From:
Christie Baird
To:
Carolyn Fyfe
Subject:
RE: Background
Date:
Wednesday, 4 May 2016 1:38:00 pm
Hi Carolyn,
Thanks very much for that background information – extremely helpful.
I will let you know how I get on with the OPC.
Thanks
Christie Baird / Privacy Officer / Senior Legal Counsel
Legal Services Team - Regulatory and Commercial
Organisational Support
S9(2)(a)
E [email address] / W nzta.govt.nz
cid:image001.jpg@01D1A517.DF1EE5F0
_________ _____________________________________________
From: Carolyn Fyfe
Sent: Wednesday, 4 May 2016 12:32 p.m.
To: Christie Baird
Cc: Carolina Lukkien; Leigh Mitchell
Subject: Background
Hi Christie,
Thanks for letting me know about your call from the OPC. Can I please be involved in any
conversations about this?
I think a key point is the distinction between access to the CAS
system, which is not open (as you
know people are able to apply for free access, which is assessed against the purpose for which
the data is collected); and the data we make openly available from this system. In the data we
under the Official Information Act 1982
make publically available we need to make sure we are meeting our obligations under the
Privacy Act by ensuring that an individual cannot be identified in the data (ie by factors other
than just personal identifiers).
Historically we made unit record information available from CAS in the form of csv files, however
these were removed from the web to be replaced with aggregated data as the data in the csv
files could potentially allow the identification of an individual.
Released
Some information on correspondence with S9(2)(a)
·
Most recent – the email you saw about access
·
Update after our phone call – I sent S9(2) a follow-up within the fortnight after our
(a)
phone call as agreed, noting we were undertaking a PIA. However, as S9(2) doesn’t
mention this in his post, I now wonder if he didn’t receive this.
(a)
·
Phone conversation with
S9(2)(a)
(Chair, Cycle Aware Wellington). To
understand their needs primarily, but I also explained about cas access (which S9(2)
does not want as he wants to make information about individual crashes available(a)
publically, which would not be allowed under the confidentiality provisions of the
agreement) and about identifying information as opposed to identifiers.
Summary from other correspondence:
· S9(2)(a) key points are about usefulness of aggregated data and contesting there are
privacy concerns.
· S9(2)(a)notes there are other ways to protect privacy (only specifying an approximate
date, or randomising the location slightly, or suppressing the reporting of specific
accident codes). These are valid but I think they’d be less useful than aggregation for the
majority of users as day/time and precise location are often key. We need to apply
consistent rules.
·
S9(2) is asking for documents of the ‘review’ of cas data online and asks why there
wasn’t consultation – what we said was ‘We are currently reviewing the CAS information
(a)
we have available on our website to make sure it meets our privacy and security
standards’ –this isn’t about consulting, it’s about making sure the data conforms to our
aggregation rules etc so individuals can’t be identified in the data. There isn’t a review
document.
Hope this helps – let me know if there is more I can provide.
Cheers,
Carolyn
From: Christie Baird
Sent: Wednesday, 4 May 2016 11:57 a.m.
To: Carolyn Fyfeunder the Official Information Act 1982
Subject: Have you seen this?
http://www.nearimprov.com/cas-saga/
Christie Baird / Privacy Officer / Senior Legal Counsel
Legal Services Team - Regulatory and Commercial
Organisational Support
S9(2)(a)
E [email address] / W nzta.govt.nz
Released
National Office / Victoria Arcade, 50 Victoria Street,
Private Bag 6995, Wellington 6141, New Zealand
cid:image001.jpg@01D1A517.DF1EE5F0