Privacy Policy

Kaenga Hou Trust Privacy Statement

Kaenga Hou Trust (“we”, “us”, “our”) is committed to protecting your personal information in accordance with the Privacy Act 2020. This Privacy Statement outlines how we collect, use, store, share, dispose and protect your personal information as a progressive home ownership provider and finance lender.

We adhere to the 13 Information Privacy Principles (IPPs) under the Privacy Act 2020.

Our Policy

We only use, store, and share personal information collected in accordance with this privacy statement and the Privacy Act 2020.

Scope

This privacy statement applies to all personal information, including personal information collected through our website, social media pages, phone calls, written communications we receive, meetings we conduct, and other interactions with you and the organisations we partner with to deliver our services.

This privacy statement also applies to personal information provided by the following persons:

• Our clients and potential clients, including people who participate, or apply to participate, in the programmes we administer and their authorised representatives;

• Persons who voluntarily provide us personal information, for example users of our website, those who contact us or connect with us on social media.

This statement applies to all capacities in which we exercise our duties, functions, and obligations. You accept this privacy statement when you interact with us or use our services.

Purpose of Collection

We collect personal information only when it is necessary for lawful purposes connected to our role as:

• A progressive home ownership provider;

• A finance lender for our home ownership programmes.

We collect information to:

• Assess your eligibility and suitability for our programmes;

• Enter into agreements (e.g., shared ownership or loan agreements);

• Monitor, manage, and enforce agreements, including financial lending;

• Meet legal, regulatory, and reporting obligations, including Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT) and the Credit Contracts and Consumer Finance Act 2003;

• Improve our services and respond to inquiries.

Source of Personal Information

We collect your personal information directly from you, through phone calls, emails, meetings, application forms, our website and social media.

We may also collect information about you from other people, such as:

• Our service partners contracted to deliver education and associated support services.

• Someone else you have authorised to provide us with personal information or to update your personal information, for example when someone else updates your details with us. We may ask your authorised person to show proof of connection to you.

• When we search publicly available information where relevant.

• Organisations, with your consent such as banks, credit reporting agencies etc.

• Biometric verification providers for AML/CFT compliance purposes.

• Third parties to undertake services on our behalf to enable us to perform our functions, and those third parties collect your information.

Collecting Personal Information

We may collect the following types of personal information:

• Identity Information: Name, date of birth, gender, ethnicity, identification documents such as your driver’s licence for identity verification.

• Contact Information: Phone numbers, address and email address.

• Financial Information: Income, expenses, debts, banking history, savings, and loan details.

• Credit history: including repayment history and any defaults, credit accounts, credit limits and other financial commitments.

• Household Information: Iwi affiliation, number of occupants, family composition.

• Personal circumstances: marital status, number of dependants, living situation

• Employment Information: Occupation, employment status.

• Interaction Data: Communications with us, website usage (cookies).

• Customer survey information: For reporting purposes to our funders.

• Information about your requirements, objectives and purpose: in connection with our products and services.

• Biometric Information: Facial recognition data collected solely for AML/CFT compliance purposes.

Providing your personal information to us is optional. However, failure to provide necessary personal information may limit our ability to deliver services or process applications.

Manner of Collection

We collect information in a lawful, fair, and transparent manner. You will always be informed of the purpose of collection, and consent will be obtained where required.

Storage and Security of Personal Information

We take all reasonable steps to keep your personal information secure. This includes:

• Restricting access to authorised staff only.

• Storing hard copies securely and using encrypted databases for electronic records.

• Partnering with reputable third-party service providers who meet privacy and security standards.

• Monitoring and maintaining our systems to prevent loss, misuse, or unauthorised access.

Right of Access and Correction

Subject to the exceptions in the Privacy Act 2020, you have the right to:

• Find out from us whether we hold personal information about you.

• Access that information.

• Request corrections of that information, if applicable. If you believe any information we hold is inaccurate, incomplete, or outdated, you may request a correction. If we decline, we will explain the reason and attach your requested correction to the record. If you request such a correction, we will inform you of the action taken as a result of the request.

If you want to find out whether we hold personal information about you, access that information, or request a correction, please email: kiaora@kaengahou.co.nz

We will respond to requests within 20 working days as required under the Privacy Act.

Accuracy Before Use

Before using your personal information, we will take reasonable steps to ensure it is accurate, up-to-date, complete, and not misleading.

Retention of Personal Information

We retain your personal information only as long as necessary to:

• Fulfil the purposes it was collected for;

• Meet our legal and regulatory obligations (e.g., financial lending requirements, AML/CFT compliance).

Personal information related to financial agreements will be retained for a minimum of 7 years to meet legal and regulatory requirements. Once no longer required, your information will be securely deleted or anonymised.

Use of Personal Information

We use your personal information to:

• Assess and process housing or loan applications and payments.

• Assess whether our products and services are suitable for you.

• Monitor and manage agreements (e.g., repayment schedules, shared ownership updates).

• Comply with legal obligations, including anti-money laundering and credit reporting, which includes identity verification.

• Communicate with you about our services or respond to inquiries.

• Improve our programmes and operations.

• Perform internal research and development to enhance services.

Sharing and Disclosure of Personal Information

We do not generally share your personal information with third parties unless sharing it is needed for the purpose for which you gave the information to us. However, we may share your personal information in the following circumstances:

• To your authorised representatives.

• To banks, credit reporting agencies, or lenders when assessing financial applications.

• To government agencies or regulators as required by law.

• To service providers (e.g., IT providers, auditors, legal advisers, insurers) under strict confidentiality.

• To our funding partners where relevant for reporting.

• To biometric verification providers for AML/CFT compliance.

• To credit reporting agencies to notify repayment history, defaults, or assess creditworthiness.

We will not disclose personal information to another person or agency unless we believe on reasonable grounds:

• the disclosure is directly related to the purposes for which the personal information was collected.

• the personal information is publicly available, and disclosure is not unfair or unreasonable.

• you have authorised the disclosure.

• the personal information will be used in a form where you are not identifiable; or

• non-compliance is necessary as set out in the Privacy Act 2020.

When we disclose your information to third parties, we make sure they are aware of the importance we place on protecting your privacy. They are required to keep your information confidential and only use it for the purpose for which we have supplied it, or as permitted or required by law. In all other cases we will only disclose your personal information if it is permitted under the Privacy Act 2020.

Unique Identifiers

We may assign unique identifiers (e.g., client ID numbers) where necessary to manage your application or programme involvement. These identifiers will be handled securely and used only for their intended purpose.

Cookies and Website Use

Our website uses cookies to enhance user experience. Cookies collect anonymous data about your browsing activity, such as:

• Pages visited.

• Browser type.

• IP address.

We may also use Google Analytics and similar tools to understand website usage. You can manually disable cookies in your browser settings, though this may impact website functionality.

Privacy Breaches

If there is a breach of privacy involving your personal information, we will comply with any legal obligations in the Privacy Act 2020. If there is a notifiable privacy breach (one which has caused or is likely to cause serious harm) we will:

• Notify the Office of the Privacy Commissioner.

• Inform affected individuals promptly.

• Take steps to contain and prevent further harm.

• Conduct an internal investigation and apply corrective measures where required.

Contact Us

If you have any questions, requests, or complaints regarding this Privacy Statement or your personal information, please contact our CEO:

Email: kiaora@kaengahou.co.nz

Address: 285 Lytton Road, Awapuni Gisborne 4010

If you are unsatisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner:

Website: www.privacy.org.nz

Phone: 0800 803 909

Policy Review

This Privacy Statement will be reviewed annually or when there are significant changes to relevant laws, operations, or systems.

Last Updated: 20 December 2024