Sam McSorley Limited (we, us, our) complies to the highest standard with the New Zealand Privacy Act 2020 (the Act) and the Privacy Principles in its dealings with personal information as it relates to our clients or other individuals. We also treat any applicable personal information in line with the Health Information Privacy Code 2020.
We care deeply about the information you share with us, and these are the rules by which we operate in relation to your information.
Personal information is information which can used to identify an individual (i.e., a natural person) and as an agency, we collect and store personal information to operate as a lawful business within New Zealand.
This policy outlines how we will collect, use, disclose and protect your personal information and does not limit or exclude any privacy rights you may have in the Act or at common law.
Further information on your privacy rights can be found below:
- The Office of the Privacy Commissioner
- The Privacy Act 2020
- Health Information Privacy Code 2020
Changes to this policy
This policy may change from time to time; if we update this policy, we reserve the discretion to advertise this change or access on our website or through other communication mediums.
How we collect your personal information
We collect personal information about you from:
You, when you provide personal information to us. This may include your IP when you visit our website, any information from or when you contact us by phone, electronic or digital means. This includes name, address, email address, date of birth, gender, bank details and personal health information if provided to us.
Third parties, where you have authorised this or it is the most practicable way to collect your personal information.
The public sphere, where personal information is available publicly and it helps in the provision of our supply of products and services to you, then we will collect it to the extent required to operate in our ordinary course of business.
Where possible, we will always collect your personal information from you.
Collection over the internet
We are not responsible for any transient capture of your personal information if you arrive at our website from another agency’s website.
Sam McSorley uses Google Advertising. By using the Ads Preferences Manager, you can opt out of Google Analytics for Display Advertising and customize Google Display Network ads.
Why we collect your personal information
We collect your personal information in order to operate, as a part of our ordinary course of business, in the provision of supply of products and services to New Zealand individuals and entities. For example, to action or respond to your inquiry, to administer, evaluate and improve the site, and to improve our services. We only disclose your personal information for the operation and maintenance of law and only to the extent required.
Disclosing your personal information
We will never disclose personal information where we do not have to by operation of law (e.g., the New Zealand Police). We must disclose in certain circumstances such as by the operation of law (e.g. the Inland Revenue or New Zealand Courts) or by an authority within the Act or any other Act.
Where we are required to disclose your personal information by the operation of law, to the extent possible, we will redact and withhold all personal information outside the scope of the request.
How we store your personal information
We store your personal information securely. All personal information is sensitive information:
If we hold your personal information in a physical medium, like on paper or within a folder, then it is protected by multiple security measures including a 24/7 monitored security system within our secure offices and is handled in accordance with our internal procedure, for example in the transportation of personal information.
If we hold your personal information in a digital medium, like email or our digital storage system, then it is protected by measures like simple password protection as well as our information security maintained by our IT security providers.
We always take reasonable steps to keep your personal information safe from loss, unauthorised use or any other unauthorised disclosure.
How we handle and use your personal information
We will use your personal information:
- To verify your identity and meet obligations under New Zealand law.
- To provide our services to you.
- To market our services to you.
- To communicate with you for the purposes of complaints and billing.
- To conduct research and analysis; and
For any other purposes connected with the operation and supply of our products and services within New Zealand.
We handle large amounts of personal information, so it is necessary to use unique identifiers to
catalogue within our data systems. Our unique identifiers are just that, unique and we will take
reasonable steps to change any identifier which is used by another agency where possible.
Sam McSorley is the Privacy Officer as an agency under the Act.
How you can request, access or correct your personal information
We take your privacy seriously therefore we will take reasonable steps to protect your personal information we hold against misuse, loss or unauthorised access or disclosure.
When we hold your personal information, we commit to a transparent process around your access and the continuing authenticity of your personal information:
You have the right to:
- find out from us whether we hold personal information about you.
- access that information, and if applicable
- request corrections to that information.
If your request for access falls within the scope of any of the grounds of refusal within Part 4 of the Act, then we will redact the information only to the extent necessary to protect those other interests.
If your request for correction is reasonable and we are able to change your personal information, we will make that correction as soon as we practicably are able to do so.
Depending on the volume of personal information we hold, or the medium it occupies, it may take time for access, replication or correction of that personal information. We ask you for your patience in these situations.
In your request for access or correction, please provide evidence of your identification and the details of your privacy request. We reserve the discretion to require additional information to prove your identity.
To request access or correction of your personal information, simply contact: firstname.lastname@example.org
The General Data Protection Rules and how they relate to this policy
Sam McSorley will handle personal information lawfully in compliance with the EU General Data Protection Rules (GDPR) where necessary and applicable. Where personal information constitutes “personal data” from individuals within the European Economic Area (EEA) and it is captured within the ambit of the GDPR, we will only collect on legal grounds to the extent necessary, and only with positive and active consent, and to perform any lawful function or contracts we may have, or otherwise where we have a legitimate interest in the information collected. You also have additional rights as an individual within the EEA in certain circumstances such as withdrawal of consent, portability of your data to third parties, to object us processing your personal data and the right to erasure (the right to be forgotten).
To discuss any issues about your personal data and our collection and processing procedure, simply contact: email@example.com
How we maintain this policy
This policy will be updated yearly and on an ad-hoc basis where major privacy developments in law or guidance render any part of this policy redundant or ineffective.
If you believe your privacy has been breached or if you have concerns about your private information held with us, you can contact us on: firstname.lastname@example.org
If you do not agree with a decision regarding access to your personal information. To manage such issues, our organisation has an internal dispute resolution process for complaints, and we would like to hear from you in the first instance to help.
We will review your concerns about your privacy and if we cannot resolve it, you may contact the Privacy Commissioner, either by phone on 0800 803 909 or by mail to P.O Box 466, Auckland 1140.