IR-01-22-37552
12 January 2023
J A Harris
[FYI request #21326 email]
Request for information
Thank you for your Official Information Act request of 3 December 2022, asking
Please provide details of any guidelines and copies of any documents that guide
when and why a privacy impact assessment needs to be completed, and how to
complete a privacy impact assessment.
Please provide details of privacy impact assessments developed/completed by
Police. It is Not necessary to provide the content of the assessments themselves,
just the number and subject of the PIA where an assessment was done.
I note that your request for a list of PIAs was subsequently clarified to PIAs completed in
the 2022 calendar year.
In response to your request, please find attached a copy of Police’s TenOne internal
guidance relating to Privacy Impact Assessment and Privacy by Design.
Further, please see below a table of PIAs completed in the 2022 calendar year.
PIA Subject
1.
Ingestion of Sovereign Citizen Information into ArcGIS Enterprise
2.
Ingestion of Persons of Interest data into ArcGIS Enterprise
3.
Ingestion of Gang Activity and Offence Information into ArcGIS
4.
Ingestion of Bail Management data into ArcGIS Enterprise
5.
Arms Information System (AIS) – Release 1
6.
Visitor Management System (VMS)
7.
Hybrid email solution - Microsoft 365
8.
Unstructured text search across NIA attachments and narratives
9.
Rural Lookout Strategic Dashboard ArcGIS Enterprise
10.
Use of body worn cameras (in relation to use of Taser)
11.
Improvement of Mental Health Triage Line
12.
Use of Mail Chimp for tracking stakeholder engagement
13.
Voice of Customer platform use
14.
Trial use of dashcam technology
15.
Employee expense management software
16.
Financial Intelligence Unit Service Delivery Transformation
17.
Use of Citizen Space consultation platform
18.
IMS Photo Manager facial comparison system
19.
Motor Vehicle staff travel remediation project
20.
Personal information management - He Aranga Ake
I trust the information provided addresses your areas of interest.
Ngā mihi
Annabel Fordham
Chief Privacy Officer
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Privacy Impact Assessment and Privacy by Design
Personal information is a strategic Police asset in the delivery of Our Business. Good
stewardship of personal information helps us maintain public trust and confidence.
Completing Privacy Impact Assessments (PIA) and using a Privacy by Design (PbD)
approach go hand in hand to identify and design out privacy risk in Police systems
and processes.
Good stewardship of personal information is enhanced by undertaking a PIA when a
new project or way of handling personal information may affect privacy. Privacy by
Design has an enduring effect – it means systems and processes are built to make it
easier for our people to do the right thing and harder for them to make mistakes.
The PIA template is designed to be straightforward for project teams to complete
and provides an opportunity for substantive comments and explanation of risks and
mitigations. Privacy by Design means considering privacy from the beginning of a
project, making safe information handling part of project thinking and system
design, and integrating it into our systems, tools, services and processes.
What is PIA and PbD
Privacy Impact Assessment (PIA)
This policy outlines the importance of assessing privacy risk in projects and
situations involving change to business processes or new systems and processes.
Completing a Privacy Impact Assessment (PIA) is a methodology to identify, assess
and manage privacy risk.
A PIA should help you to:
• identify impacts (either positive or negative) on the privacy of the public or
Police staff
• understand the privacy risks and document how those risks will be eliminated
or mitigated to an acceptable level
• provide a reference point for future action and review when systems, tools,
services or processes change.
Privacy by Design – a design methodology
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Privacy by Design means considering privacy from the beginning of a project, making
privacy part of project thinking and system design, and integrating it into our
systems, tools, services and processes. The ‘privacy by design’ approach goes hand
in hand with undertaking a PIA - privacy risks are identified early and can be
designed out, or at least partly mitigated to reduce the risk and consequence if the
risk eventuates.
Privacy by Design involves thinking about how Police manage personal information
from collection through to its eventual destruction or disposal. The approach aligns
with the allied concept of ‘Security by Design’.
Privacy by Design ensures we engineer safe information handling practices into our
systems, tools, services or processes for maximum and enduring impact.
Benefits of PIA and PbD
PIA - assessing privacy risk
The PIA process is designed to identify risks or potential risks to the integrity and
security of personal information through changed or new business projects. A PIA
may also provide assurance that a project contains limited or no risks to the
business.
The PIA process assists Police to:
• comply with the Privacy Act 2020 and embed Data Protection and Use Policy
(DPUP) values into how Police manage personal information
• determine the risks and effects of a change or new project, and
• evaluate options to remove or reduce potential privacy risks.
Good stewardship of personal information is enhanced by undertaking a PIA when a
new project or way of handling personal information may affect privacy – either
negatively or positively. PIAs (and the Privacy by Design approach) also supports our
vision of having the trust and confidence of the community.
Privacy by Design has an enduring effect
Privacy by Design has an enduring effect – it means systems and processes are built
to make it easier for our people to do the right thing and harder for them to make
mistakes.
No individual or organisation is perfect in how it operates. In various ways, the
quality of our work diminishes or decays over time. Embedding good practice into
systems design helps prevent decay in our day-to-day operational practices.
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The ‘by design’ approach supports privacy compliance, reducing risk for Police as it
collects, stores, uses, discloses, and eventually destroys or disposes of personal
information, commonly described as the ‘information lifecycle’.
Building in sound privacy practices at the start lessens or prevents privacy breaches
from happening.
The Privacy by Design approach raises privacy awareness about handling of
personal information across Police projects and supports early identification and
resolution of privacy risks while giving increased assurance that we are meeting our
Privacy Act obligations.
Completing a PIA
PIA template
The PIA template is designed to be straightforward for project teams to complete
and provides an opportunity for substantive comments and explanation of risks and
mitigations. Completing the PIA template ensures there is sufficient substance to
enable it to be used for consultation purposes with other parties, such as the
Privacy Commissioners Office.
Do I need to do a PIA?
Deciding whether completion of a PIA is necessary is assessed case-by-case basis.
Make early contact with the Privacy Team in the Assurance Group about your project
and they will provide advice and recommend the most suitable way forward
([email address]).
When there is only a minor change to a system, tool, service or process it may be
sufficient to simply consult with and receive advice from the Privacy Team.
If you are uncertain about the level of impact that a project will have on Police’s
management of personal information, or on individuals’ reasonable expectations of
privacy, a PIA will be required.
It will also be necessary to complete a PIA for large system changes or significant
changes to the way Police manages personal information.
Examples of projects that may benefit from a PIA process:
• Developing an online service or creating a website or mobile app to collect
personal information
• Sharing personal information with another agency, or providing access to
Police systems
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• Using a third-party provider to process personal information (for example, a
cloud-based service)
• Introducing workplace tools that affect how personal information about staff is
collected, stored, and used.
Who should carry out a PIA?
Completing a PIA does not always require a privacy specialist, Police’s privacy officer
or a lawyer. If a project is particularly complex or the proposed use of personal
information is novel or significantly different to the status quo, engage others
(either internal or external) with the requisite expertise to either lead or assist with
the assessment.
It is essential Police staff involved in a project contribute to the PIA process. If an
external specialist is engaged to complete the PIA it is crucial to the integrity of the
assessment that our institutional knowledge is included in the development of the
PIA.
When should a PIA be undertaken?
There should be early consideration of privacy issues and risks when considering
any new product, service, system, or process that includes personal information. A
‘by design’ approach means building in privacy from the outset, so start the PIA
process alongside work on your business process design work.
It is also important to understand that a PIA is a ‘living document’, not a one-time
review. As a project changes in scope or design, update the PIA to reflect new
positions and new or altered privacy risks.
Privacy by Design thinking
The principles of Privacy by Design
There are seven Privacy by Design principles:
1. Proactive not Reactive/Preventative not Remedial
Think about privacy at the beginning of your project and build privacy features into
new systems, tools, services or processes.
2. Consider privacy a default setting
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Privacy interests need to be at the forefront of what we do. This means being
thoughtful about the personal information we collect, how we collect it, how we use
and share it, how we keep it safe and how long we keep it. It also means
remembering there are people behind the information we collect.
3. Privacy Embedded into Design
Privacy needs to be integral to the way Police thinks and operates – it should be
embedded in our systems, tools, services and functions.
4. Full Functionality – no trade-off or loss
Our obligation to protect personal information should be an opportunity to design a
better system, tool, service or process rather than a trade-off with other
functionality.
5. End to end privacy protection
Protection and security of personal information should be considered at every stage
of the information lifecycle, through its collection, storage, use, and eventual
disposal.
6. Provide visibility and transparency
We need to be transparent with individuals about how their personal information
will be used. Our communications with the public should be written in plain English
and take account of other cultures and languages where possible.
7. Respect individuals’ privacy rights
Design user-centric systems, tools, services or processes to support individuals’
ability to exercise some level of control over their information (including an access
and correction right under New Zealand privacy law).
Privacy by Design strategies
These design strategies inform a privacy-focussed design approach for ICT and
digital teams:
Minimise and separate — reduce opportunities for unauthorised access to
information
Hide and abstract — make it difficult for
unauthorised people to use personal
information
Enforce and demonstrate — reduce the probability of unauthorised access and use
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Inform and control — provide individuals with information and choices to reduce
the risk to their personal information.
Further advice and assistance
For advice and assistance with PIAs, and how to bring the Privacy by Design
approach to life, contact Police’s Chief Privacy Officer.
Resources
PIA template Privacy Impact Assessment Template Version July 2022
Privacy: advice, guidance and tools to help government agencies improve their
privacy capability and maturity. https://www.digital.govt.nz/standards-and-
guidance/privacy-security-and-risk/privacy/
Assess project privacy risk - https://www.digital.govt.nz/standards-and-
guidance/privacy-security-and-risk/privacy/assess-privacy-risk/assess-project-
privacy-risk/
Privacy by design strategies - https://www.digital.govt.nz/standards-and-
guidance/privacy-security-and-risk/privacy/manage-a-privacy-programme/privacy-
by-design-pbd/
Last modified: 22/12/2022
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