Privacy Impact Assessment (PIA) for "anonymised" loan-level data

M B made this Official Information request to Reserve Bank of New Zealand

The request was refused by Reserve Bank of New Zealand.

From: M B

Dear Reserve Bank of New Zealand,

Please provide:

a) the PIA relating to the provision of Loan-Level data to the Reserve Bank of New Zealand. This PIA contains discussion on why the data given under a unique numerical identifier is not considered personal information under the Privacy Act; and

b) any material held that indicates any processes, practices, or procedures that allow the unique identifier to be de-anonymised (via a name or other identifiable characteristic). This part of the request includes internal or external request process (such as seeking further data from a financial institution).

Part b may be answered by providing a list of processes rather than a substantial response.

Yours faithfully,
Mason Helm.

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From: RBNZ Info
Reserve Bank of New Zealand

Kia ora, 

  

Thank you for contacting the Reserve Bank of New Zealand - Te Pūtea
Matua.  

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Kind regards | Ngā mihi nui 

Reserve Bank of New Zealand – Te Pūtea Matua     

2 The Terrace, Wellington 6011. PO Box 2498, Wellington 6140         
 
T + 04 471 3660  

E [31][RBNZ request email]   W [32]rbnz.govt.nz  

 

 

 

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Link to this

From: Ministerial correspondence Mailbox
Reserve Bank of New Zealand


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2/07/2024

 

 

Mason Helm

[1][FOI #27448 email]

 

Dear Mason

 

Official information request

Thank you for your official information request of 1/07/2024 for:

 

a) the PIA relating to the provision of Loan-Level data to the Reserve
Bank of New Zealand. This PIA contains discussion on why the data given
under a unique numerical identifier is not considered personal information
under the Privacy Act; and

 

b) any material held that indicates any processes, practices, or
procedures that allow the unique identifier to be de-anonymised (via a
name or other identifiable characteristic). This part of the request
includes internal or external request process (such as seeking further
data from a financial institution).

 

Part b may be answered by providing a list of processes rather than a
substantial response.

 

We will endeavour to respond to your request as soon as possible and in
any event no later than 29/07/2024, being 20 working days after the day of
your request. If we are unable to respond to your request by then, we will
notify you of an extension of that timeframe.

 

Charges for providing official information and publishing responses

The Official Information Act allows charges to be imposed for the
preparation of information that we send in response to requests. The
Reserve Bank is resourced to meet disclosure obligations for a reasonable
level of requests and generally will not impose charges for small, simple
or infrequent requests. Where the request is for information that requires
substantial collation, research and preparation work, and is chargeable,
we will work with you first to refine the request to a smaller scale or
scope that is less likely to involve charges.

 

Responses to official information requests are published on the Reserve
Bank’s website. We will confirm in our decision letter to you whether we
intend to publish our response to your request.

 

Further information about charges and publishing responses is available on
our website at
[2]www.rbnz.govt.nz/research-and-publications/official-information-requests.

 

 

Yours sincerely

 

Government and Industry Relations team

  Reserve Bank of New Zealand –
Te Pūtea Matua

2 The Terrace, Wellington 6011.  
PO Box 2498, Wellington 6140
[5][IMG] [6][IMG] [7][IMG] [8][IMG] [9][IMG]
E
[3][email address]  
W [4]rbnz.govt.nz

 

 

 

 

 

This message (and any files transmitted with it) are confidential and may
be legally privileged. If you are not the intended recipient please notify
the sender immediately and delete this message from your system.

This message does not necessarily reflect the views of the Reserve Bank of
New Zealand. If the recipient has any concerns about the content of this
message they should seek alternative confirmation from the Reserve Bank of
New Zealand.

References

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7. https://www.youtube.com/user/reservebank...
8. https://www.facebook.com/ReserveBankofNZ
9. https://www.instagram.com/reservebankofnz/

Link to this

From: Ministerial correspondence Mailbox
Reserve Bank of New Zealand


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Dear Mason

 

Please see attached a response from the Reserve Bank of New Zealand – Te
Pūtea Matua to your request made under the Official Information Act 1982.

 

Regards

 

Government and Industry Relations

Reserve Bank of New Zealand – Te Pūtea Matua [3]Text Description
automatically generated
2 The Terrace, Wellington 6011. PO Box 2498,
Wellington 6140    

E [1][email address]   W
[2]rbnz.govt.nz

 

 

This message (and any files transmitted with it) are confidential and may
be legally privileged. If you are not the intended recipient please notify
the sender immediately and delete this message from your system.

This message does not necessarily reflect the views of the Reserve Bank of
New Zealand. If the recipient has any concerns about the content of this
message they should seek alternative confirmation from the Reserve Bank of
New Zealand.

References

Visible links
1. mailto:[email address]
2. https://www.rbnz.govt.nz/

Link to this

From: M B

Dear Ministerial correspondence Mailbox,

Thank you for the response. Your reference to concerns for personal information held by RBNZ appears to materially contribute to the refusal of this request.

According to the information available on the RBNZ's website, the data in question is anonymised. Anonymised information, by definition, should not include information about an identifiable individual and therefore is not "personal information" so should not raise issues related to personal data security. If the data is indeed properly anonymised without the ability to revert (the subject of this request), the concerns about personal information are irrelevant.

Could you please reconsider this request? Perhaps partial disclosure of the PIA is appropriate while still upholding any broader security considerations.

Yours sincerely,
Mason.

Link to this

From: Ministerial correspondence Mailbox
Reserve Bank of New Zealand

Dear Mason

 

Thank you for your email about the RBNZ’s decision on your request made
under the Official Information Act 1982. We are assessing your further
request and will respond to you shortly.

 

Kind regards,

 

Ruth

 

 

From: M B <[1][FOI #27448 email]>
Sent: Monday, July 29, 2024 3:03 PM
To: Ministerial correspondence Mailbox <[2][email address]>
Subject: Re: OIA response

 

Dear Ministerial correspondence Mailbox,

Thank you for the response. Your reference to concerns for personal
information held by RBNZ appears to materially contribute to the refusal
of this request.

According to the information available on the RBNZ's website, the data in
question is anonymised. Anonymised information, by definition, should not
include information about an identifiable individual and therefore is not
"personal information" so should not raise issues related to personal data
security. If the data is indeed properly anonymised without the ability to
revert (the subject of this request), the concerns about personal
information are irrelevant.

Could you please reconsider this request? Perhaps partial disclosure of
the PIA is appropriate while still upholding any broader security
considerations.

Yours sincerely,
Mason.

-----Original Message-----

Dear Mason

 

Please see attached a response from the Reserve Bank of New Zealand – Te
Pūtea Matua to your request made under the Official Information Act 1982.

 

Regards

 

Government and Industry Relations

Reserve Bank of New Zealand – Te Pūtea Matua [3]Text Description
automatically generated
2 The Terrace, Wellington 6011. PO Box 2498,
Wellington 6140    

E [1][email address]   W
[2]rbnz.govt.nz

 

 

This message (and any files transmitted with it) are confidential and may
be legally privileged. If you are not the intended recipient please notify
the sender immediately and delete this message from your system.

This message does not necessarily reflect the views of the Reserve Bank of
New Zealand. If the recipient has any concerns about the content of this
message they should seek alternative confirmation from the Reserve Bank of
New Zealand.

References

Visible links
1. [3]mailto:[email address]
2. [4]https://www.rbnz.govt.nz/

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[5][FOI #27448 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[6]https://fyi.org.nz/help/officers

If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.

-------------------------------------------------------------------

This message (and any files transmitted with it) are confidential and may
be legally privileged. If you are not the intended recipient please notify
the sender immediately and delete this message from your system.

This message does not necessarily reflect the views of the Reserve Bank of
New Zealand. If the recipient has any concerns about the content of this
message they should seek alternative confirmation from the Reserve Bank of
New Zealand.

References

Visible links
1. mailto:[FOI #27448 email]
2. mailto:[email address]
3. mailto:[email
4. https://www.rbnz.govt.nz/
5. mailto:[FOI #27448 email]
6. https://fyi.org.nz/help/officers

hide quoted sections

Link to this

From: M B

Dear Ministerial correspondence Mailbox,

I would like to enquire about the further response to the concerns raised.

Yours sincerely,
Mason.

Link to this

From: Ministerial correspondence Mailbox
Reserve Bank of New Zealand


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Dear Mason

 

Apologies for the delay responding to you.

 

We have given further consideration to your request and our decision
remains that section 9(2)(k) of the OIA applies.

 

To clarify, we are not withholding the information on the basis of privacy
where disclosure would result in the disclosure of personal information
(this is a different withholding ground under the OIA).  We are
withholding this information because it is necessary to prevent the
disclosure or use of official information for improper gain or improper
advantage.

 

The information that informs these assessments is sensitive and the misuse
of this information, if released (even in part), could open up RBNZ to
malicious attacks on our network and systems more generally (beyond the
specific data you have mentioned).

 

You continue to have the right to make a complaint to the Ombudsman should
you choose. More information on the complaints process is available at
www.ombudsman.parliament.nz

 

Yours sincerely

 

Government Relations

Reserve Bank of New Zealand – Te Pūtea [2]Text Description automatically
Matua generated

2 The Terrace, Wellington 6011. PO Box    
2498, Wellington 6140

W [1]rbnz.govt.nz

 

 

 

From: M B <[FOI #27448 email]>
Sent: Saturday, August 31, 2024 5:37 PM
To: Ministerial correspondence Mailbox <[email address]>
Subject: RE: OIA response

 

Dear Ministerial correspondence Mailbox,

I would like to enquire about the further response to the concerns raised.

Yours sincerely,
Mason.

-----Original Message-----

Dear Mason

 

Thank you for your email about the RBNZ’s decision on your request made
under the Official Information Act 1982. We are assessing your further
request and will respond to you shortly.

 

Kind regards,

 

Ruth

 

 

From: M B <[1][FOI #27448 email]>
Sent: Monday, July 29, 2024 3:03 PM
To: Ministerial correspondence Mailbox <[2][email address]>
Subject: Re: OIA response

 

Dear Ministerial correspondence Mailbox,

Thank you for the response. Your reference to concerns for personal
information held by RBNZ appears to materially contribute to the refusal
of this request.

According to the information available on the RBNZ's website, the data in
question is anonymised. Anonymised information, by definition, should not
include information about an identifiable individual and therefore is not
"personal information" so should not raise issues related to personal data
security. If the data is indeed properly anonymised without the ability to
revert (the subject of this request), the concerns about personal
information are irrelevant.

Could you please reconsider this request? Perhaps partial disclosure of
the PIA is appropriate while still upholding any broader security
considerations.

Yours sincerely,
Mason.

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[3][FOI #27448 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[4]https://fyi.org.nz/help/officers

If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.

-------------------------------------------------------------------

This message (and any files transmitted with it) are confidential and may
be legally privileged. If you are not the intended recipient please notify
the sender immediately and delete this message from your system.

This message does not necessarily reflect the views of the Reserve Bank of
New Zealand. If the recipient has any concerns about the content of this
message they should seek alternative confirmation from the Reserve Bank of
New Zealand.

References

Visible links
1. https://www.rbnz.govt.nz/
3. mailto:[FOI #27448 email]
4. https://fyi.org.nz/help/officers

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