FORMAL GOVERNANCE COMPLAINT AND NOTICE OF REGULATORY ESCALATION
To:
Chief Executive and Privacy O icer
Horizons Regional Council
Cc:
Board of Directors – Manawatū-Whanganui LASS Limited (MWLASS)
Subject:
Formal Complaint – Alleged Misuse of Position, Privacy Breach, Doxing, and Defamatory
Publication by Martyn Lindsay Boyce
This document constitutes a
formal governance complaint concerning the conduct of
Martyn
Lindsay Boyce, Operations Manager of Manawatū-Whanganui LASS Limited (MWLASS), in
relation to the
collection, compilation, and public disclosure of personal information within
a sworn a/idavit filed in High Court proceedings CIV-2024-454-000074.
The matters raised in the attached complaint involve
serious concerns regarding:
• Unauthorised collection and disclosure of personal information
• Publication of private personal identifying information in a public court filing
• Allegations capable of causing reputational harm and embarrassment
• Potential misuse of organisational authority and resources
• Conduct capable of constituting “doxing” and defamatory publication
The complaint identifies potential issues arising under the following legislation:
• Privacy Act 2020
• Local Government Act 2002
• Companies Act 1993
• Harmful Digital Communications Act 2015
• Harassment Act 1997
• Defamation Act 1992
• Crimes Act 1961
• Public Records Act 2005
• Local Government O icial Information and Meetings Act 1987
The attached complaint also raises questions regarding
governance accountability for a
council-controlled organisation and the potential use of publicly funded resources in the
preparation and publication of the material in question.
For clarity, this notice also confirms that:
• A
formal complaint will be lodged with New Zealand Police requesting assessment of
potential criminal o ences.
• Regulatory escalation may occur to the
O/ice of the Privacy Commissioner and the
O/ice
of the Auditor-General should the issues raised require independent review.
Requested Action
Given the seriousness of the issues raised, I respectfully request that:
1. This complaint be
acknowledged within five (5) working days.
2. A
formal investigation be initiated into the conduct described.
3. Relevant governance oversight bodies within Horizons Regional Council and MWLASS
be
notified of the complaint.
A
record preservation notice is included within the attached complaint requiring the
preservation of all relevant communications, records, and electronic information relating to the
matters raised.
Attachments
Formal Complaint – Breach of Sta Code of Conduct, Privacy Breach, Defamation and Misuse
of Position
Supporting documentation and a idavit references
Submitted by:
Date: 12 March 2026