In carrying out our business, it may be necessary for us to collect personal information from clients, residents, customers, employees, contractors and other individuals. The type of personal information that may be collected will be determined by the nature of our business relationship with the individual.
This document sets out our policy for the collection, use, disclosure and storage of personal information that is covered under the New Zealand Privacy Act 1993, as amended from time to time (the Act), and related Codes of practice, including the Health Information Privacy Code 1994 (the Code). We may, from time to time, amend and update this policy and publish the updated policy on our website.
General information about privacy and the operation of the Act, the Code, and other Codes of practice can be found at the Office of the Privacy Commissioner website at www.privacy.org.nz.
Definitions
In this policy, unless the context provides otherwise:
| > | our corporate website at www.campuslivingvillages.com; | |
| > | each Village website, a list of which is available at www.campuslivingvillages.com/village-locations; | |
| > | our social media accounts, which includes each Villages’ Facebook and Twitter accounts; and | |
| > | any ancillary portals provided through our websites, such as the Resident Portal or the Investor Portal which are accessible only by a unique username and password issued by us (or on our behalf) to you; |
www.campuslivingvillages.com/village-locations
We recognise that an individual’s right to keep personal information private is highly important. We are committed to protecting and maintaining the privacy, accuracy and security of personal information in accordance with the privacy principles established under the Act, specifically the Information Privacy Principles (the Privacy Principles).
By engaging with us (whether in person, by telephone or in writing, including by electronic means), you agree:
You have the right to refuse to provide us with personal information. However, if you decide to do so, we may be unable to conduct business with you.
We only collect personal information, by lawful and fair means, and only if such information is relevant to our business relationship with you.
The personal information we collect may typically include (as well as other information depending on the nature of our business relationship) your name, date of birth, contact details (such as address, telephone numbers, email addresses), next of kin or emergency contact details, bank details and, where applicable, information about tertiary education records, and history of any prior dealings with us.
We generally collect personal information directly from you (unless you otherwise provide your consent). The personal information we collect may be provided in forms or applications, or where you provide information to us over the telephone, in person or in writing (including by electronic means). If you contact us or engage with us by electronic means, we may also keep a record of that contact. We may collect personal information about you from third parties and will let you know if we do so.
If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under the privacy law if we had requested it, we will destroy or de-identify the information, if it is lawful and reasonable to do so.
We are committed not to use or disclose personal information that we have collected, other than in accordance with this policy and in the manner contemplated by the Privacy Principles. We will obtain your consent before we use your personal information for any other purpose.
We may use your personal information as follows, depending on the nature of our business relationship (as applicable):
Marketing and promotional uses
We may use your personal information to provide you with information about our services or products or those provided by third parties, that we believe may be of interest to you, to the extent this is part of our particular business relationship with you. To that extent, we may provide your details to such third party organisations for specific marketing purposes.
We may wish to refer to you based on the nature of our business relationship when marketing our business. We will only do so with your prior consent and will only disclose personal information to the extent to which you have consented.
You may opt out at any time if you do not wish to, or no longer wish to, receive marketing promotional information. To do so, you may contact us (in writing) and request that we no longer send promotional materials to you or disclose your information to other organisations for specific marketing purposes, or, where applicable, by clicking the “unsubscribe” button from promotional messages.
We may disclose your personal information (depending on the nature of our business relationship, as applicable):
Where it is necessary for us to give external third parties, such as contractors or consultants, access to personal information held by us, we take all reasonable steps to ensure that they are bound by confidentiality and privacy obligations with respect to the protection of your personal information.
For the purposes of this policy, “sensitive information” is:
We only collect sensitive information (including health information) about you with your consent, except where we are required or permitted by law to collect your sensitive information without your consent.
We will only use your sensitive information where it is directly related to provision of our goods or services to you, and such reasonable secondary purpose. Specifically, we may use information relating to:
We will not share your personal sensitive information with any company or person other than:
We take all reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations with respect to the protection of your personal sensitive information.
Your personal information may be stored in paper-based form or electronically in our systems.
We maintain physical security over our paper-based and electronic data storage and premises and computer and network security, which are aligned with current industry standards to ensure that your personal information is kept secure and confidential. This includes implementing reasonable procedures to our information technology systems to protect personal information that is kept on our systems from misuse, interference and loss and unauthorised access, modification or disclosure. We will notify you of any breach of security which may result in unauthorised access to your personal information.
As a result of our global operations (with operations in Australia, New Zealand, the United Kingdom and USA), we may transfer personal information to those regional operations (i.e. outside New Zealand). We may also transfer personal information to our overseas operations or contractors to process, store or back-up personal information. Those recipients are generally located in Australia, the United Kingdom or the United States of America. Any such transfer, however, does not change any of our commitments to safeguard your personal information under this policy.
Where we no longer require your personal information (including where we are no longer required by law to keep records relating to you), we will ensure that it is destroyed or de-identified.
With your help, we will keep your personal information accurate, complete and up to date.
In addition to personal information you may provide to us directly, we may also collect personal information from you when you access our websites via the cookies on our websites, to which this policy also applies.
A ‘cookie’ is a small text file which is placed on your internet browser and which we access each time you visit our website. The cookie allows us to obtain information about how our website is being used. Cookies may be used by us for various reasons, including remarketing across the internet through Google Adwords, maintaining website security, monitoring website traffic, measuring website performance and improving the navigational experience of our websites. We do not use cookies to identify you or any other user.
If you do not wish to receive cookies when using our websites, you should select the appropriate “opt-out” setting in your web browser.
Our website may contain links to third party websites that are not operated by us. We are not responsible for the privacy practices or policies of those sites and encourage you to review each website’s privacy policy and/or terms of use, especially if you intend to disclose any personal information via that site.
A link to any third party website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.
You may request access to the personal information we hold about you by contacting us. We will respond to any such request within a reasonable time, subject to any applicable law.
If we cannot provide you with access, we will provide you with a written notice setting out the reasons for the refusal. For example, in certain circumstances you may not access information relating to existing or anticipated legal proceedings between you and us, where the request for access is frivolous or vexatious, where access might threaten the privacy of others or where access would be unlawful or prejudicial to law enforcement.
If you believe that personal information we hold about you is incorrect, incomplete or not current, you can request that we correct or update your personal information by contacting us in writing.
We will deal with your request within a reasonable time. If we do not agree with the corrections that you have requested, we are not obliged to alter your personal information accordingly. However, where we refuse to do so:
If you have any questions, concerns or complaints in connection with this policy (including any concerns about how we handle your personal information), please contact us in writing. We will respond to you as soon as possible.
If you are not satisfied with our response, please let us know and we will investigate further and work with you to resolve the matter.
Where we are not able to resolve the complaint with you, you may also refer the complaint to the Office of the Privacy Commissioner.
You may contact our Privacy Officer as follows:
You may contact our friendly Village staff by referring to the ‘Contact Us’ tab at the relevant Village website, which is listed at
www.campuslivingvillages.com/village-locations.