Privacy Policy
Intent
We collect and manage a range of personal information. We treat it respectfully and carefully, are open with people about why we collect it, how it is held and stored, what we do with it and rights of access. We comply with regulatory standards and only release and share information in accordance with our policies and the law. Wherever possible, we forewarn and seek consent from people about when their information may have to be disclosed.
Definitions
“Personal information” is information about an identifiable, living human being. It includes health information and all other types of information whether paper, digital, or electronic which identifies a person.
“Privacy Officer”- see here for role of Privacy Officer.
Responsibilities
Management will:
- act as or delegate the responsibilities of Privacy Officer to kaimahi/staff
- monitor and manage our information management system
- monitor and manage our privacy and data breach risks with appropriate safeguards
- manage privacy and data breach incidents.
The Privacy Officer(s) will:
- monitor the organisation’s compliance with this policy and the Privacy Act 2020
- assist with privacy-related training of staff/volunteers
- liaise with the Office of the Privacy Commissioner as necessary.
- support staff and volunteers when dealing with privacy-related issues.
Saff/kaimahi and volunteers will comply with this policy.
Requirements
When and how we collect personal information
Personal information will only be collected when necessary for service provision and business purposes.
Information will be collected in a way that is sensitive to a person’s culture, age, abilities, level of understanding and circumstances.
Informed Consent will be obtained and all due care taken to ensure the person understands the reasons for collecting the information, how and when it will be used, stored, accessed, and shared, and their rights to access and correct it (evidenced by a Privacy Consent form or equivalent.)
Source of personal information
If non-identifying information would achieve the same purpose as personal information, non-identifying information will be collected and used instead.
Where possible, personal information will be collected directly from the person concerned or their representative. When personal information is collected from a third party or via an AI tool, reasonable steps will be taken to check accuracy (eg check with the person whose information it is; check reliability of AI tool for that purpose.)
However, if personal information is collected from third parties for evaluative purposes (eg referee checks) it will not be checked for accuracy.
Use of Personal Information
Personal information will only be used or shared for the purposes for which it was collected or as allowed by law (HIPC Rule 10; IPP 10 Privacy Act).
Staff should be “risk-aware” when using people’s personal information.
Privacy risks should be identified and resolved, or if unable to be resolved, discussed with management, before personal information is used. As a general rule, information collected for one purpose cannot be re-purposed. Staff/kaimahi must seek approval from the Privacy Officer/management before using personal information for purposes that are not directly related to the reason(s) for collecting the information.
Personal information will only be shared with overseas organisations and people if the same or better privacy protections apply to the receipt and use of the information in that country as in NZ/Aotearoa. Unless specifically authorised by Bishop Action Foundation, personal information will not be input to AI tools.
Accuracy
Reasonable steps will be taken to ensure that the information we hold or use is accurate, up-to-date, relevant, and not misleading.
A person may request that personal information/ health information we hold is corrected.
If the correction is agreed, it will be documented in the file notes. A printed copy of the change will be given to any other party who holds the notes that require correction. A refusal to correct will be documented in the relevant file with reasons. At the person’s request, the proposed correction will be placed on their file (ie without the correction made).
Before using AI or other tools, we will check for accuracy giving known risks including:
- whether there is a risk of bias in the AI tool (eg if the tool’s outputs are based solely on training data generated overseas)
- how reliable and accurate the tool is known to be when used in the way we intend
- that the personal information generated or collected by Bishop Action Foundation through AI will be able to be corrected (on request by a person or at our initiative).
Access to personal information
A person may request access to their own or their child’s personal information. Unless there is good reason to refuse, we will facilitate access as follows:
- enable access within 20 working days of receiving the request for access
- remove information about another person on their file beforehand (under the oversight of management/their delegate)
- encourage the person to have support while viewing their record (ie for sensitive information)
- inform the person of their right to seek a correction to their personal information.
A parent/guardian’s request to access their child’s personal information may be declined if the child is under 16 years and we reasonably believe that parental access to their health information would not be in the young person’s interests after considering:
- the young person’s views on access
- the nature of the personal information to be accessed
- the parent’s reasons for wanting access
- the importance of privacy to the wellbeing of the young person/rangatahi.
If access is denied, the parent/guardian will be informed of our reasons and their right to complain to the Privacy Commissioner. People will be informed in writing about who will access their personal information.
Recordkeeping
A record will be kept of:
- any request for access and of the date when received
- a copy of the information accessed
- authorisation to access (if given by a person relevant)
- the reasons for delay or refusal (if applicable)
- safeguards implemented to action the request
- other steps taken for the request (eg in relation to parental access).
Privacy Officer
We have a Privacy Officer to support our compliance with the law and policies and to support our interactions with the Office of the Privacy Commissioner (eg about privacy breaches; complaints etc.)
AI and Personal Information
Bishop Action Foundation will take a cautious approach to using AI and be guided by advice from the Office of the Privacy Commissioner about responsible use under the Privacy Act 2020.
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Procedure
Disclosure of shared confidentiality Rangatahi must be informed that any information they give may be shared with other staff who are professionally involved with them.
Staff will not accept information from rangatahi on the condition they keep it to themselves. If rangatahi are unwilling to accept this principle of shared confidentiality within Manna, the confidence will normally be refused.
In rare and exceptional circumstances, particularly sensitive information may be accepted from rangatahi on the condition that staff inform management, rather than share the information with their colleagues.
Within Manna, a request by rangatahi for access to files should be dealt with in the following way:
Process for enabling access and correction of personal information
On receipt of a written request, the chief executive officer will:
- Inform rangatahi that the request will be complied with within 20 working days and make an appointment for the rangatahi to return to see the CEO and file information.
- Inform rangatahi that the original file is the property of Manna and must remain with Bishop Action Foundation but that a duplicate copy of their file may be made available to take away.
- Inform the leadership team of the request; jointly review the file to assess the likely impact of access on the rangatahi; and block out any third-party information or information that may cause another person to be at risk.
- Seek leadership guidance if intending to withhold any part of the file from the rangatahi. The request will be recorded on the database in the young person’s personal notes.
Correction of Personal Information
The staff team and ultimately, the chief executive officer will decide the request. Any agreed changes will be made evident on file.
Rangatahi disagreeing with the information on file
If rangatahi disagree with the information being stored because they feel it is inaccurate or unfair, staff should note the objections and raise them with the Manager with a view to altering the file or adding a statement from the rangatahi to the file.
If it isn’t possible to resolve the objection(s) eg by correction, the client will be advised that they may complain to the leadership team about it.
Compliance
Social Sector Accreditation Standards – Level 2 Client services and programmes 5.0; Governance and management structure and systems Social Sector Accreditation Standards – Levels 3 & 4, Governance and management structure and systems 2.0 NZS 8134:2021 Criteria 2.5, 1.4
Review
Date: November 2024. Next review by January 2026
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