Covenant Trustee Services ("Covenant", "we", "us", "our") complies with the New Zealand Privacy Act 2020 (the Act) when dealing with personal information. Personal information is information about an identifiable individual (a natural person).
Covenant recognises the importance of safeguarding clients’ personal information. This policy sets out how we will collect, use, disclose and protect your personal information.
The collection of your personal information and/or your client’s personal information is essential to enable us to conduct our business of offering and providing you with our range of products and services (“Services”). This information may be confidential or sensitive, so we think it is important you know how we treat this information.
What information does Covenant collect?
We are committed to our obligations under the Act relating to collecting personal information. In order to provide our Services, it is essential we collect and process some personal information.
The information we collect can include:
- Information you provide when using our Services. This includes information provided at the time of registering or utilising any of our Services, interacting with our staff.
- Correspondence or contact information collected during the interaction.
- Details of transactions carried out with our team or using our technology, including the fulfilment of these transactions.
In addition to the above, Covenant offices are under video and camera surveillance. Images of Covenant staff and clients may be collected when entering Covenant offices. These images may be used by Covenant in connection with the security of its office and on request (but only in accordance with the Privacy Act 2020) may be provided to law enforcement and government bodies, insurers and third parties who may provide Covenant with services from time to time.
The images are held securely, and access is restricted to authorised individuals only and for the purposes set out above.
We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration.
How does Covenant use your information?
We may use your information:
- To set up, administer and manage our Services;
- For the security of our staff and clients;
- For any other use you authorise;
- To ensure the secure and proper operation of our websites;
- To protect our rights;
- To communicate with you;
- To verify your identity.
We are required by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 to collect your personal information to verify your identity. We may be required by the Foreign Account Tax Compliance Act and OECD Common Reporting Standard to collect and report certain information about an account holder’s tax residency.
Therefore, the collection of certain personal information will be mandatory for particular Services you require.
Sharing your information
We use and disclose your personal information for the purposes we collected it.
We may use and disclose your personal information for a secondary purpose only if the secondary purpose is directly related to the purpose of collection.
When necessary and in connection with the purposes listed above, we may disclose your personal information to:
- Subsidiaries, related companies or joint venture companies where required or authorised under our relationship;
- Information technology providers, including hardware and software vendors and consultants such as programmers, for the development or delivery of our Services only;
- Accounting and financial specialists, trustees associated with superannuation funds, government, law enforcement or statutory bodies, professional advisors, administration or business management services;
- Printers and mail service and delivery providers for the mailing of statements;
- Imaging and document management services;
- Electronic Verification: if you choose to have your identity and address verified by electronic verification, we will share your personal information with APLYiD, a provider of electronic identity verification services;
- Regulators including the Financial Markets Authority, Reserve Bank of New Zealand and the Registrar of Retirement Villages. When disclosing personal information to regulators, Covenants staff must disclose under the relevant legislation giving Covenants protected disclosure;
- Our complaints provider – FSCL.
There are also instances where we may have to send your personal information overseas or collect personal information from overseas. These instances include:
- When you have asked us to do so;
- When we are authorised or required by law to do so, including in response to any order from any regulator or court in any jurisdiction;
- When we have outsourced a business activity or function to an overseas provider with whom we have a contractual arrangement;
- Certain electronic transactions;
- When it is necessary to facilitate a transaction on your behalf.
When disclosing information to an overseas person, the jurisdiction in which the overseas person resides must be subject to privacy laws that, overall, provide comparable safeguards to those in the Act or are subject to a prescribed country's privacy laws. Prescribed country means a country specified in regulations.
You are entitled to obtain confirmation from us that we hold personal information about you and can request access to the personal information by contacting us. When a request is received, it is referred to the Privacy Officer, who will respond within 20 working days. If accessing your personal information will take an extended period of time, we will inform you of the likely delay.
If you believe the information we hold about you is incorrect, you may ask to correct it.
Personal Information Storage
We will take all reasonable steps to ensure that the information we collect or disclose is accurate and stored in a secure environment. We will endeavour to store personal information on secure servers and specified email boxes.
We will use every security precaution reasonably available to us to maintain the security of your personal information. However, there are risks inherent in transmitting and storing data online. As such, we cannot guarantee data sent or stored electronically will be secure, and any information provided to us is at your own risk.
We will endeavour to contact you if any security breaches compromise the security of your personal information.
- Email on firstname.lastname@example.org;
- Telephoning us on 0800 746 422; or,
- Writing to us at Covenant Trustee Services, PO Box 4243, Auckland 1140