PRIVACY POLICY
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