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3/02/2026
Joshua Riley
[FYI request #33248 email]
Tēnā koe Joshua
OIA: GEMS-46597 - Advice regarding Age Verification Mechanisms and Privacy Risks for
Social Media Regulation
I refer to your email of 13 December 2025 to the Minister of Education, Hon Erica Stanford,
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).
The Minister’s office transferred
parts one and two of your request to the Ministry of Education
(the Ministry) on 23 January 2026, and these have been considered under the Official Information
Act 1982 (the Act).
Wellington National Office, 1 The Terrace, Levels 5 to 14, Wellington 6011
PO Box 1666, Wellington 6140, DX SR51201 Phone: +64 4 463 8000
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Unfortunately, that transfer was in error, as responsibility for this workstream has now moved to the
Department of Internal Affairs (DIA). We have therefore determined that the information requested
is more closely connected with the functions of DIA, and I have transferred your request to DIA in
accordance with section 14(b)(ii) of the Act. We regret that this was not identified prior to the initial
transfer from the Minister’s office.
You may expect a response from DIA directly concerning your request.
Nāku noa, nā
Emma Drysdale
Manager, Official and Parliamentary Information
Government, Executive and Ministerial Services
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