[IN CONFIDENCE RELEASE EXTERNAL]
25OIA1317
03 October 2024
Shane Gibson
[FYI request #28360 email]
Dear Shane Gibson
Thank you for your request made under the Official Information Act 1982 (OIA), received on 11
September 2024. You requested the following:
Please provide a copy of the Privacy Impact Assessment that was done as part of this
data sharing arrangement.
Inland Revenue takes privacy very seriously. We have not leaked or sold any taxpayer
information.
We advertise on social media because it is an effective tool to inform customers of their tax
obligations or entitlements like Working for Families and FamilyBoost. Using custom audience
lists on social media allows organisations to securely upload de-identified information (referred
to as hashed information) for direct marketing purposes. We have used custom audience lists
on Meta (Facebook and Instagram), LinkedIn and Google.
On 12 September we paused the use of custom audience lists while we undertake an internal
review of this practice (undertaken by our Chief Information Security Office (CISO)). We did this
due to public concern and to provide reassurance that we take the public’s concerns seriously.
We are also working with the Office of the Privacy Commissioner who are assessing whether
there are any privacy issues with hashing.
The New Zealand Information Security manual, which is maintained by the Government
Communications Security Bureau (GCSB), has guidelines on information assurance and systems
security. Our standards with relation to hashing operate within these guidelines.
More information on our use of custom audience lists, including how this complies with the
Privacy Act 2020, is on our website at
www.ird.govt.nz/customaudiencelists. This page will be
updated when the review has been completed or if we have further information to share.
Information requested
A privacy impact assessment helps identify whether a project will impact on people and their
information, how any risk can be reduced and ensures the project complies with the Privacy Act
2020.
The following privacy impact assessments are enclosed as
Appendix A:
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[IN CONFIDENCE RELEASE EXTERNAL]
25OIA1317
Date
Document Title
Decision
1.
September 2016
Use of Facebook’s Custom Audience for
Released in full.
advertising campaigns – Brief Privacy
Analysis
2.
September 2024
Use of Custom Audience on social media for Released in full.
advertising campaigns – Privacy Threshold
Assessment
Inland Revenue conducted a privacy impact assessment in 2016. In September 2024, Inland
Revenue conducted a new privacy impact assessment to assess the use of custom audience on
social media for advertising campaigns. This version contains more detail, but the privacy impact
rating is the same.
Right of review
If you disagree with my decision on your OIA request, you can ask an Inland Revenue review
officer to review my decision. To ask for an internal review, please email the Commissioner of
Inland Revenue at
: [email address].
Alternatively, under section 28(3) of the OIA, you have the right to ask the Ombudsman to
investigate and review my decision. You can contact the office of the Ombudsman by email at:
[email address].
If you choose to have an internal review, you can still ask the Ombudsman for a review.
Thank you again for your request.
Yours sincerely
Pip Knight
Service Leader, Marketing & Communications
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