
17 March 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 2526-0812
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).
Part one and two of the request has been transferred to the Department by Hon Erica
Stanford’s office. We have already provided a response to this matter. Please refer to
previous OIA request, OIA2526-0676 sent to you on 2 February 2026.
On 17 February 2026, you requested clarification on part three with the following:
I am requesting that you specifically query the Digital Safety Team regarding Part 3.
Have they had any correspondence with the Australian eSafety Commissioner (Julie Inman
Grant) or the Australian Government regarding their recent age verification legislation?
If you continue to refuse Part 3 under section 18(e), please confirm that the Digital Safety
Team was specifically consulted on this question and confirmed they hold no records of any
kind (including emails) regarding the Australian legislation.
Response to your request There is one document that is in scope of your request which is attached at
Appendix A.
Some information in this document is withheld under 9(2)(a) of the Act to protect the
privacy of natural persons, including that of deceased natural persons.
Public interest considerations As is required by section 9(1) of the Act, consideration has been given as to whether the
withholding of information is outweighed by other public interest considerations which
would make it desirable to make this information available. In this instance, it is not
considered to be the case.
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.
Nāku noa, nā
Mark Batt
Director Branch Performance
Policy and Te Tiriti
Appendix A: Documents within scope
No. Title
Date
Decision (Release, partial
Withholding grounds
release or withhold)
under the Act
1 Email
12 December 2025
Partial release
9(2)(a)