This Policy outlines the obligations Lane Neave has in managing the Personal Information it holds about its clients, potential clients, contractors and others. Lane Neave is bound by the Privacy Act 1993 (Privacy Act) and the privacy principles set out in that Act.
Why does Lane Neave collect personal information?
Lane Neave collects personal information in order to conduct its business, to provide and market its services and to meet its legal obligations.
Who does Lane Neave collect personal Information about?
The type of information Lane Neave may collect and hold includes (but is not limited to) personal information about:
- clients, business associates and potential clients and their employees;
- suppliers and their employees;
- prospective employees, employees and contractors; and
- other people who come into contact with a member of Lane Neave.
What kind of personal Information does Lane Neave collect?
In general, the type of personal information Lane Neave collects and holds includes (but is not limited to): names, addresses, contact details, occupations and other information which assist it in conducting its business, providing and marketing its services and meeting its legal obligations.
In most cases, if personal information that Lane Neave requests is not provided, it may not be able to supply the relevant product or service.
How does Lane Neave collect personal information?
Lane Neave will generally collect personal information by way of forms filled out by people, face-to-face meetings, interviews, business cards, telephone conversations and from third parties.
In some circumstances Lane Neave may be provided with personal information about an individual from a third party, for example a report provided by a medical professional or a reference from another person.
How might Lane Neave use and disclose your personal information?
Lane Neave may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.
In general, Lane Neave uses and discloses your personal information for the following purposes:
- to conduct its business;
- to provide and market its services;
- to communicate with you;
- to purchase from you;
- to comply with its legal obligations, and
- to help manage and enhance its services.
Who might Lane Neave disclose your personal information to?
Lane Neave may disclose your personal information to:
- other companies or individuals who assist Lane Neave in providing services or who perform functions on their behalf (such as mailing houses, specialist consultants and barristers);
- courts, tribunals and regulatory authorities, and
- anyone else to whom you authorise them to disclose it.
Lane Neave also collects personal information from these organisations and individuals, and deals with that information in accordance with this Policy.
Disclosures related to AML/CFT processes
Certain personal information (“AML information”) is obtained to enable Lane Neave to check and confirm your identity and to enable it to undertake other identity related checks. Lane Neave does this for the purposes of ensuring that it can act for you or your organisation on any matter where Lane Neave’s obligations at law, and in particular its obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and associated regulations (“AML/CFT”), require these checks and confirmations before Lane Neave can act for you or your organisation on that matter. Lane Neave uses AML information for the following identity related checks:
- to check that the AML information matches the information in the relevant government databases, e.g. passport databases. This includes accessing the New Zealand and Australian document verification services. Lane Neave has arrangements in place to work with third parties to use the third party systems to undertake the information matching process. These third parties include Green ID Limited, VIX Verify Pty Limited, APLY Limited (trading as APLYiD) and Data Zoo Pty Limited. Lane Neave provides an information match request, and receives an information match result and other information match data from the service. The information involved will be transmitted to and from Australia when accessing the Australian document verification service
- to check we are not prohibited from acting for you under the AML/CFT. Lane Neave accesses a number of other databases, many of which are outside of New Zealand, in order to undertake these checks. We may also use third parties, including APLYiD, to facilitate such access which occurs in a similar manner.
All such use of the AML information when accessing those databases is limited to compliance with our obligations under the AML/CFT and any other applicable law.
Lane Neave can only undertake these checks with your consent, which is given by signing a consent form or by using any electronic service we make available for that purpose. You may withdraw your consent at any time prior to us undertaking our identity check process. To do so, please contact firstname.lastname@example.org.
We may provide a copy of the form we collect or, where an electronic services is used, any online form and the electronic consent provided, to the third parties used if they require it to evidence your consent in the information matching process they undertake for us.
Management of personal information
The Privacy Act requires Lane Neave to take reasonable steps to protect the security of Personal Information. Lane Neave’s personnel are required to respect the confidentiality of personal information and the privacy of individuals.
Lane Neave takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records.
Where Lane Neave no longer requires your personal information for a permitted purpose under the Privacy Act, they will take reasonable steps to destroy it.
How does Lane Neave keep personal information accurate and up-to-date?
Lane Neave endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. They encourage you to contact Lane Neave to update any Personal Information held about you. Contact details are available on the following page laneneave.co.nz/contact.
You have the ability to seek access to your personal Iinformation. Subject to the exceptions set out in the Privacy Act, you may seek access to the Personal Information which Lane Neave holds about you by contacting CEO, Peter Dwan.
Lane Neave will require you to verify your identity and specify what information you require. A reasonable fee may be charged for providing access. Lane Neave will advise you of the likely cost in advance.
Updates to this policy
This policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this policy can be obtained by contacting Lane Neave’s CEO, Peter Dwan.
If you have any questions about privacy-related issues please contact Lane Neave directly.