This policy relates to Vested’s collection and handling of personal information that is covered by the Privacy Act. It is not intended to cover categories of personal information that are not covered by the Privacy Act.
Collection of Personal Information
Vested collects and holds personal information from clients, suppliers, candidates, employees, contractors and other individuals. We collect and hold this information when it is necessary for business purposes.
Typically, the personal information we hold includes names, addresses, telephone numbers, e-mail addresses and job titles. While providing professional services to our clients, we may collect and hold more detailed personal information (for instance financial details if we are engaged to perform financial services, or credit information); and when recruiting employees, we will collect and hold CVs and other evaluative information.
We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face to face meetings, email messages, telephone conversations or by third parties. If you contact us, we may keep a record of that contact.
Because of the nature of our business, it is generally impracticable for us to deal with individuals on an anonymous basis or using a pseudonym, although sometimes this is possible (for example, when seeking staff or client feedback generally).
Use of Personal Information
The main purposes for which we collect, hold and use personal information are:
- to provide our services;
- to respond to an individual’s request;
- to maintain contact with clients;
- to keep clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars and other events we are holding;
- for general management and reporting purposes, such as invoicing and account management;
- for recruitment purposes;
- for purposes related to the employment of our personnel and providing internal services to our staff. If you choose not to provide us with personal information, we may be unable to do such things.
We may collect, hold and use personal information about individuals to market our services, including by email. However, individuals can elect not to receive further marketing information from us by writing to us at email@example.com.
Alternatively, if we have contacted you by email, you may use the unsubscribe function in that email to notify us that you do not want to receive further marketing information from us by email.
If we collect, hold or use personal information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the Privacy Act.
Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by Vested. For information about our practices relating to employee information, please contact us directly.
Disclosure of Personal Information
Vested does not routinely disclose personal information to other organisations unless:
- use or disclosure is permitted by this policy;
- we believe it is necessary to provide you with a product or service which you have requested (or, in the case of a partner, employee or contractor of Vested, it is necessary for maintaining or related to your role at Vested);
- to protect the rights, property or personal safety of any member of the public or a customer of Vested or the interests of Vested;
- some or all of the assets or operations of Vested are transferred to another party as part of the sale of some or all of Vested’s business;
- you give your consent;
- or such disclosure is otherwise required or permitted by law, regulation, rule or professional standard.
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell to or trade personal information with third parties.
Vested uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations (including internal business requirements, such as recruitment and human capital requirements). This means that individuals and organisations outside of Vested will sometimes have access to personal information held by Vested and may collect or use it from or on behalf of Vested. This may include, but is not limited to, independent contractors and consultants, travel service providers, mail houses, off-site security storage providers, information technology providers, event managers, credit managers and debt collecting agencies. We require our service providers to adhere to our privacy guidelines and not to keep, use or disclose personal information we provide to them for any unauthorised purposes.
If Vested staff obtain products or services offered by a third party pursuant to an agreement or arrangement between that third party and Vested, such as a credit card provider, we may provide your personal information to that third party, including information that relates to your use of such services.
Storage of Information in Cloud Systems
Vested may store personal information within services provided by offshore cloud service providers (CSP). Currently, Vested only utilises the services of CSP who can provide a guarantee that information remains within a specific geographic location within the CSP infrastructure. Vested utilises cloud services from a CSP who has met the data sovereignty and data privacy framework stipulated by the New Zealand Government.
Privacy on our Websites and Applications
This policy also applies to any personal information we collect via our websites, including vested.co.nz, and applications including mobile applications. In addition to personal information you provide to us directly (such as where you make a request or complete a registration form), Vested may also collect personal information from you via its applications and websites.
To properly manage our websites and applications, we may log certain statistics about the users of the facilities, for example the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites and applications present the best possible navigational experience for users.
If you have registered an account with us, you will be identified by a user name and password when you log into our website or applications. The information we collect about members’ use of our websites may be used for measuring use and performance and in assisting to resolve any technical difficulties.
Security of Personal Information
Depending on the purpose for which we have collected personal information (for example, registration for a Vested event or a request for particular information or material), we may store some of the information electronically in Vested’s customer relationship management system. Some or all of this personal information may be available to partners and authorised staff of Vested for use in accordance with this policy.
Vested will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard-copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by Vested.
Vested aims to achieve industry best practice in the security of personal information which it holds. It is our policy not to retain personal information once there is no longer a legal or business need for us to do so.
Access to Information
We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another person’s privacy).
When you make a request to access personal information, we will require you to provide some form of identification (such as a driver’s licence or passport) so we can verify that you are the person to whom the information relates. In some cases, we may also request an administrative fee to cover the cost of access.
If at any time you want to know what personal information we hold about you, you may contact us by email firstname.lastname@example.org.
Corrections and Concerns
If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us and we will try to resolve those concerns.
If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, auditing or internal risk management reasons).
Effect of Policy
Vested operates in a dynamic business environment and we aim to review this policy annually to keep it current.