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 to 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, or posted material.
- If you contact us, we may keep a copy of the correspondence.
- Details of transactions you carry out with our team or using our technology including the fulfilment of these transactions.
- Details of your visits to our websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources you access.
- We may also ask you to complete surveys we use for research purposes, although you do not have to respond to these requests.
In addition to the above, Covenant branches are under video and camera surveillance. Images of Covenant staff and clients may be collected when entering Covenant branches. These images may be used by Covenant in connection with the security of its branches 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 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 and to report aggregate information for our advertisers. This is statistical data about our users' browsing patterns and actions, and does not identify any individual.
How does Covenant use your information?
We may use your information:
- To establish your requirements and provide the appropriate Services;
- To set up, administer and manage our Services;
- To understand your needs and improve our Services, including training and developing our staff and representatives;
- For the security of our staff and clients;
- For any other use you authorise;
- For internal research purposes;
- 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.
- Customer research organisations, solely for the purpose of service improvements, however, not for direct marketing purposes.
- Intermediaries including your agent, adviser, broker, a representative acting on your behalf, or our authorised representatives and our agents.
- 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, and marketing material.
- 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.
Additionally, if you have not opted out of receiving marketing material from us, we may also provide your contact details to carefully selected third parties who we reasonably believe provide products or services that may be of interest to you, or who have contracted with us to keep the information confidential, or who are subject to obligations to protect your personal information.
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 in order to facilitate a transaction on your behalf.
- In instances where we may share your personal information overseas, this will only occur when we believe that the overseas company will protect your personal information in a way that provides comparable safeguards to those in this Act.
In instances where we may share your personal information overseas, this will only occur when we believe that the overseas company will protect your personal information in a way that provides comparable safeguards to those in this Act.
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. In some circumstances, we are able to deny your request for access to personal information. If we deny your request, we will tell you why.
We will normally get back to you with a response within 20 working days. If accessing your personal information will take an extended period of time, we will inform you of the likely delay. For more detailed requests for access to information, an administration fee may be charged to cover the associated cost of supplying this information, but we’ll discuss this with you before we go ahead.
If you believe the information we hold about you is incorrect, you may ask for it to be corrected. If we decline to correct the information, you may request a statement is attached to the information that a correction was sought but not made.
Personal Information Storage
We will endeavour to store personal information on secure servers and encrypt any passwords and transactions details you provide to us.
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.
We would like to use and disclose your personal information to keep you up to date with the range of products or services available from us. Generally, we will use and disclose your personal information for our marketing purposes and may use your information in other aspects of our business.
If you do not want us to use and disclose your personal information for marketing purposes, please advise us of this during the on-boarding process or contact us by:
- Telephoning us on 0800 87 87 82;
- Email on email@example.com;
- Writing to us at Covenant Trustee Services, PO Box 4243, Shortland Street, Auckland 1140.
- Email on firstname.lastname@example.org;
- Telephoning us on 0800 87 87 82; or,
- Writing to us at Covenant Trustee Services, PO Box 4243, Auckland 1140.