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NILS and StepUP Loan Schemes – Privacy Statement

1.         Introduction

This Privacy Statement explains what happens to your personal information when you inquire about or participate in the No Interest Loan Scheme (“NILS”) and/or StepUP Loan Programme (each a “Programme”, and together the “Programmes”).  This Privacy Statement applies in addition to Good Shepherd New Zealand’s general privacy policy, which is available at www.goodshepherd.org.nz, and any privacy statement provided by your community provider, and/or your loan provider.

2.         We collect personal information

When you inquire about a NILS or StepUP loan, the entity receiving your inquiry (usually your community provider or Good Shepherd New Zealand) will collect the information that you disclose to them in your inquiry.  This will include at least your name and contact details, but may also include other information, like demographic data and how you intend to use the loan.

If you attend one or more interviews about a loan (whether in person, by telephone or otherwise), and if you apply for a loan, your community provider and the relevant loan provider will collect further information from you.  This information will include pay slips and bank statements, evidence of your household expenses, proof of identification, details of how you intend to use the loan, anything else that you disclose to us in the interview and the information on your application form.

If your application is successful and you take out a loan, your community provider and loan provider will collect further information about you as they interact with you throughout the term of your loan (including your payment history and records of any further communications they have with you regarding the loan).

In addition, if you later agree to participate in any detailed research or provide a client story, then we may collect further information from you as part of that.  What we collect and how we will treat that information will be disclosed to you at the time, and we will ask your consent in advance of collecting this further information.

3.         If we can’t collect your information, we may not consider you for a loan

Sometimes if we ask you to provide certain information, and you don’t provide it, we may not be able to continue with your loan assessment and application process, or provide you with a loan.

However, this does not apply to information we separately ask you to provide for research purposes or in connection with client stories – it is always completely optional as to whether you take part in those separate activities, and if you do not want to participate in that separate research or client story that will not affect the outcome of your loan application.

4.         Why we collect your personal information

Your personal information is collected in order to administer the NILS and StepUP Loan Programmes.  This includes:

a)     Receiving and processing inquiries and (where applicable) transferring your inquiry or application to the appropriate community provider and/or loan provider;

b)    Considering your eligibility for a loan, including your financial position;

c)     Assisting you to complete and submit a loan application, and negotiating with the community provider and/or loan provider if necessary;

d)    Assessing your loan application;

e)     Providing and administering your loan, including monitoring and assisting you to manage your repayments, and conducting audits, monitoring and training;

f)     Handling complaints;

g)    Reporting between the various parties involved in the NILS and StepUP Loan Programmes, including the relevant loan providers, community providers and Good Shepherd New Zealand, the Ministry of Social Development and other internal and external stakeholders;

h)     Carrying out research, assessment and analysis of our various projects and initiatives (on the basis that your personal information will not be published in a manner that identifies you unless you expressly consent to it);

i)      Contacting you in relation to your loan, and requesting your consent to participate in further detailed research or client stories from time to time.

Good Shepherd New Zealand, your loan provider and your community provider also conduct research, evaluation and statistical analysis relating to the NILS and StepUP Loan Programmes.  Generally, your personal information will be de-identified before any research is published.  If we want to publish any research or other information that identifies you, Good Shepherd New Zealand or your community provider will get in touch with you and ask your permission first.

5.         How your personal information is used

Your personal information is used to carry out the above purposes of collection (paragraph 4).  Your personal information may only be used for another purpose if permitted under the Privacy Act 1993, or with your consent.

6.         Who your personal information is disclosed to

Generally your personal information is only disclosed where this is to carry out the purpose of collection (paragraph 4), or where permitted by the Privacy Act 1993.

However:

a)     If you make an inquiry to Good Shepherd New Zealand about a loan, Good Shepherd New Zealand will pass your information on to your nearest community provider and/or loan provider;

b)    We may facilitate transfer of your information between community providers, for example if we need to transfer your loan from one provider to another;

c)     If you apply for a StepUP loan, your application will be passed to the Bank of New Zealand, which administers the StepUP loan (and the Bank of New Zealand will treat your information in accordance with its own privacy policy);

d)    Records relating to your loan may be stored on central files or a central database administered by Good Shepherd New Zealand, your community provider and/or your loan provider. Good Shepherd New Zealand, your community provider and/or your loan provider may access your personal information (including information held on these databases), and may use it for audit and monitoring purposes, to provide technical support and training to the relevant loan provider and/or your community provider, to generate de-identified reports for research, evaluation and analysis, and to help improve the Programmes;

e)     Good Shepherd New Zealand, your loan provider, and your community provider will exchange information about your loan application and (if you take out a loan) your loan, including in relation to your credit history, capacity, standing and general creditworthiness.  Those parties will also exchange information about how you pay off your loan (including your relevant balance(s)) and your loan management generally;

f)     Loan providers and community providers will tell Good Shepherd New Zealand if they receive a complaint about a loan and may involve Good Shepherd New Zealand in the complaints handling and resolution process.  Similarly, if Good Shepherd New Zealand receives a complaint relating to a loan, it may forward that complaint on to the relevant loan provider or community provider;

g)    If you have a NILS or StepUP Loan outstanding, this fact may be disclosed to other loan providers and/or community providers if you apply for a loan through them;

h)     We share personal information with the third party partners that we conduct research with.  This includes organisations like the Ministry of Social Development and Statistics NZ, who may supplement, match and check our information.  We only do this for the purpose of the research, and to evaluate the success and outcomes of our projects and initiatives.  The research we publish will not identify you personally unless you expressly consent to it;

i)      We also need to report certain personally identifiable information to the Ministry of Social Development in order to obtain funding from them.  This is for the purpose of allowing the Ministry to track and assess the outcomes of the NILS and StepUP loan Programmes.  At the moment the information we give to the Ministry is sent in an identifiable form, but is only used in a non-identifiable way.

In addition:

j)      Your personal information may be disclosed where required or permitted by applicable law;

k)     Good Shepherd New Zealand may share information with its service providers and related entities in connection with carrying out the purposes explained above;

l)      If the NILS Programme or your loan is transferred to a third party your personal information may be shared with that third party;

m)   Some central databases used as part of the NILS and StepUP Loans Programmes are hosted overseas (e.g. in Australia) and your personal information may be transferred and stored overseas as part of this.

7.         Retention and security of personal information

Your information will be protected by reasonable security safeguards against loss, unauthorised access, use, modification, disclosure, and other misuse.  Your information will not be kept for longer than permitted by applicable law.

8.         You have rights of access and correction

Under the Privacy Act 1993, you have certain rights to access personal information held about you, and to correct it if it is wrong.  To request access to or correction of your personal information held by Good Shepherd New Zealand, please contact us on the contact details below:

Good Shepherd New Zealand Limited
Level 7, 2 Kitchener Street, Auckland
microfinance@goodshep.org.nz

9.         Glossary

In this Privacy Statement:

“Good Shepherd New Zealand” or “we”/”us” means Good Shepherd New Zealand Limited and includes its (directly or indirectly) related entities in New Zealand and Australia;

“community provider” means a community organisation that you talk to regarding a NILS or StepUP loan, for example The Salvation Army;

“loan provider” means the organisation that funds your loan.  If you take out a NILS loan, your loan provider is both your community provider, and the bank that provides your community provider with loan funding.  If you take out a StepUP loan, your loan provider will be the Bank of New Zealand.