Advice regarding Age Verification Mechanisms and Privacy Risks for Social Media Regulation

Joshua Riley made this Official Information request to Erica Stanford

Currently waiting for a response from Erica Stanford, they must respond promptly and normally no later than (details and exceptions).

From: Joshua Riley

Dear Erica Stanford,

I am writing to request information under the Official Information Act 1982 regarding the proposed legislation to restrict social media access for users under the age of 16.

Specifically, I am requesting copies of all advice, briefings, cabinet papers, or aides-mémoire provided to you or your office regarding the technical implementation of age verification, specifically covering the period from October 1, 2024, to present.

I request the following specific information:

1. Device-Based vs. Provider-Based Verification: Any documents outlining the comparative analysis between "Device-Based/OS-Level" verification (using Apple/Google APIs) versus "Provider-Based" verification (requiring platforms like Meta/TikTok to verify users).
Specific interest: I am seeking information on why the "Device-Based" model was rejected or not mandated, given its superior privacy characteristics.

2. Privacy Impact of ID Uploads: Any advice received regarding the privacy risks of the "Provider Liability" model, specifically concerning the likelihood of social media platforms requiring government ID uploads or facial biometrics from New Zealand adults and children to ensure compliance.

3. Australian Consultation: Any correspondence with the Australian Government or eSafety Commissioner regarding the privacy implications of their Online Safety Amendment (Social Media Minimum Age) Bill 2024, specifically regarding the use of third-party identity brokers (e.g., Yoti, k-ID).

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From: Erica Stanford (MIN)
Erica Stanford

Thank you for contacting the Office of Hon Erica Stanford, Minister of
Education, Minister of Immigration, Lead Coordination Minister for the
Government's Response to the Royal Commission's Report into Historical
Abuse in State Care and in the Care of Faith-based Institutions, and
Member of Parliament for East Coast Bays.

We appreciate you reaching out – the Minister considers all correspondence
to be important, and all messages are carefully read and considered.
Please do note it is not always possible to provide a personal response to
every email received. Personal views, feedback and suggestions are
gratefully received and will be passed on to the Minister and/or relevant
Agencies.

Please note the following to help us direct your correspondence:

* If you are seeking ministerial intervention for an immigration case,
please contact Associate Minister of Immigration, Hon Chris Penk, at
[email address] Minister Stanford is unable to comment on
individual cases.
* Emails relating to education matters that are operational in
nature will be transferred to the Ministry of Education (or other
agency).  Minister Stanford is unable to comment on individual cases.
You can contact the Ministry directly at:
[email address]
* For assistance related to historical abuse in state care, please
contact the Survivor Experiences Team at
[email address].
* If you have invited Minister Stanford to an event, or requested a
meeting, a member of staff may contact you for more information.
* Official Information or Privacy Act requests will be managed under the
relevant Acts, which may include transfer to another Agency.
* If you are a journalist, your request will be referred to the Press
Secretary.
* If you are a constituent of East Coast Bays, your email will be shared
with the Electorate Office.

Thank you again for writing to Minister Stanford.
Kind regards,
Office of Hon Erica Stanford
Reception: +64 4 817 6805 | Ministerial Email:
[1][Erica Stanford request email] |
Web: beehive.govt.nz  | Post: Freepost Parliament, Private Bag 18 041,
Parliament Buildings, Wellington 6160, New Zealand

References

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1. mailto:[Erica Stanford request email]

Link to this

From: Erica Stanford (MIN)
Erica Stanford


Attachment image001.jpg
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OIA ACKNOWLEDGEMENT

 

 

Dear Joshua,

 

Thank you for your Official Information Act 1982 (the Act) request,
received on 13/12/2025, in which you requested the following information:

 

I am writing to request information under the Official Information Act
1982 regarding the proposed legislation to restrict social media access
for users under the age of 16.

 

Specifically, I am requesting copies of all advice, briefings, cabinet
papers, or aides-mémoire provided to you or your office regarding the
technical implementation of age verification, specifically covering the
period from October 1, 2024, to present.

 

I request the following specific information:

 

1. Device-Based vs. Provider-Based Verification: Any documents outlining
the comparative analysis between "Device-Based/OS-Level" verification
(using Apple/Google APIs) versus "Provider-Based" verification (requiring
platforms like Meta/TikTok to verify users).

Specific interest: I am seeking information on why the "Device-Based"
model was rejected or not mandated, given its superior privacy
characteristics.

 

2. Privacy Impact of ID Uploads: Any advice received regarding the privacy
risks of the "Provider Liability" model, specifically concerning the
likelihood of social media platforms requiring government ID uploads or
facial biometrics from New Zealand adults and children to ensure
compliance.

 

3. Australian Consultation: Any correspondence with the Australian
Government or eSafety Commissioner regarding the privacy implications of
their Online Safety Amendment (Social Media Minimum Age) Bill 2024,
specifically regarding the use of third-party identity brokers (e.g.,
Yoti, k-ID).

 

 

Your request will be answered within the provisions of the Official
Information Act.

 

 

Kind regards,

Office of Hon Erica Stanford

 

Office of Hon Erica Stanford

 

MP for East Coast Bays

Minister of Education

Minister of Immigration

Lead Coordination Minister for the Government’s Response to the Royal
Commission’s Report into Historical Abuse in State Care and in the Care
of Faith-based Institutions

 
Website: [1]www.Beehive,govt.nz

Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand

 

Disclaimer: The information in this email (including attachments) is
confidential and may be legally privileged. If an addressing or
transmission error has misdirected this email, please notify the author
by replying to this email and destroy the message. If you are not the
intended recipient, any use, disclosure, copying or distribution is
prohibited and may be unlawful.

 

 

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From: Erica Stanford (MIN)
Erica Stanford


Attachment image001.jpg
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Dear Joshua,

 

Thank you for your email of 13 December 2025 requesting the following
information:

 

Specifically, I am requesting copies of all advice, briefings, cabinet
papers, or aides-mémoire provided to you or your office regarding the
technical implementation of age verification, specifically covering the
period from October 1, 2024, to present.

I request the following specific information:

 1. Device-Based vs. Provider-Based Verification: Any documents outlining
the comparative analysis between "Device-Based/OS-Level" verification
(using Apple/Google APIs) versus "Provider-Based" verification
(requiring platforms like Meta/TikTok to verify users).

Specific interest: I am seeking information on why the "Device-Based"
model was rejected or not mandated, given its superior privacy
characteristics.

 2. Privacy Impact of ID Uploads: Any advice received regarding the
privacy risks of the "Provider Liability" model, specifically
concerning the likelihood of social media platforms requiring
government ID uploads or facial biometrics from New Zealand adults and
children to ensure compliance.
 3. Australian Consultation: Any correspondence with the Australian
Government or eSafety Commissioner regarding the privacy implications
of their Online Safety Amendment (Social Media Minimum Age) Bill 2024,
specifically regarding the use of third-party identity brokers (e.g.,
Yoti, k-ID).

 

This letter is to advise you that it is necessary to transfer part of your
request to the Ministry of Education (The Ministry) and that we are
extending the 10 working day time limit available to make this transfer,
to 23 Jan. This extension is necessary because the consultations necessary
to make a decision on transfer of your request are such that a proper
response cannot reasonably be made within the original time limit.

 

Papers such as advice and briefings on this issue are drafted for me by
the Ministry. Therefore, parts 1 and 2 of your request have been
transferred to the Ministry under section 14(b)(ii). You can expect to
receive a response from the Ministry directly on these parts of your
request.

 

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
[1]www.ombudsman.parliament.nz or freephone 0800 802 602.

 

 

 

Office of Hon Erica Stanford

 

MP for East Coast Bays

Minister of Education

Minister of Immigration

Lead Coordination Minister for the Government’s Response to the Royal
Commission’s Report into Historical Abuse in State Care and in the Care
of Faith-based Institutions

 

 
Website: [2]www.Beehive,govt.nz

Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand

 

Disclaimer: The information in this email (including attachments) is
confidential and may be legally privileged. If an addressing or
transmission error has misdirected this email, please notify the author
by replying to this email and destroy the message. If you are not the
intended recipient, any use, disclosure, copying or distribution is
prohibited and may be unlawful.

 

 

From: Erica Stanford (MIN) <[email address]>
Sent: Monday, 15 December 2025 8:50 am
To: Joshua Riley <[FOI #33248 email]>
Cc: Erica Stanford (MIN) <[email address]>
Subject: RE: ESOIA840 | Official Information request - Advice regarding
Age Verification Mechanisms and Privacy Risks for Social Media Regulation

 

OIA ACKNOWLEDGEMENT

 

 

Dear Joshua,

 

Thank you for your Official Information Act 1982 (the Act) request,
received on 13/12/2025, in which you requested the following information:

 

I am writing to request information under the Official Information Act
1982 regarding the proposed legislation to restrict social media access
for users under the age of 16.

 

Specifically, I am requesting copies of all advice, briefings, cabinet
papers, or aides-mémoire provided to you or your office regarding the
technical implementation of age verification, specifically covering the
period from October 1, 2024, to present.

 

I request the following specific information:

 

1. Device-Based vs. Provider-Based Verification: Any documents outlining
the comparative analysis between "Device-Based/OS-Level" verification
(using Apple/Google APIs) versus "Provider-Based" verification (requiring
platforms like Meta/TikTok to verify users).

Specific interest: I am seeking information on why the "Device-Based"
model was rejected or not mandated, given its superior privacy
characteristics.

 

2. Privacy Impact of ID Uploads: Any advice received regarding the privacy
risks of the "Provider Liability" model, specifically concerning the
likelihood of social media platforms requiring government ID uploads or
facial biometrics from New Zealand adults and children to ensure
compliance.

 

3. Australian Consultation: Any correspondence with the Australian
Government or eSafety Commissioner regarding the privacy implications of
their Online Safety Amendment (Social Media Minimum Age) Bill 2024,
specifically regarding the use of third-party identity brokers (e.g.,
Yoti, k-ID).

 

 

Your request will be answered within the provisions of the Official
Information Act.

 

 

Kind regards,

Office of Hon Erica Stanford

 

Office of Hon Erica Stanford

 

MP for East Coast Bays

Minister of Education

Minister of Immigration

Lead Coordination Minister for the Government’s Response to the Royal
Commission’s Report into Historical Abuse in State Care and in the Care
of Faith-based Institutions

 
Website: [3]www.Beehive,govt.nz

Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand

 

Disclaimer: The information in this email (including attachments) is
confidential and may be legally privileged. If an addressing or
transmission error has misdirected this email, please notify the author
by replying to this email and destroy the message. If you are not the
intended recipient, any use, disclosure, copying or distribution is
prohibited and may be unlawful.

 

 

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From: Enquiries National


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[UNCLASSIFIED]

Kia ora Joshua

 

Thank you for the information request below, that was part transferred to
the Ministry on 23 January 2026.  The Ministry will consider and respond
to your request in accordance with the Official Information Act 1982 the
Act).

 

Under section 15(1) of the Act, we are required to make and inform you of
our decision on your request as soon as reasonably practicable and in any
case not later than 20 working days after the day on which your request is
received. You can therefore expect to receive our decision on your request
on or before 23 February 2026. If more than 20 working days are needed due
to the potential workload and/or consultations involved in answering your
request, we will notify you accordingly.

 

The Ministry may publicly release on our website the response to your
request five days after you have received it. Any personal information
will be removed.

 

In the interim, if you have any questions about your request, please email
[1][email address]

 

Ngā mihi

 

Enquiries National Team | Te Tāhuhu o te Mātauranga | Ministry of
Education | TW

[2]education.govt.nz

We shape an education system that delivers equitable and excellent
outcomes
He mea tārai e mātou te mātauranga kia rangatira ai, kia mana taurite ai
ōna huanga

 

 

 

From: Erica Stanford (MIN) <[3][email address]>
Sent: Friday, 23 January 2026 4:23 pm
To: Joshua Riley <[4][FOI #33248 email]>
Cc: Erica Stanford (MIN) <[5][email address]>
Subject: RE: ESOIA840 | Official Information request - Advice regarding
Age Verification Mechanisms and Privacy Risks for Social Media Regulation

 

Dear Joshua,

 

Thank you for your email of 13 December 2025 requesting the following
information:

 

Specifically, I am requesting copies of all advice, briefings, cabinet
papers, or aides-mémoire provided to you or your office regarding the
technical implementation of age verification, specifically covering the
period from October 1, 2024, to present.

I request the following specific information:

 1. Device-Based vs. Provider-Based Verification: Any documents outlining
the comparative analysis between "Device-Based/OS-Level" verification
(using Apple/Google APIs) versus "Provider-Based" verification
(requiring platforms like Meta/TikTok to verify users).

Specific interest: I am seeking information on why the "Device-Based"
model was rejected or not mandated, given its superior privacy
characteristics.

 2. Privacy Impact of ID Uploads: Any advice received regarding the
privacy risks of the "Provider Liability" model, specifically
concerning the likelihood of social media platforms requiring
government ID uploads or facial biometrics from New Zealand adults and
children to ensure compliance.
 3. Australian Consultation: Any correspondence with the Australian
Government or eSafety Commissioner regarding the privacy implications
of their Online Safety Amendment (Social Media Minimum Age) Bill 2024,
specifically regarding the use of third-party identity brokers (e.g.,
Yoti, k-ID).

 

This letter is to advise you that it is necessary to transfer part of your
request to the Ministry of Education (The Ministry) and that we are
extending the 10 working day time limit available to make this transfer,
to 23 Jan. This extension is necessary because the consultations necessary
to make a decision on transfer of your request are such that a proper
response cannot reasonably be made within the original time limit.

 

Papers such as advice and briefings on this issue are drafted for me by
the Ministry. Therefore, parts 1 and 2 of your request have been
transferred to the Ministry under section 14(b)(ii). You can expect to
receive a response from the Ministry directly on these parts of your
request.

 

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
[6]www.ombudsman.parliament.nz or freephone 0800 802 602.

 

 

 

Office of Hon Erica Stanford

 

MP for East Coast Bays

Minister of Education

Minister of Immigration

Lead Coordination Minister for the Government’s Response to the Royal
Commission’s Report into Historical Abuse in State Care and in the Care
of Faith-based Institutions

 

 
Website: [7]www.Beehive,govt.nz

Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand

 

Disclaimer: The information in this email (including attachments) is
confidential and may be legally privileged. If an addressing or
transmission error has misdirected this email, please notify the author
by replying to this email and destroy the message. If you are not the
intended recipient, any use, disclosure, copying or distribution is
prohibited and may be unlawful.

 

 

From: Erica Stanford (MIN) <[8][email address]>
Sent: Monday, 15 December 2025 8:50 am
To: Joshua Riley <[9][FOI #33248 email]>
Cc: Erica Stanford (MIN) <[10][email address]>
Subject: RE: ESOIA840 | Official Information request - Advice regarding
Age Verification Mechanisms and Privacy Risks for Social Media Regulation

 

OIA ACKNOWLEDGEMENT

 

 

Dear Joshua,

 

Thank you for your Official Information Act 1982 (the Act) request,
received on 13/12/2025, in which you requested the following information:

 

I am writing to request information under the Official Information Act
1982 regarding the proposed legislation to restrict social media access
for users under the age of 16.

 

Specifically, I am requesting copies of all advice, briefings, cabinet
papers, or aides-mémoire provided to you or your office regarding the
technical implementation of age verification, specifically covering the
period from October 1, 2024, to present.

 

I request the following specific information:

 

1. Device-Based vs. Provider-Based Verification: Any documents outlining
the comparative analysis between "Device-Based/OS-Level" verification
(using Apple/Google APIs) versus "Provider-Based" verification (requiring
platforms like Meta/TikTok to verify users).

Specific interest: I am seeking information on why the "Device-Based"
model was rejected or not mandated, given its superior privacy
characteristics.

 

2. Privacy Impact of ID Uploads: Any advice received regarding the privacy
risks of the "Provider Liability" model, specifically concerning the
likelihood of social media platforms requiring government ID uploads or
facial biometrics from New Zealand adults and children to ensure
compliance.

 

3. Australian Consultation: Any correspondence with the Australian
Government or eSafety Commissioner regarding the privacy implications of
their Online Safety Amendment (Social Media Minimum Age) Bill 2024,
specifically regarding the use of third-party identity brokers (e.g.,
Yoti, k-ID).

 

 

Your request will be answered within the provisions of the Official
Information Act.

 

 

Kind regards,

Office of Hon Erica Stanford

 

Office of Hon Erica Stanford

 

MP for East Coast Bays

Minister of Education

Minister of Immigration

Lead Coordination Minister for the Government’s Response to the Royal
Commission’s Report into Historical Abuse in State Care and in the Care
of Faith-based Institutions

 
Website: [11]www.Beehive,govt.nz

Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand

 

Disclaimer: The information in this email (including attachments) is
confidential and may be legally privileged. If an addressing or
transmission error has misdirected this email, please notify the author
by replying to this email and destroy the message. If you are not the
intended recipient, any use, disclosure, copying or distribution is
prohibited and may be unlawful.

 

 

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