2 February 2026
45 Pipitea Street, Thorndon, Wellington 6011
PO Box 805, Wellington
Phone: 04 495 7200
Joshua Riley
Email
: [email address]
[FYI request #33250 email]
Website: dia.govt.nz
Tēnā koe Joshua,
Your Official Information Act 1982 request, reference OIA 2526-0676
I am responding to your email of 13 December 2025 to the Department of Internal Affairs
(the Department) requesting the following under the Official Information Act 1982 (the Act):
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).
Response to your request The Department has conducted a thorough search for information within the scope of your
request. This included consultation with the Policy and Branch Performance teams. These
teams have advised that they do not hold any documents relating to your request.
Therefore, I am refusing your request under section 18(e) of the Act as the documentation
requested does not exist or, despite reasonable efforts to locate it, cannot be found.
Accessing the Ombudsman
You have the right to seek an investigation and review of my decision by the Office of the
Ombudsman. Information about how to make a complaint is available at
www.ombudsman.parliament.nz or freephone 0800 802 602.
Proactive release
We intend to publish our response to your request on our website at:
www.dia.govt.nz/Official-Information-Act-Requests-2. This letter, with your personal details
removed, will be published in its entirety. Publishing responses increases the availability of
information to the public and is consistent with the Act’s purpose of enabling more effective
participation in the making and administration of laws and policies and promoting the
accountability of Ministers and officials.
Nāku noa, nā
Mark Batt
Director Branch Performance
Policy and Te Tiriti
