Office of the Privacy Commissioner
PO Box 10094, Wellington 6140
Level 11, 215 Lambton Quay
Wellington, New Zealand
P +64 4 474 7590 F +64 4 474 7595
E [email address]
0800 803 909 Enquiries
privacy.org.nz
11 February 2026
Sam Brown
By email only to: [FYI request #33427 email]
Tēnā koe
Official Information Act Request (Our Ref: OIA/0497)
We refer to your Official Information Act request received on 6 January 2026. We received
two requests from you – the second request being a more detailed version of the first
request.
Your requests covered the following relating to satellite internet providers
1. Any complaints, inquiries, or investigations received by your of ice regarding
satellite internet providers' data collection practices, data retention policies, or
handling of New Zealand user information.
2. Any assessment, advice, or guidance provided regarding whether satellite
internet providers routing New Zealand internet traffic through foreign
jurisdictions (particularly United States data centres) complies with New Zealand
privacy law, including consideration of Privacy Act requirements and
international data transfer obligations.
3. Any advice provided to government agencies or Ministers regarding data
sovereignty implications of government agencies, emergency services, or critical
infrastructure operators using satellite internet services where traffic routing and
data storage occurs outside New Zealand jurisdiction.
4. Any correspondence with satellite internet providers regarding their privacy
practices, data handling procedures, or compliance with New Zealand privacy
requirements.
5. Any assessment of whether users of satellite internet services receive adequate
privacy protections compared to terrestrial internet services, particularly
regarding exposure to foreign signals intelligence collection or disclosure
requirements under foreign legislation such as the United States CLOUD Act.
You indicated that the context for your request is seeking to understand whether privacy
and data sovereignty implications have been adequately assessed as New Zealand
increases reliance on satellite internet services that route traffic through foreign
jurisdictions.
OIA/0497/A1150653
link to page 2
2
Our response
Having checked our records, we do not hold information in scope of points 2-5.
It is not possible to identify whether we hold information in scope of point 1 without
substantial collation and research, as our files are not held in a way that means we can
identify this issue without manually checking numerous files.
Your request (points 2-5) is therefore declined under section 18(e) of the Of icial Information
Act. Your request (point 1) is declined under section 18(f) of the Of icial Information Act.
While we are not able to provide the information requested, I can confirm that the Of ice is
aware of the privacy issues relating to satellite internet services and may provide advice in
future should this issue be raised with us.
For your information, some of the relevant human rights considerations are set out in this
report from Access Now – Holding Space for Human Rights: Improving the Governance of
Satellite Internet Connectivity (February 2025).
1
Please note that if you are not satisfied with this response to your request, under section 28
of the Of icial Information Act 1982 you have the right to ask the Ombudsman to investigate
and review our decision on your request, however we would appreciate the opportunity to
discuss this with you first.
Nāku iti noa, nā
Liz MacPherson
Deputy Privacy Commissioner
1
https://www.accessnow.org/wp-content/uploads/2025/02/Holding-Space-for-Human-Rights-
a-bid-for-better-governance-of-satellite-internet-connectivity.pdf
OIA/0497/A1150653
