This Compliance Plan interprets the Privacy Act 1993 and the Health Information Privacy Code 1994.
It is intended for use by:
- Parent to Parent National Office
- Parent to Parent Groups
- Accredited Parent to Parent Support Parents
Compliance with the Privacy Act is based on twelve principles. The Privacy Act, its principles, and the Health Information Privacy Code are much more extensive than this brief Compliance Plan. This Plan is intended to be a brief guide only in the application of the privacy principles to Parent to Parent..
All officers handling personal information, as well as their controlling committees, must be aware of their responsibilities under the Privacy Act.
Should you have any queries regarding compliance with the privacy principles, please direct your questions to the Privacy Officer through the National Office.
Parent to Parent New Zealand Inc.
PO Box 234
Waikato Mail Centre.
Telephone: 07. 853 8491
Privacy Act Compliance Plan
Principle 1 • Purpose of collection of information
No personal information shall be collected by Parent to Parent groups, National Office, or Support Parents unless that information is necessary to enable a lawful function or activity of Parent to Parent to be carried out.
Principle 2 • Source of personal information
Personal information can only be obtained directly from the individual concerned unless:
- the individual concerned authorises collection of the information from someone else, or
- the individual concerned is unable to give his/her authority, and that Parent to Parent, having made the principal caregiver aware of Principle 3, collects the information from the principal caregiver. This means that information can be obtained from the principal caregiver of a child with special needs if that child is unable to give that information themselves.
Principle 3 • Collection of information
When Parent to Parent groups, National Office, or Support Parents collect personal information direct from the individual concerned or from the principal caregiver, they must ensure that the person supplying the information is made aware of:
a) the fact that the information is being collected
b) the purpose for which the information is being collected the intended recipients of the information
c) the name and address of the group/office collecting the information, and the group/office/person who will hold that information
d) the right of access to, and correction of, that information.
With regard to item (c) above, the intended recipient will generally be Parent to Parent rather than an individual within the organisation.
Principle 4 • Manner of collection of personal information
Personal information cannot be collected by Parent to Parent:
- by unlawful means
- by unfair means
- by means which intrude to an unreasonable extent on the personal affairs of the individual concerned. “Unreasonable intrusion” includes consideration of:
- Physical privacy (e.g. public area), especially when sensitive information is being collected
- Streamlining the collection process so that sensitive questions are not repeatedly asked
- Ensuring that people who collect information have training about privacy issues others present.Some individuals may specifically wish members of their family or whanau to be present (or absent) when information is being collected
- Cultural sensitivities of the individual concerned
- Particular concerns or preferences expressed by the individual.
Principle 5 • Storage and security of information
Parent to Parent groups, National Office, and Support Parents must ensure that:
- Personal information held is kept in secure storage
- Reasonable safeguards are taken to protect personal information against loss, unauthorised access, use, modification or disclosure
- That destruction of unnecessary data ensures that the information cannot be retrieved or used again
Where information is no longer necessary, it must be disposed of in a manner that preserves the privacy of the individual. Destruction must be total.
Principle 6 • Access to personal information
Principal caregivers and individuals concerned are entitled to access to information held about them.
This information must be provided as soon as practicably reasonable, and in no case longer than 20 working days after the request was made.
When providing personal information, ensure that access is not given on personal information held on any other individual.
There are some legitimate reasons for declining to provide personal information to the individual concerned:
a) If disclosure would involve the unwarranted disclosure of the affairs of another individual
b) If disclosure would involve a breach of promise to the person who supplied the information
c) If disclosure would be likely to prejudice the physical or mental health of the individual
d) If, in the case of an individual under 16, disclosure would be contrary to that persons interests
e) If disclosure would breach legal professional privilege
f) If the request is frivolous, or the information requested is trivial
Principle 7 • Correction of personal information
Principal caregivers or the individuals concerned may request Parent to Parent to correct information held about them. If Parent to Parent declines to change the information held, the principal caregiver or individual concerned may request that a statement setting out their version of the facts be attached to the information held.
Parent to Parent should only decline a request for change of information held if they believe that the change requested is not accurate, up to date, complete, or is misleading.
You will need to advise the person requesting the change of the reasons for your refusal, and of their right to complain to the Privacy Commissioner.
Principle 8 • Accuracy of personal information to be checked before use
Parent to Parent groups, National Office, and Support Parents must not use any personal information held without taking reasonable steps to ensure that the information held is accurate, up to date, complete, relevant, and not misleading.
Support Parent information is generally updated annually, but we should remain sensitive to the fact that circumstances may change between updates.
Principle 9 • Retention of personal information
Personal information must not be kept any longer than the purpose for which the information was collected in the first place.
Information held regarding a family being supported must be destroyed when it becomes obvious that, that family no longer requires support.
Information held regarding a Support Parent must be destroyed when that person ceases to be a Support Parent in that particular group. When a Support Parent moves to another area, personal information can only be passed on to another Parent to Parent group with the consent of the Support Parent concerned.
Principle 10 • Limits on use of personal information
Personal information cannot be used for any purpose other than that for which it was initially collected except where:
a) the principal caregiver or individual concerned authorises use for other purposes
b) the information will not identify the individual concerned
This effectively allows personal information held to be used for statistical and research purposes provided information is not published in a form that could reasonably be expected to identify the individuals.
Principle 11 • Limits on disclosure of personal information
Personal information held must not be disclosed to any other person or agency unless:
a) the disclosure is one of the purposes for which that information was obtained. This allows for information from a parent requesting support to be passed on to a Support Parent
b) the disclosure has been authorised by the individual concerned or their representative
c) the disclosure is necessary to prevent or lessen a serious threat to the life or health of the individual concerned or another individual. You will need to positively identify the person requesting information to establish their entitlement to it. Special care will need to be taken with requests for information by telephone.
Principle 12 • Unique identifiers
Parent to Parent shall not use unique identifiers unless it is necessary to carry out its functions efficiently. Due to the sensitive nature of information held, it is considered necessary to assign unique identifiers to Support Parents. These identifiers are issued by National Office.