Purpose

At General and Travel Investigations Limited (GTI), we recognise that every person has their own intrinsic worth, or mana, and that their wellbeing, or mauri, should be protected and upheld. We acknowledge that some individuals face challenges that may impact their ability to engage fully in interactions and processes. This policy ensures that we identify, support, and protect those who may be vulnerable, enabling them to access our services and participate in our processes fairly and with dignity. It also sets out clear guidelines for identifying, reporting, and responding to potential abuse or neglect.

Scope of the Policy

This policy applies to all employees and contractors representing and its partners, who interact with members of the public while carrying out their duties.

Key Principles

• Proactively identify and address potential risks to vulnerable individuals while upholding their mana.

• Treat all individuals with respect and dignity, ensuring that their mauri (wellbeing) is nurtured.

• Ensure all potential vulnerabilities are considered during interactions and that appropriate safeguards are implemented to support the individual. 

• Mandatory reporting of suspected abuse or neglect to the instructing agency, and/or appropriate authorities, while ensuring culturally appropriate processes are followed.

• Maintain detailed records of all concerns, assessments, actions taken, and communications.

Definition of a Vulnerable Person

A Vulnerable Person is someone who may be disadvantaged or require additional support due to:

• An intellectual or physical disability

• Mental illness

• Financial hardship

• Domestic or family violence

• Homelessness

• Language barriers (English not being their primary language)

• Literacy issues

• Age (i.e., minors and elderly individuals)

• Remote location

• Cultural background

• Cognitive impairment

Identifying a Vulnerable Person

Our employees and contractors should remain vigilant for signs that a person may be in a vulnerable situation. A person may be identified as vulnerable at any stage of interaction based on:

• Information contained in client instructions or documents obtained during investigations (e.g., medical or police reports).

• Observations made during direct interaction with the individual.

• Information provided by a representative, guardian, or support person.

• Direct disclosure from the person themselves.

• Changes in behaviour, physical appearance, or wellbeing.

Recognizing someone as vulnerable does not affect our obligation to act impartially, but it may require a flexible approach to accommodate their specific needs.

Reporting Procedures

• If a person is in immediate danger, call emergency services immediately.

• Report concerns to the Instructing Agency using the secure, confidential reporting lines. 

• In cases of suspected abuse or neglect, report concerns to relevant external agencies such as Oranga Tamariki or the Police.

Supporting Vulnerable People

The type of assistance required will depend on the nature of the person’s vulnerability. Support measures may include:

• Informing the person of their right to have a support person, advocate, or kaumātua present and facilitating this where possible.

• Ensuring that an appropriate adult is present when dealing with minors.

• Arranging for assistance, such as accredited interpreters or cultural liaisons.

• Offering flexible arrangements for interviews, including video conferencing for those in remote locations.

• Our employees may discuss other options with the vulnerable person to determine the most appropriate form of support.

Staff Training and Awareness

• All staff must complete training on identifying and responding to vulnerable persons.

• Training should cover relevant legislation, reporting procedures, and best practices for supporting vulnerable individuals.

Confidentiality

• All information related to vulnerable individuals must be treated with the utmost confidentiality, adhering to privacy laws and respecting cultural sensitivities.

• While considering the above, maintain detailed records of all concerns, assessments, actions taken, and communications.

Implementing the Policy

Implementation of this policy is the responsibility of the Director.

GTI will implement this policy by:

• Providing awareness training to employees and contractors who are likely to interact with vulnerable individuals.

• Ensuring employees and contractors understand their responsibilities under this policy.

• Developing and maintaining procedures that employees and contractors must follow when dealing with vulnerable persons.

• Regularly review and update the policy to reflect changes in legislation and best practices.

• Monitor the effectiveness of reporting and response mechanisms.

The aim of these procedures is to ensure that vulnerable individuals interacting with GTI and its representatives are treated with dignity and respect, with their mana upheld and their mauri nurtured.

Approved by: Brook Ballantyne
Published: 1st Feb 2025

Introduction

General and Travel Investigations Limited (GTI) conducts factual investigations as instructed by our clients to assist them in carrying out their lawful business activities and meeting their obligations under various legislation. We also conduct investigations to assist clients in managing human resource issues, grievances, allegations of misconduct, and suspected fraud or potentially illegal behavior.

Why We Collect Personal Information

To provide these services, we may collect Personal Information and Sensitive Information about individuals.

Personal Information refers to information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) Whether the information or opinion is true or not; and
(b) Whether the information or opinion is recorded in a material form or not.

We need to collect this information to properly investigate matters referred to us by our clients and provide them with the facts, evidence, and information they require to carry out their lawful functions.

We may also use Personal Information relating to our clients and service providers to conduct research, better understand client needs, provide information about our services, and engage in business development and marketing activities.

We are committed to protecting the privacy and security of all Personal and Sensitive Information that we collect. Our Privacy Policy complies with the Privacy Act 2020 (New Zealand) and the Privacy Act 1988 (Australia), including the New Zealand and Australian Privacy Principles.

Types of Information We Collect

To carry out our functions, we may collect and hold the following types of personal information:

• Name, date of birth, gender, and contact details.

• Information relevant to a claim or complaint under investigation, including:

  • Employment history and current employment details.

  • Underwriting information such as insurance claims history, criminal and traffic records.

  • Financial information such as assets, liabilities, and bank account details.

  • Sensitive information such as medical history (where relevant to an investigation).

  • Video footage of individuals and their activities.

Additionally, we collect necessary information from our service providers, including:

• Name, address, contact details, and business/company details.

• Licensing details.

How We Collect Information

We may collect information about individuals in various ways, including:

• From our instructing clients.

• Directly from individuals via phone, email, or interview.

• By means of covert surveillance, where permitted by law and relevant to the investigation.

• From publicly available sources such as the internet, including social media.

• From third parties, including witnesses, complainants, and other involved parties.

• From entities or individuals overseas where relevant to the investigation.

• By formal information requests to government agencies such as the Police and other authorities.

Where reasonable and practicable, we will collect Personal Information directly from the individual. Before conducting an interview or statement, our investigator will introduce themselves, explain whom they represent, and state the purpose of their inquiry. Investigators will seek consent to collect, use, and disclose personal information and will record this consent in the statement or interview.

There may be circumstances where we must collect information from other sources or third parties. In such cases, we will only use lawful and fair means to collect information.

How We Use and Disclose Personal Information

We only collect information that is directly relevant to the purpose for which we are collecting it, as well as related purposes that individuals would reasonably expect. Personal and Sensitive Information is used only for the investigation of claims or complaints and is not disclosed to unauthorized parties or used for any other purpose unless required by law.

All collected information is treated as strictly confidential and is generally only disclosed to the instructing client or, where authorized, to their legal representation.

Other parties we may disclose Personal Information to include:

• Service providers or consultants engaged to conduct specialist tasks (e.g., forensic accountants).

• Government, statutory, regulatory, or enforcement bodies, where required by law.

• Legal advisors or consultants.

Transfer of Data Overseas

We may disclose Personal Information to overseas entities where necessary for the investigation of a claim or complaint. For example, if instructed to investigate an overseas incident, we may disclose information to a local service provider to conduct inquiries.

Where we disclose Personal Information to an overseas entity, we take reasonable steps to ensure compliance with New Zealand and Australian privacy laws. Our contractual arrangements with service providers generally include obligations to protect privacy.

Data Security

We use physical and information technology security measures, including biometrics and multi-factor authentication (MFA) to protect the information we hold. Access to Personal Information within GTI is appropriately limited to prevent misuse or unlawful disclosure.

Employees receive training on New Zealand and Australian Privacy Principles. Employees and contractors engaged by GTI are contractually bound to comply with these principles and to keep all information secure.

Data Retention

Personal Information is retained only for as long as necessary for the investigation or as required by law. Once no longer required, information is securely destroyed or de-identified.

Access to Personal Information

Individuals may request access to their Personal or Sensitive Information by contacting us at Privacy@GTI.co.nz

Requests for access will be handled in accordance with the Privacy Principles of the requester's country of origin.

Complaints Process

If you believe GTI has handled your Personal Information inconsistently with the New Zealand or Australian Privacy Principles, you may submit a written complaint, including details and supporting evidence, to:  

Privacy@GTI.co.nz.

We will:

• Acknowledge receipt of your complaint.

• Investigate the matter and determine necessary actions.

• Provide a response upon completion of our investigation.

If you are unsatisfied with our response, you may escalate your complaint to the Office of the Privacy Commissioner (New Zealand) or the Office of the Australian Information Commissioner (OAIC).

Approved by: Brook Ballantyne
Published: 1st Feb 2025

1. Purpose

General and Travel Investigations Limited (GTI) is committed to conducting investigations with professionalism, integrity, and compliance with all applicable laws and regulations, including the Private Security Personnel and Private Investigators Act 2010, the Fair Trading Act 1986, the New Zealand Fair Insurance Code, and the General Insurance Code of Practice (GICOP). We acknowledge the importance of addressing complaints in a fair, transparent, and timely manner.

2. Scope

This policy applies to all complaints regarding:

• The conduct of our investigations or investigators

• Alleged breaches of privacy, ethical standards, or legal obligations

• Service quality and timeliness

• Compliance with the GICOP, the New Zealand Fair Insurance Code, or insurance industry standards

3. How to Make a Complaint

We encourage complainants to raise concerns as soon as possible. Complaints can be submitted via:

• Email: Admin@GTI.co.nz

• Post: General and Travel Investigations Limited, PO Box 302196, North Harbour 0751, New Zealand

All complaints should include:

• The complainant’s full name and contact details

• A clear description of the issue

• Any supporting documentation

• The preferred outcome or resolution

• Legal or Support persons details (if relevant)

4. Complaint Handling Process

4.1 Acknowledgement

• We will acknowledge receipt of the complaint within five business days.

• If additional information is required, we will request it within this timeframe.

4.2 Investigation & Assessment

• The complaint will be reviewed by an independent senior staff member who was not involved in the matter.

• We will conduct an internal investigation in line with legal, ethical, and insurance industry standards.

• If the complaint relates to an insurer-related matter, we will liaise with the insurer where appropriate.

4.3 Response & Resolution

• We aim to provide a written response within 20 business days of receiving all necessary information.

• If the issue requires more time, we will update the complainant on progress and provide an estimated resolution timeframe.

• If we determine that corrective action is required, we will implement appropriate measures.

5. Escalation Process

If a complainant is not satisfied with our response, they may escalate their complaint to:

• The Insurance & Financial Services Ombudsman (IFSO)

  • Website: www.ifso.nz

  • Phone: 0800 888 202

• The Insurance Council of New Zealand (ICNZ) for Fair Insurance Code compliance concerns

  • Website: www.icnz.org.nz

  • Email: info@icnz.org.nz

• Private Security Personnel Licensing Authority (PSPLA) for matters related to private investigation conduct

  • Website: www.justice.govt.nz

  • Email: pspla@justice.govt.nz

6. Confidentiality & Fair Treatment

• All complaints will be treated confidentially and handled with respect.

• Complainants will not be subjected to adverse treatment for lodging a complaint.

• We will ensure that our complaint process does not interfere with ongoing investigations unless required by law.

7. Continuous Improvement

We regularly review complaints to identify trends and implement improvements in our processes, ensuring compliance with industry best practices, the New Zealand Fair Insurance Code, and regulatory requirements.

For any questions regarding this policy, please contact us at Admin@GTI.co.nz

Approved by: Brook Ballantyne
Published: 1st Feb 2025

1. Purpose

General and Travel Investigations Limited (GTI) is committed to maintaining the highest standards of integrity, impartiality, and professionalism in all investigations. This policy ensures that potential or actual conflicts of interest are identified, disclosed, and managed in accordance with legal, ethical, and industry standards, including the Private Security Personnel and Private Investigators Act 2010, the Fair Trading Act 1986, the New Zealand Fair Insurance Code, and the General Insurance Code of Practice (GICOP).

2. Scope

This policy applies to all employees, contractors, and agents engaged by GTI. It covers:

• Personal, financial, or business relationships that may affect impartiality

• Engagements that create competing interests between clients

• Any situation where professional judgment could be compromised

3. Identifying Conflicts of Interest

A conflict of interest may arise when:

• An employee or agent has a personal or financial interest in the subject of an investigation

• There is a pre-existing relationship with a party involved in the case

• The investigator has previously worked on related matters that may compromise objectivity

• Accepting an assignment could result in a conflict with an existing client’s interests

Employees and agents are responsible for assessing whether a conflict exists and must disclose any potential conflicts before commencing work on an investigation.

4. Disclosure & Management of Conflicts

4.1 Disclosure Process

• All potential conflicts of interest must be disclosed in writing to senior management as soon as they are identified.

• A conflict disclosure form must be completed and submitted to Admin@GTI.co.nz

4.2 Review & Resolution

• The conflict will be assessed by senior management to determine whether it can be managed or if it necessitates withdrawal from the assignment.

• If the conflict can be mitigated, appropriate safeguards will be implemented, such as reassignment of the case to another investigator.

• Where a conflict cannot be resolved, GTI will decline or discontinue the engagement to maintain ethical and professional integrity.

5. Prohibited Conduct

To uphold ethical standards, employees, contractors, and agents must not:

• Investigate cases where they have a personal or financial interest

• Accept gifts, favors, or inducements that could influence decision-making

• Disclose confidential client information for personal gain

• Engage in outside work that conflicts with GTI responsibilities

6. Escalation & Compliance

Failure to disclose or manage a conflict of interest appropriately may result in disciplinary action, including termination of contract. Serious breaches may be reported to:

• Private Security Personnel Licensing Authority (PSPLA)

  • Website: www.justice.govt.nz

  • Email: pspla@justice.govt.nz

• The Insurance Council of New Zealand (ICNZ) for concerns related to the Fair Insurance Code

  • Website: www.icnz.org.nz

  • Email: info@icnz.org.nz

7. Continuous Review

This policy is reviewed annually to ensure alignment with industry best practices and regulatory requirements.

For any questions regarding this policy, please contact us at Admin@GTI.co.nz

Approved by: Brook Ballantyne
Published: 1st Feb 2025

1. Purpose

General and Travel Investigations Limited (GTI) ("the Company") is committed to conducting business with integrity, transparency, and accountability.

This Anti-Bribery and Corruption Policy ("Policy") sets out the Company’s stance on bribery and corruption and provides guidance to employees, contractors, and business partners on how we uphold our ethical standards.

2. Scope

This Policy applies to all employees, contractors, consultants, agents, and any other individuals or entities acting on behalf of the Company, regardless of location.

3. Definition of Bribery and Corruption

Bribery refers to offering, giving, receiving, or soliciting anything of value to improperly influence a business outcome or gain an unfair advantage.

Corruption refers to dishonest or fraudulent conduct by those in power, typically involving bribery.

4. Prohibited Conduct

The Company strictly prohibits:

• Offering, promising, or giving a bribe to any person or entity, including government officials, clients, or suppliers.

• Soliciting, accepting, or receiving a bribe.

• Making facilitation payments (small, unofficial payments to expedite routine actions).

• Engaging in corrupt practices, including fraud, embezzlement, or misuse of assets.

5. Gifts, Hospitality, and Entertainment

Employees and representatives of the Company must:

• Ensure that any gifts, hospitality, or entertainment provided or received are reasonable, proportionate, and transparent.

• Not offer or accept gifts intended to improperly influence a business decision.

• Seek approval for gifts, hospitality, or entertainment exceeding a reasonable threshold as defined in Company guidelines.

6. Third-Party Relationships

The Company requires due diligence when engaging third parties, including suppliers and business partners. 

7. Reporting and Whistleblowing

Employees and business partners must report any suspected or actual breaches of this Policy.

Reports can be made confidentially via Privacy@GTI.co.nz  

Please provide details of the matter and supporting evidence.

The Company prohibits retaliation against individuals who report in good faith.

8. Compliance and Training

All employees must complete anti-bribery and corruption training as required by the Company.

Compliance with this Policy is mandatory, and breaches may result in disciplinary action, including termination of employment or contract.

9. Consequences of Non-Compliance

Non-compliance with this Policy may result in severe legal and reputational consequences, including criminal liability for individuals and the Company.

The Company reserves the right to take disciplinary action, up to and including termination and legal action, for any violations.

10. Review and Amendments

This Policy will be reviewed periodically to ensure effectiveness and compliance with relevant laws and regulations.

Amendments may be made as necessary.

For any questions or concerns regarding this Policy, please contact Privacy@GTI.co.nz  

Approved by: Brook Ballantyne
Published: 1st Feb 2025

At General and Travel Investigations (GTI), we are committed to sustainability and environmental responsibility.

We prioritize minimizing unnecessary travel and promoting online video meetings to reduce our carbon footprint and conserve resources.

Embracing virtual communication platforms as our preferred method of interaction enables us to maintain productivity and collaboration while reducing the need for physical travel.

In alignment with our sustainability goals, we aim to minimize paper usage wherever possible and prioritize digital documentation and communication channels.

By leveraging electronic workflows, electronic signatures, and secure online platforms, we not only reduce our environmental impact but also enhance data security and confidentiality.

Our employees are encouraged to adopt digital practices and receive training and support to transition to paperless operations.

Through these efforts, we strive to contribute to environmental conservation while upholding the highest standards of information security and efficiency in our operations.