22 May 2026
File Ref: OIAPR-1274023063-50442
Miss M Quicken
By email:
[FYI request #33695 email]
Tēnā koe Miss Quicken
Request for information 2026-209
I refer to your request for information dated 11 February 2026, which was received by Greater
Wellington Regional Council (Greater Wellington) on 13 February 2026. You have requested the
following:
“Snapper, when tagging on and off indicates whether the user is:
a) Connect
b) Child
c) Normal Adult fare
This is visible to everyone in the bus on either the public transport onboarding or departing the
bus.
Please provide the impact assessment that was done re:
a) Privacy
b) Human rights
Around the functional analysis of the Snapper system when both introduced and maintained
given the evolution of laws.”
Greater Wellington’s response follows:
Your request has been assessed under the Local Government Official Information and Meetings
Act 1987 (the Act).
Wellington office
Upper Hutt
Masterton office
0800 496 734
PO Box 11646
PO Box 40847
PO Box 41
www.gw.govt.nz
Manners St, Wel ington
1056 Fergusson Drive
Masterton 5840
[email address]
6142
As noted in our letter dated 14 May 2026 acknowledging your request and our delay in
responding to you, we advised we would provide you with any additional information from
Snapper regarding your request when we received it. The following response has been
provided by Snapper:
“Snapper has not undertaken a formal Privacy or Human Rights Impact Assessment specific
to concession notification functionality, either at launch or as a recurring review. The current
approach is the product of research carried out during the rollout of the Integrated Bus
Ticketing System (IBTS) and our subsequent rail deployment, where we worked to balance
privacy considerations against the customer experience as carefully as we could. The
resulting designs were reviewed and signed off by Greater Wellington Regional Council.
The rationale for surfacing concession information at the moment of tag-on is to give the
customer immediate confirmation that they are receiving the correct concession and being
charged the correct fare.
The applied concession is also displayed on the Bus Driver Console and announced audibly at
the validator. This is intentional: it enables the driver to request identification where
appropriate. Under the conditions of carriage, customers travelling on certain concessions
are required to carry valid ID.”
Public transport ticketing systems are designed to ensure customers pay their correct fare. In
this case, the general disclosures of a person’s concession type (child or student) are
necessary for the bus driver to ensure the correct fare is paid. These requirements are also
included in Metlink’s conditions of carriage.
As no impact assessments were done, we are therefore refusing this request under section
17(e) of the Act under the grounds that the document alleged to contain the information
requested does not exist.
If a request is likely to be refused under section 17(e) of the Act we must, before the request is
refused, consider whether consulting with the person who made the request to assist that
person to make the request in a form that would remove the reason for the refusal. In this case
we have considered consulting and we don’t believe that it would remove the reason for the
refusal.
If you have any concerns with the decision(s) referred to in this letter, you have the right to
request an investigation and review by the Ombudsman under section 27(3) of the Act.
Nāku iti noa, nā
Samantha Gain
Kaiwhakahaere Matua Waka-ā-atea | Group Manager Metlink
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