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Your privacy is important to us, we respect your personal privacy and are committed to maintaining your trust and confidence in the way we collect, store, use, and share your personal information. This Policy sets out how we collect, store, use and share your personal information, and how we comply with our obligations under the New Zealand Privacy Act 2022.
Personal information includes any information that can identify you as an individual. You have the choice not to provide us with your personal information (other than as required by law). However, this may result in us being unable to provide you with some or all of our services or may substantially reduce the level of service we are able to provide to you, and/or reduce the areas of our website that you will be able to access.
When using our reporting services such as our case management system EthicsPro® (Reporting Services), no personal information is automatically collected from you. Personal information is only collected and stored when you voluntarily give such information to us.
We collect personal information as part of our ordinary business operations and through our Reporting Services. Personal information that we collect from you or about you where you have been named through our Reporting Services may include:
We collect personal information from you when you interact with us, or we interact with you. The personal information we collect will depend on the nature and purpose of the interaction with us. We will generally collect your personal information when you:
By providing us with your personal information, you consent to our collection, storage, use, sharing of your personal information and using it in accordance with this Policy and applicable law.
We collect personal information where it is necessary to perform our services, including our Reporting Services, where it is necessary to respond to your request, or to otherwise manage your interaction with us.
When we obtain your personal information, we will only use that personal information for the purpose for which it is collected, as set out in this Policy or as permitted by law. Generally, we will collect and use personal information from you for the following purposes:
In most instances, we will collect personal information directly from you. However, there may be instances where we need to collect information from third parties.
We will only collect personal information about you from third parties as set out in this Policy, where it is reasonably necessary for the circumstances, where it relates to our Reporting Services, where we are obtaining such personal information from a publicly available source, or where you have provided your express or implied consent.
Examples of where we collect personal information about you from third parties include:
We may need to share your personal information with third parties from time to time. We will only share personal information with third parties where we are permitted under this Policy, where you have specifically authorised us to do so, as part of the Reporting Services and other services we are providing or where we are permitted or required to in accordance with applicable law.
For example, we may share your personal information with:
At times, cookies may be used to help us serve you better when you use our website. A cookie is a small element of data sent by a website to your browser, which may then be stored on your hard drive so we can recognise you when you return. You may set your browser to notify you when you receive a cookie and, if you wish, to reject it, or clear cookies by using your browsers options.
Web beacons, also known as clear gif technology, or action tags, assist in delivering the cookie. This technology tells us how many visitors clicked on key elements (such as links or graphics) on our website. We do not use this technology to access your personal information. It is a tool we use to compile aggregated statistics about the website’s usage. We may share this tracking information with third parties.
Where you opt-in to receive commercial messages and advertising from us, you agree to receive our marketing and other communications (including commercial electronic messages) electronically (via email or text message) and by post. If you decide that you no longer wish to receive commercial electronic messages from us you can unsubscribe by using the unsubscribe feature in any commercial electronic message, or notify us by email at [email protected] or by contacting us directly by telephone or post.
We are committed to using industry-standard practices to keep the personal information you provide to us safe against loss, unauthorised access, unauthorised modification, and unauthorised disclosure. We will not retain your personal information for longer than reasonably necessary or longer than required by law. However, aggregated or anonymised data may be retained for longer.
We have implemented a variety of security measures in relation to the protection of personal information.
In some cases, we may use technology such as file encryption when we are transmitting personal information from time to time. Where personal information transmission is taking place by unencrypted email, we cannot guarantee that your personal information will remain secure during transmission.
Where we are sharing your personal information with third parties, other than the police or regulatory authorities, we will use reasonable endeavours to require the third party to maintain confidentiality of your personal information.
If we are sharing your personal information with a third party that is not located in New Zealand, a data storage provider, or otherwise subject to the New Zealand Privacy Act 2020, we shall ensure that such entities are subject to similar levels of privacy protection as New Zealand, alternatively, we will require the third party to protect your personal information in a way that provides comparable safeguards to those in the New Zealand Privacy Act 2020.
If we believe that there has been a privacy breach, then we will identify the breach and take reasonable steps to minimise any harm caused by the breach. Where we believe any breach of privacy poses a risk of serious harm or is likely to cause serious harm, then we are required to notify the Privacy Commissioner and affected parties.
Where you believe that there has been a breach in relation to your privacy, then please contact us as soon as possible. Our Privacy Officer’s contact details are set out at the end of this Policy.
If you are not satisfied with the way we have dealt with or resolved your complaint then you can escalate this by contacting the Privacy Commissioner at any time:
You are entitled to ask whether we hold any personal information about you, access any personal information that we hold about you, and request the correction of any personal information held by us.
If you wish to access or correct personal information held by us then please contact our Privacy Officer on the details set out below.
We reserve the right to change this Policy from time to time as we see appropriate. In the event we do amend this Policy, we will post the revised version on our website and use reasonable endeavours to draw your attention to the amended policy. The most recent version of this Policy will apply from its effective date.
Your privacy is important to us, if you have a general privacy enquiry or complaint about a privacy breach then please contact our Privacy Officer Greg Dunn at [email protected].