Privacy Policy

Privacy Act

Fingo recognises it responsibilities as an agency under the Privacy Act. Everything in this policy should be interpreted in addition to and in support of the requirements of the Act.

Personal Information

Fingo collects personal information from staff, contractors (associates), candidates, and client personnel. Personal information is only collected where it is necessary for Fingo to effectively conduct its role as:

an employer; or
a contract party.

Fingo ensures that when information is collected that the subject of the information is made aware of the reason for the collection, whether it is mandatory, and what will happen to any information provided.

Staff and Training

Fingo will have a nominated privacy officer identified within the company at all times.

Fingo ensures that the privacy officer and all staff with access to personal information are familiar with our responsibilities under the Privacy Act, this policy and the supporting procedures.

Fingo ensures that access to physical or electronic records including personal information is limited to those staff who require access in furtherance of one or more of the business roles listed above.

Access and Correction

Fingo provides current and former staff, contractors, candidates (associates), and client personnel with the means to request access and correction of any personal information held about them (in accordance with Principles 6 and 7 of the Act).

Fingo evaluates all data services / software that may hold personal information for compatibly with this part of the privacy policy including the capability to correct and/or annotate personal information that may be held.

Retention and Disposal

Fingo maintains a retention and disposal schedule for business records. Where those records include personal information a governing consideration (under Principle 9 of the Act) is to ensure that personal information is not retained longer than necessary.

The schedule is actively maintained, with:

new types of personal information to be added as they arise; and
an annual review of the full schedule

Fingo ensures that disposal of records is done securely and irreversibly. For physical records this means using secure document destruction services. For electronic records this means deleting records permanently to the extent allowed by the software or data service used.

Where electronic records exist on digital media owned by Fingo (disks, laptops etc), disposal usually means a standard operating system delete. However, if media used to hold records is to be sold or otherwise transferred, they must first be wiped at a low-level to ensure records are not recoverable. If this is not possible the media should not be transferred and must be destroyed.

Fingo evaluates all data services / software that will hold records including personal information for compatibly with this privacy policy including the capability to permanently delete information.

Information Security

Fingo ensures the security of all physical files held that include personal information. Files are stored in locked cabinets. Active files may be held on desks within the Fingo office during business hours but are not to be left unattended and visible.

All physical files should be returned to locked storage (or destroyed) when the staff working with them complete their workday.

Fingo ensures the security of electronic records that include personal information. This means:

requiring strong, unique passwords for information systems holding such records
2-factor authentication required when this is supported by an information system
monitoring access to information systems
ensuring the information held is encrypted
for externally hosted information systems reviewing the security and privacy policies of the service
evaluating any new information system for compatibility with this policy include support for a strong password policy, 2-factor authentication, and encryption.

For further information, please contact info@fingo.co.nz addressed to Attn: Privacy Officer.

Last updated: June 2021