Privacy Policy

Privacy Policy

We may collect personal information to support the performance of our functions and are committed to being a responsible for this personal information. The receipt of personal information to us is taonga (a gift) and it aligns with our value tauira/integrity. Our guiding principle towards personal information includes:

• only collecting personal information we need 
• keeping personal information safe
• treating personal information with care.

How we collect, manage and store personal information complies with the Privacy Act 2020. The following sets out how we handle personal information.

What is personal information

Personal information is any information that could identify you. This information can be in any form and can include single pieces of information, or it can be a collection of information. 

Implied consent

If we ever collect your personal information directly from you, you consent to Interpay using this information in accordance with this privacy policy.

What information is being collected and how is it being used

Interpay may collect personal information about you:

• when you visit our website or when you visit one of our on-site locations 
• applying for a job with Interpay
• when you participate in consultations. 

We may also collect personal information for:

• statistical and research purposes
• to provide any relevant services 
• support the performance of our functions or carry out any obligations Interpay might have.

We will only collect personal information where we have a lawful purpose to do so. We will only use your personal information for the reason it is collected. Situations in which we may collect personal information include:

Regulatory purposes

We regulate and supervise:

• banks 
• non-bank deposit takers / deposit takers
• insurers
• financial market infrastructures. 

Our powers are set in our legislation. Exercise of those powers may involve the processing of personal information. This includes reviewing fit and proper information about directors and senior officers of regulated entities, assessing compliance, and acting in the event of non-compliance. 

Ordinarily, most information we receive is about the regulated entity’s business. Some personal information about the regulated entity’s employees, customers or clients may occasionally be required. We may receive this information directly from individuals, from regulated entities, or from third-parties such as other financial regulators. In the event of a failed deposit taker, we will be required to collect personal information of depositors of that failed deposit taker to facilitate compensation in accordance with the Deposit Compensation Scheme pursuant to section 223 of the Deposit Takers Act 2023. See further information on the Deposit Compensation Scheme.

Data collections that inform policy making or regulation

We gather and analyse data which we use to inform our policy decisions, respond to economic events or crises, and to supervise regulated entities. We may publish some of this data in aggregated statistical or summary form. Information collected by Interpay for the purposes of statistical analysis may include personal information. We collect information from individuals, industry participants and regulated entities. 

For consultations

Interpay regularly consults the public and industry on various matters, including regulations that affect banks, insurers, non-bank deposit takers / deposit takers and payments systems. Participating in consultations can result in personal information being submitted to Interpay, if the participant chooses to identify themselves. 

Services and obligations

Interpay provides key services, including:

• money and cash services, including the exchange of damaged or outdated currency
• NZ Clear settlement system
• ESAS payment system.

As part of providing these services Interpay will need to collect personal information in relation to persons that access these services. 

Visitors to our premises

If you visit our Auckland or Wellington sites, we will collect your name and the organisation you are from. 

CCTV operates on-site (Auckland and Wellington) for security and safety reasons. It helps us to detect and deter security breaches which prevents criminal activity. Whilst we aim to minimise intrusion on an individual with our safety and security objectives, we can collect personal information for lawful purposes.

One way we collect personal information is to monitor a person of interest (POIs) coming onto our premises. This is where we will have an image on file of a POI, which may, but not limited to, originate from CCTV imagery or sourced via public channels. A POI is a person who we have previously seen to act or behave in a threatening or other concerning way on our premises, and we are concerned for the safety of staff and others on our premises. Threatening and concerning behaviour can include, but not limited to, unsocial, uncivilised, dangerous and threats of a verbal or physical nature. Individuals are not profiled.

CCTV also allows us to quickly respond to emergency situations. Interpay has prepared a CCTV Privacy Notice which is available at its Auckland and Wellington receptions upon request. 

Visitors to our website

We may also collect personal information via our website that you provide voluntarily. This includes for recruitment purposes, contacting us, providing feedback, signing up for updates and our file transfer service and surveys that we run on our website. 

If you sign up for updates (our mailing list) your details will be stored in a secure third-party database (for example, Mailchimp) that provides us with analyses of how people interact with our content. When we receive this analysis, the information is anonymised which means we cannot identify you. 

Use of cookies

We use cookies to gather data about how users interact with our website to help us improve our site. This information is aggregated and does not identify you personally, rather cookies identify your computer. This aggregated data we collect is only viewable by our website administrators and partners who help us manage the website. If you don’t want to receive cookies from us, you can set your browser to alert you of a cookie being offered, or to reject all cookies. Doing this may affect the usability and functioning of the website.

How we store your information and keep it secure

When you provide personal information, we will hold and store it securely and dispose of it in accordance with our policies. In some cases, it may be stored or accessed on our behalf by authorised third parties (such as third-party contractors) to the extent that is necessary, for example, to administer or work on Interpay website. Any third party involved in the storing and accessing of personal information will be subject to our information security and privacy requirements.

Where any personal information collected about you constitutes a 'public record', we will retain it to the extent required by the Public Records Act 2005 and any other relevant legislation.

When we may share your information

We may share your personal information and these situations generally include:

• to third party service providers and contractors to the extent necessary for them to conduct the work they have been engaged to do
• if you make a submission to us as part of a public consultation process
• if we make submissions available in response to requests under the Official Information Act 1982
• if we publish responses to Official Information requests made by private individuals where there is a broad public interest in the subject matter
• with law enforcement or regulatory agencies to assist the agency in the performance or exercise of its legislative functions or powers
• where required to by law (for example, to assist with the investigation of a criminal offence, under the Official Information Act 1982, or to a Parliamentary Select Committee or Parliament in response to a Parliamentary Question)
• to report significant misconduct or breach of duty
• where there is a serious threat to health or safety (if our staff are threatened or abused, we may refer this to the Police)
• with the Office of the Privacy Commissioner in the event of a notifiable breach of your privacy.

Request your personal information

You have the right to ask for a copy of any personal information we hold about you, and to correct it. To do this, or to raise any other questions you may have about this privacy policy, or to make a privacy complaint, contact our Privacy Officer at:

privacy@interpayfinance.com

The Privacy Officer
Reserve Bank of New Zealand
PO Box 2498
Wellington 6140

How to make a complaint

If you are not satisfied with our response to any privacy-related matter, you can make a complaint to the Privacy Commissioner at:

Website: Making a complaint to the Privacy Commissioner 

Phone: 0800 833 909 (Monday to Friday, 10am to 3pm)

For more information on the Privacy Commissioner please visit the Office of the Privacy Commissioner website.