Privacy Policy

PURPOSE
To ensure that Dress for Success Northland (DFS) and MahiPlus collects, records,
stores and uses all information respectfully and lawfully.

SCOPE
This policy is applicable to DFS/ MahiPlus board, staff (including contractors), donors, clients
and volunteer members.

PRINCIPLES

• We commit to compliance with the Privacy Act 2020 in the creation and implementation of this policy.

• Our values, Manaakitanga, Kotahitanga and Whakamana, guide and inform the implementation of this policy.

• We acknowledge He Whakaputanga o te Rangatira o Nu Tireni me te Tiriti o Waitangi as founding constitutional documents of Aotearoa New Zealand. The intent and articles of each founding document, guide and inform the implementation of this policy.

RESPONSIBILITES

Privacy Officer
The Privacy Act 2020 requires the appointment of a designated Privacy Officer to ensure DFS
/ MahiPlus complies with the Act.

The Executive Manager is appointed as Privacy Officer for DFS / MahiPlus is present on site
daily and is trained and understands the privacy requirements.

Governance Oversight
Privacy matters are reviewed regularly by the DFS / DTI governance board. The Privacy
Officer reports to the governance board at each governance meeting and risks of breaches sits with
the governance board.

PROCEDURE

Data Collection
DFS / MahiPlus collects personal information from the people they work with, for lawful purposes connected with its functions and activities.

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Any personal information held by DFS / MahiPlus, will never be sold, rented or exchanged
with any other organisation or any other entity in existence unless lawfully allowed for.

We collect personal information in order to complete our individual dressing or career
service.

Information is collected from clients or external agencies who make referrals to us. We
collate and anonymise statistical information about gender, ethnicity, marital status, age and
number of dependents for our own reporting purposes.

Besides our staff, we may share collected information with external referring agencies to
complete service referrals. Collated anonymised statistical information is used to support
requests for funding and to report to Dress for Success worldwide on our activities.

DFSN/MahiPlus does not collect information from children or young people under the age of
18 years.

We keep information safe by storing it in secure files and only allow relevant staff to access
it.

We keep information for two years at which point we securely destroy it by erasing it
digitally or securely destroy paper files.

Consent
DFS / MahiPlus collects personal information directly from the individuals we work with in
the first instance where possible. Information is collected from clients following a documented
informed consent procedure. Informed consent includes the following verbal and/or written explanations:

 

• that their information is given voluntarily;

• about the lawful purpose supporting their information collection;

• about who will view and have access to their information;

• that their information will be securely stored in accordance with the DFS / DTI Record
   

Retention & Destruction Policy;

• about any other information impacting on the execution of this policy relevant to the Privacy Act 2020 and its amendments. 

• Collection and use of sensitive personal information requires explicit additional consent from the individual concerned.

Access and Amendment of Information
Clients and staff are informed of their right to access a copy of any personal information held
by DFSN/MahiPlus. Clients and staff have the right to request the amendment of any personal
information held if they think the information is not correct by contacting The Executive
Manager by email northland@dressforsuccess.org

Training
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The Executive Manager will ensure that they and all staff are trained to the appropriate level
regarding the organisation’s obligations under the Privacy Act 2020 by conducting regular
privacy focused staff training. Regular privacy focused staff training includes, but is not
limited
to:

• Completion of online training course(s) provided by the Privacy Commissioner,

• Privacy principles training;

• DFS / MahiPlus privacy policies and procedures

• Annual training covering informed consent, collection and use of personal information and responding to privacy breaches and complaints.

Privacy Breaches
DFSN/MahiPlus promptly manages and responds to privacy breaches, including prompt
notification to affected individuals and the Privacy Commissioner, where there is a serious
privacy breach, in accordance with this policy and legislation.

Privacy Complaints
DFS / MahiPlus uses its complaints process to respond promptly to privacy-related
complaints by individuals. Staff are aware of the complaints procedure and how to escalate
complaints to the Privacy Officer. Responses to privacy complaints will be made by the
Privacy Officer, in a timely and effective manner, addressing concerns and taking necessary
remedial actions. The Governing Board will be notified of all Breaches & Complaints Reviews.
The Privacy Officer will conduct regular reviews of DTS/DTI procedures designed to protect
the privacy of individuals who engage with DFS/DTI with regular reports to the governance
board.

Guidance
Privacy Act 2020 – Principle 1, 2, 3, 4, 6, 7, 8, 10, 11

Office of the Privacy Commissioner, Te Mana Mātāpono Matatapu Elearning

https://www.privacy.org.nz/tools/online-privacy-training-free/

Social Sector Accreditation Standards Level 4, Governance and management structure and
systems 2., 2.1, 2.3 https://xn--tekhuikhu-7bbe.govt.nz/documents/whatis
accreditation/accreditation-standards/level-4-social-sector-accreditation-standards.pdf

Dress for Success Northland / MahiPlus Complaints Policy & Procedures v.1

Dress for Success Northland / MahiPlus Record Retention and Destruction Policy & Procedures v.1