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PRIVACY POLICY

As a business that collects and holds personal information about our clients, we must comply with Code Standard 5 of the Code of Professional Conduct for Financial Advice Services and adhere to the Privacy Act 2020 and its principles.
We only use client information for the purposes that we collect it for, and we do not underestimate the importance of keeping personal information secure during the collection, use, or authorised disclosure when providing our services.

Our Key Obligations

Ensuring all information is kept secure, whether physical or electronic, and can only be accessed by authorised people
Only collecting information that is needed to provide our services
Explaining what personal information will be used for when it is collected, and informing the client of their right to access, correct and/or revoke their information at any time
Only using personal information for those purposes that have been authorised by the client
Returning or securely disposing of client information once it is no longer needed
Reporting any data breach that may cause harm to the client(s) to the Privacy Commissioner and affected individuals
Ensuring that all personal information that is collected is protected by safeguards that meet the requirements of New Zealand’s privacy laws, including all information that is transferred offshore

The Privacy Commission provides the following definition on their website:
Personal information is any piece of information that relates to a living, identifiable human being. People's names, contact details, financial health, purchase records: anything that you can look at and say, “this is about an identifiable person.”
It does not need to include the client’s name and does not need to be secret or sensitive in nature. It is any information that could be used to identify an individual.

When meeting a client for the first time, we discuss the services that we offer and explain the process followed when providing advice. This involves asking the client to complete a Personal Information Authority & Declaration that outlines:
- The purpose for collecting the client’s personal information
- What the information will be used for when providing the service
- Permission to obtain information for assessing suitability of products and/or providers
- Consent to send electronic marketing material
- Authorisation to share the information with a third party for the purposes of quality assurance, complaint management, or to meet regulatory obligations
- The client’s right to access, review and correct any information that we hold about them
We do not provide any personal information, either verbal or written, without explicit consent from the client.

When files are not being worked on, they are filed away so that there is no unauthorised access to a client’s personal information
All computers, laptops, electronic devices, and software programmes are password protected so that they can only be used by authorised individuals
We follow recommended practices when it comes to creating passwords and do not share or reuse passwords across multiple programmes
We only respond to emails or share information once we are able to verify that we are communicating with the client requesting the information

All electronic devices and software programmes are password protected
We only use internet connectivity or email services where there is a secure WiFi network and an inability for others to access data
We only use trusted third-party service providers that abide by the Privacy Act 2020 and include appropriate assurances in their business agreements or contracts
Our business uses a Customer Relationship Management platform (CRM) provided by The Adviser Platform. Details of how The Adviser Platform fulfils its obligations under the Privacy Act 2020 are included in The Adviser Platform (TAP) Data Privacy & Protection Overview, available on their website
Where laptops or electronic devices are unaccounted for, we update passwords for all applicable software programmes to prevent the chance of unauthorised access
The CRM provided by The Adviser Platform only allows a user to be logged into a single device at any one time and all users are logged out after a period of inactivity

We only use information for the purposes it is intended and only after the client has given authorisation to do so.
Client information may be used for the following purposes:
- Determining suitability of products for the client’s needs
- Applying for products supplied by one of our providers
- Underwriting requests from providers when making an offer of terms
- Submitting claims to a provider on the client’s behalf
- Quality assurance purposes
- Third-party compliance services
- Regulatory requests
- Third-party offerings that are necessary in the provision of our services to the client
- Electronic marketing (where consent has been given), with the ability for the client to unsubscribe from further electronic marketing material
All personal information will be returned to the client and/or securely destroyed once it is no longer required and at the client’s request.
We require the information to be held on file for 7 years following the end of the client relationship.

Where a breach of privacy is suspected, it is reviewed for potential harm to determine what immediate action needs to be taken to prevent any further breach.
If it is concluded that a breach of privacy has occurred, we notify the affected individuals of the breach and inform them how their privacy has been breached, what steps we are taking to limit the breach, and confirm that we will be reporting the breach to the Privacy Commissioner.
We then notify the Privacy Commissioner using the NotifyUs function on the website of the Privacy Commission:
- https://www.privacy.org.nz/privacy-for-agencies/privacy-breaches/notify-us/
Where it is determined that there has been a breach of privacy, or there was the potential for a breach to have occurred, it is recorded in our Incident & Breach Register and treated in line with our Material Issues and Reporting Policy.

We have a nominated Privacy Officer who is responsible for understanding our responsibilities under the Privacy Act 2020.
We review all advice files for accuracy and compliance with our obligations under this policy.
We also engage a third party to review our advice practices on a half-yearly basis to ensure ongoing compliance.