 192.355(28). This rule sets out the requirements that need to be met for PWB to share its participant list with other bureaus and programs that seek to implement a financial assistance program.

2. Authority

These rules are authorized by, and implement, in relevant part, the following City Charter and Code provisions, as may be amended from time to time:

1. ORS 192.355(28)
2. Portland City Code (PCC) Section3.24.030
3. Ordinance No. 191534
4. Ordinance No. 192079
5. ADM-14.01 (Account Management Policy)
6. ADM-14.04 (Collection of Personal Information)
7. ADM 14.07 (Rates and Charges for Water and Water-Related Services)

3. Definitions

4. Requirements to Receive Customer Data

PWB will:

• Provide customer data for its financial assistance program participants to any bureau or program authorized by the City Administrator to receive such information.
• Provide data that includes customer service address, discount tier or percentage, and whether the participant is an owner or renter, which can be accessed by authorized City personnel and used internally for program design purposes.
• Communicate to financial assistance program customers that they may be eligible for other financial assistance from City bureaus or programs through established communication methods.
• Provide opt-in language that will include consent from the customer to have their information shared with the bureaus and programs offering financial assistance. The consent will also allow City franchisees and other non-City entities that provide services to City residents related to the financial assistance program, such as garbage haulers, to access customer information necessary to apply financial assistance programs.
• Confirm participant status and eligibility for existing PWB customers who opt into a bureau’s financial assistance program and generate an updated monthly report of program participants.
• For eligible participants, provide data to the bureau that includes customer name, PWB account number, property ID number (if available), service address, discount tier or percentage, and date the discount was applied.

Bureau/Program will:

• Ensure customer data is handled confidentially by bureau or program staff and used solely to evaluate financial assistance program eligibility and apply the discount.
• For the BPS solid waste financial assistance program, host and own the results of a customer opt-in tool. This opt-in tool will be offered to existing LINC customers to indicate interest in eligibility to receive financial assistance on garbage and recycling services. BPS will report results to PWB monthly to receive financial assistance program-eligible customer data.
• Put safeguards in place, such as administrative rules and franchise language, to ensure customer data is handled confidentially between itself and franchisees or other outside entities.
• Limit the exchange of customer data between the bureau/program and any non-City entities and require non-City entities to agree to keep customer information confidential to the extent allowed by law. The bureau or program will limit the exchange of customer data to service address, account holder, and eligibility status of the customer.
• Get waiver form signed. created a waiver form to allow current participants to opt into the bureau’s financial assistance programs as they are developed.
• Require all employees who have direct access to PWB utility account records to sign confidentiality statements provided by PWB.