At Public Trust we take our obligations under the Privacy Act 2020 seriously. This Privacy Policy reflects our commitment to respecting and protecting all personal information that we hold about you.
You can find out all you need to know about the personal information we collect, use and share about you, as well as your rights in relation to that information in this document. This policy applies to Public Trust and all its subsidiaries.
This policy will be reviewed regularly, and we might make some changes from time to time. You will always find the current version on our websites at www.publictrust.co.nz and www.publictrustonline.co.nz
This policy applies to the personal information we hold about identifiable ‘living individuals’ who include:
Public Trust customers and potential customers
beneficiaries of estates or trusts that we administer
other ‘associated people’ (such as shareholders and company directors) of Public Trust customers
applicants for charitable grants or cadetships at Smedley Station
candidates for employment with Public Trust; and
other persons who voluntarily provide Public Trust personal information, for example as part of an online survey.
Public Trust does not have any law enforcement responsibilities, and does not gather any information for these purposes.
In most cases we will collect your personal information directly from you, such as when you:
apply for a product or service, for example on an application form
contact or connect with us online, including via social media
use our online services
ask us for information
make an appointment to visit us.
Under the Privacy Act we may also collect information about you from other people or organisations. For example, you might have appointed an agent or attorney to act on your behalf, or authorised someone else to supply your information. Where we have notified you, we may also collect information from service providers about how you interact with our digital content.
From time-to-time Public Trust may also collect personal information through searching publicly available information (media reports, social media, etc.) or by engaging third parties to undertake such investigation on our behalf in accordance with privacy and other legal and regulatory requirements. This primarily occurs to assist with:
performing our fiduciary obligations (for example, to locate a beneficiary of an estate); or
detecting or investigating potential threats to the physical security of our staff.
The personal information collected depends on the nature of your relationship with Public Trust. Though generally, at a minimum we will collect your name, contact details and date of birth:
If you contact us online, we may collect information from service providers about how you interact with our digital content.
If you are a customer, we may require identity documents, and information about your family and financial circumstances.
If you are a job applicant then we need information that is relevant to determine whether you are suitable for the role in question; for example, your education and employment history. We may also collect demographic information for reporting purposes.
If you are an applicant for a charitable grant or for a cadetship at Smedley Station, then we need information that is relevant to assess your application; for example, personal statements, educational and financial information. We may also collect demographic information for reporting purposes.
The personal information we specifically ask for is necessary to enable us to provide you with services or to assess your application. If you do not provide the personal information requested, we may not be able to provide you with the service, continue with an existing service or assess your suitability for employment, cadetship or for a charitable grant.
We collect, use and store your personal information mainly to provide you with products, services, and information that you have asked for or to otherwise meet our fiduciary obligations.
For example, if you are a customer, we may use your personal information:
to administer, monitor and manage your Public Trust products and services
to process your requests for information
to develop and improve our products and services (using feedback and other information that we have received about or from you)
to identify and contact you about events and other products and services that might interest you (these could include events, products and services offered by other organisations in conjunction with Public Trust)
as part of ‘data matching’ activities, in which we compare your information with information that is public and/or held by someone else (for example, using a service provider to confirm your postal address details)
to meet our legal obligations, as well as obligations imposed by governmental, judicial or regulatory entities or authorities in other jurisdictions, and entities that supervise or regulate Public Trust
to locate beneficiaries or other third parties as required to perform our business.
We may also use your personal information to communicate with you about:
your current Public Trust products and services
other products or services (including those of other organisations) that we believe may interest you
general marketing or promotional activities.
We use your information to assess your suitability for the job vacancy, charitable grant or cadetship that you have applied for and to meet our legal obligations. Anonymised demographic information may also be used for reporting purposes.
There may be times when we may need to share some of your information to help us provide you with the services requested, or meet our legal obligations – such as:
with your agent, attorney or authorised signatory
with other entities or companies within the Public Trust group
with people or organisations that undertake services for us (such as where we ask a market research provider to get your feedback on our products and services or carry out ‘data matching’ for us)
when we need legal or other professional advice
to help meet obligations imposed by governmental, judicial or regulatory entities or authorities in other jurisdictions, and entities that supervise or regulate Public Trust.
For example, we may disclose some of your personal information to selected third parties to help us comply with the Anti-Money Laundering and Financing of Terrorism Act 2009, and to ensure that we act according to the Terrorism Suppression Act 2002; if we have reasonable grounds to believe that a transaction or proposed transaction may be relevant to an investigation or prosecution of someone for a money laundering offense; and to help us comply with the United States Foreign Account Tax Compliance Act and/or any agreements between the New Zealand Government and other countries’ governments.
Where we disclose your information to a service provider, we make sure they are aware of the importance we place on protecting your privacy. Personal information may be processed by service providers in overseas jurisdictions. Those providers have contracts in place to ensure sub processors apply comparable privacy standards.
Service providers are required to keep your information confidential. Generally, service providers may only use your information for the purpose for which it was supplied, though in some cases, service providers may also use your information for product improvement and development purposes.
In all other cases we will only disclose your personal information if it is permitted under the Privacy Act.
We may provide your personal information to relevant third parties for the purpose of assessing your suitability for the job vacancy, charitable grant or cadetship; to meet our legal obligations; and for reporting purposes.
We will take reasonable care, or require any third-party as the case may be, to keep your personal information safe from loss, misuse and unauthorised disclosure.
Customers only: Public Trust stores your hard-copy personal information within our Customer Centres or in outsourced secure, off-site storage. We store your electronic-copy personal information within New Zealand hosted data centres.
The law requires us to destroy your personal information if we no longer require it for the purpose for which we collected it, or if it is no longer required to meet our legal requirements. If we have to keep it to meet our legal requirements, we will continue holding it for the legally required timeframe.
We will not use or disclose your personal information without taking reasonable steps to check that it is accurate and complete.
You are welcome to ask for, have access to, and check the personal information that we hold about you – and if you believe that any of it is incorrect, you can ask us to correct it. (Note: if we choose not to make the correction, you can ask us to attach to the information a statement of the correction you wanted).
We can only refuse you access to your information in very limited circumstances, such as when disclosure would involve an unjustified breach of someone else’s privacy.
Customers only: Chat history is stored in our systems and may include personal information. Where the chat history includes personal information, it may be linked to existing customer records.
In the unlikely event of a privacy incident, we will take the following steps in dealing with it.
Contain: we will contain the incident to minimise its impact – for example, we will contact the inadvertent recipient of the personal information and request they return or destroy the information.
Assess: we will assess the incident by gathering the facts and evaluating the risks, and where possible, take action to remediate any risk of harm.
Notify: we will notify you and report to the Privacy Commissioner any privacy incidents that have caused serious harm, or are likely to do so, in accordance with the Privacy Act 2020.
Prevent: review the incident and consider what actions can be taken to prevent future occurrences.
If you would like more information, have any questions or would like to provide us with feedback about this policy, please feel free to:
Phone us on 0800 371 471
Your call may be recorded. We use these recordings...
to improve our service
to ensure that we have accurate records of our calls
for employee training purposes.
Email us at [email protected] or
Visit your nearest Public Trust Customer Centre or
Write to us at:
The Privacy Officer
Public Trust
PO Box 1598
Auckland 1140
If you make a privacy complaint, we will follow it up through our internal complaints process. If you are not satisfied with the outcome, you can contact the Privacy Commissioner on 0800 803 909 or visit www.privacy.org.nz.
Please note that this Privacy Policy may be updated from time to time without notice.