18 October 2024
45 Pipitea Street, Wellington 6011
Phone +64 4 495 7200
dia.govt.nz
Mijail Linares
fyi-request-28465-
[email address]
Tēnā koe Mijail
OIA request 2425-0277 Request for Legal Basis For Sharing New Citizenship Information
Thank you for your Official Information Act (Act) request received by the Department of Internal
Affairs (Department) on 20 September 2024.
You requested –
Under the Official Information Act 1982, I respectfully request information relating to the
sharing of new citizens' personal contact details, such as names and email addresses, with
Members of Parliament or third parties. Specifically, I request the following:
1. Legal Authority for Sharing Information:
Is there any Approved Information Sharing Agreement (AISA), policy, or other statutory basis
that allows the Department of Internal Affairs to share the personal contact details (e.g.,
email addresses) of new citizens with Members of Parliament or any other external entities?
2. Information Sharing Process:
What is the specific process through which Members of Parliament are notified of new
citizens? For example, are names, contact details, or other personal information shared with
MPs? If so, under what legal framework is this done, and how does the Department ensure
that this process complies with the Privacy Act 2020?
3. Information Disclosure to Julie Anne Genter’s Office:
Has the Department of Internal Affairs shared my personal contact information with the
office of Julie Anne Genter, or any other Member of Parliament? If yes, please provide the
legal authorization under which this occurred.
4. Consent Mechanisms:
What mechanisms for consent are in place regarding the sharing of personal information
such as email addresses with third parties, including Members of Parliament? Is explicit
consent from new citizens required before this information is shared for non-governmental
purposes like political outreach?
5. Privacy Protections:
What privacy protections are implemented when sharing new citizens' personal information
with third parties? How does the Department ensure compliance with the Privacy Act 2020,
specifically the provisions outlined in Information Privacy Principle (IPP) 11 regarding limits
on disclosure of personal information?
You provided additional clarification of your request on the same day. This has been
consolidated into one request:
6. Does the AISA explicitly cover political outreach activities, such as soliciting feedback,
inviting new citizens to share their views and attend events hosted by MPs? For
reference, in the email I received from Julie Anne Genter’s office, I was not only welcomed
as a new citizen but also invited to share my concerns and attend events throughout the
year. I would like to know if the sharing of personal contact details for such purposes falls
within the scope of the AISA.
7. If the AISA’s scope does not cover political engagement or outreach of this nature, can
you provide clarity on how the sharing of my contact information for these purposes was
legally justified?
In response to your request, I can provide you with the following information.
The Department is committed to looking after the personal information entrusted to us so that
our staff, members of the public and the government retain the highest level of confidence in
our ability to safeguard the personal information we hold.
Thank you for your feedback which has identified some areas of improvement in our processes
which I will go into greater detail on in this response.
Questions One and Two
The Department shares new citizenship information with the Electoral Commission as legislated
under the Electoral Act 1993 (Electoral Act).
The purpose of sharing new citizenship information is to identify people who qualify to apply to
register as an elector and encourage those identified, to register. This also ensures the accuracy
of the particulars of people whose name is on the electoral roll.
Sections 263B(3)(d) and 263(4)(d)(i) of the Electoral Act, allows authorised parties, at the
request of the Electoral Commission, to supply to the Electoral Commission information on any
people who obtain New Zealand citizenship under the
Citizenship Act , 1977.
In case it may be of interest, further information about the Department’s Approved Information
Sharing Agreements (AISA) can be found on our webs
ite www.dia.govt.nz/privacy-information-
sharing.
Page 4 of 4
The Department shares new citizen data with Members of Parliament (MPs) and local
authorities, though there is no formalised information-sharing agreement in place.
Agreement for contact information being shared with MPs and local councillors is part of the
citizenship application process and the form contains the following statement:
“I authorise the Department of Internal Affairs to release my name and address to my local
Member of Parliament and local councillors so that they can formally welcome me to New
Zealand following my grant of citizenship.”
This allows these representatives to formally welcome new citizens to New Zealand after
citizenship is granted.
Local authorities receive a candidate lists to organise ceremonies and welcome new citizens.
Citizenship ceremony attendees are logged/ recorded on to the Department’s system as the last
requirement for citizenship. Once complete, a list of new citizens is provided to MPs within
each electorate district to welcome them.
Questions Three and Four
I can confirm that your contact information was shared the office of Julie Anne Genter and MPs
within the same electorate as per the address provided. As explained above, agreement for the
sharing of contact information is part of th
e citizenship application process.
As a result of your feedback the Department has reviewed its policies and email addresses will
now not be included as part of the new citizenship lists shared.
Each new citizens list comes with a reminder to MPs and local authorities that the information
provided must not be used for any other purpose, such as marketing or campaigning, nor shared
with third parties. The list must be securely destroyed once it has served its intended purpose.
Questions Five, Six and Seven
I can confirm there is no Authorised Information Sharing Agreement (AISA) or other comparable
sharing agreement relating to the sharing of new citizens with MPs or local authorities.
As explained above, agreement for the sharing of contact information is part of th
e citizenship
application process.
Local authorities and MPs are responsible for ensuring that any information they receive is used
only for the purpose it was intended. The Department will take action if it becomes aware that
information is being misused and will follow up on your feedback.
As this information may be of interest to other members of the public, the Department has
decided to proactively release a copy of this response on the DIA website. All requestor data,
including your name and contact details, will be removed prior to release. The released
response will be made available here:
https://www.dia.govt.nz/Official-Information-Act-
Requests-2.
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You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at www.ombudsman.parliament.nz or
freephone 0800 802 602.
Ngā mihi
John Crawford-Smith
Manager Operational Policy and Official Correspondence (Acting)
Service Delivery and Operations
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