1. POLICY STATEMENT
This is the Privacy Statement for Shift Advisory Limited and Shift Compliance Limited (SHIFT, we or us), located at Ground Floor, Regus, 155 Fanshawe Street, Auckland 1010, and (together with our Terms of Engagement and any other agreement between us) sets out how SHIFT collects, uses, stores, secures and discloses personal information about the people with whom we interact, including:
- our employees/contractors and potential employees/contractors (Workers);
- our Clients and potential Clients,
- our suppliers; and
- the persons representing them, associated with them or acting on their behalf, (collectively, you).
We are bound by and committed to complying with the Privacy Act 2020 (Privacy Act) and the privacy principles set out in the Privacy Act.
Please take a moment to read this Privacy statement carefully. If you have any questions about this Privacy Statement, please contact us at email@example.com.
2. WHAT IS PERSONAL INFORMATION
Personal information is information about an identifiable individual such as that individual’s name and contact details.
3. HOW DOES SHIFT COLLECT PERSONAL INFORMATION?
SHIFT collects information about you whenever you interact with us, for example:
- when you contact us via our website;
- if you instruct us to provide services to you; or
- if you work, or express an interest in working, with us.
That information may be collected in a number of ways, including:
- directly from you: we might collect information directly from you in person, by telephone, by email or post or personal information about you might be included in documentation you provide to us;
- collection by third parties: in some cases, a third party may collect information from you on our behalf – for example, our bookkeepers might collect information they need in order to process payments to or from you;
- collection from third parties: with your consent, we might collect information from third parties – for example, from your referees;
- from public sources: we may collect information about you that you have chosen to make public, for example on social media; and
- automatically: we might also collect information from our website – see section 7
We may also create or obtain personal information in the course of our relationship with you and any evaluative information we create may be confidential to us.
4. WHAT TYPE OF INFORMATION DOES SHIFT COLLECT?
Depending on the nature of your interaction with us, the types of personal information we collect may include:
- your name;
- your contact details;
- your bank account details and other financial information (including a credit check where required by a client);
- your CV and other information relating to your work history and qualifications;
- identity information such as your passport or driver’s license; and/or
- feedback or performance related information related to your work with SHIFT clients.
If a SHIFT client with whom you are associated is, for example, a company or trust, we might also ask you for information about, and evidence of, the nature of your relationship with that client. This is to help us meet our obligations under anti-money laundering laws.
5. WHAT IF YOU ARE UNABLE TO PROVIDE THE INFORMATION WE NEED?
In many cases, if personal information is not provided as requested by us we may not be able to provide our services to you, employ or otherwise engage you or otherwise enter into or continue a relationship with you.
6. HOW DOES SHIFT USE PERSONAL INFORMATION?
We may use the personal information we collect and hold:
- to consider the services you have asked us to provide and to provide those services;
- to represent, advise and communicate with you;
- if you have expressed an interest in working with us, to consider whether to engage you to do so (including for the purposes of reference checking);
- to perform our obligations under any agreement with you including, if we have engaged you to work with us, the employment or other agreement between us;
- for dealing with commercial or legal conflicts; and
- to otherwise comply with our legal obligations (including those relating to anti-money laundering and terrorist financing).
We may also use personal information:
- in order to send you publications and invitations to seminars and functions and otherwise to market our services, however you will have the ability to opt out of these communications (see clause 10);
- for internal business purposes such as billing and debt recovery (which may involve disclosing information to debt collectors); and
- for specific purposes we tell you about or you authorise.
We also collect general user information when you visit our website. This might include your internet protocol address, browser type and internet service provider details. We use this information to administer our website and to better understand how visitors use our website. However, the technical information we collect in this way is not personal information – because it does not include any personally identifiable information.
8. LINKS TO OTHER WEBSITES
9. TO WHOM DOES SHIFT DISCLOSE PERSONAL INFORMATION
We may need to disclose personal information we hold about you to third parties, including:
- other entities or individuals who assist us in providing services or who perform functions on our behalf, such as identity verification agencies, our bookkeepers, hosting and data storage providers and marketing platform providers (including Campaign Monitor, who help us understand how email recipients engage with emails we send them – for more information about how Campaign Monitor processes this personal information see their privacy statement);
- government agencies and regulators, or anyone else with whom we are required to share that information for the purposes of complying with law – including laws relating to money laundering and terrorist financing; and
- in connection with a potential purchase of our business or assets.
We may also disclose personal information if:
- it is required by the client with whom you are engaged for the purposes of that engagement;
- it is required or authorised by law or the Law Society’s Rules of Professional Conduct.
10. OPTING OUT/UNSUBSCRIBE
By subscribing to electronic communications from us, or otherwise providing your email address and/or mobile number, you consent to receiving the relevant subscriptions from us or the communications for which you provided your details for. You can unsubscribe at any time by contacting us on firstname.lastname@example.org or by clicking the unsubscribe function in the relevant electronic communication.
11. STORAGE AND PROTECTION
We may store the personal information we collect about you in hard copy or using electronic storage which may be located within or outside New Zealand and which may be operated by our trusted third party service providers.
We will take all reasonable steps to protect personal information that is held by us or our trusted third party service providers from loss, misuse, unauthorised access, disclosure, alteration, or destruction.
We will retain your personal information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it. After that period we will comply with our legal obligations in respect of that information and generally this means we will delete it or make sure it is anonymised.
13. ACCESS AND CORRECTION
You may request access to, or correction of, any personal information we hold about you by emailing email@example.com.
To ensure that the personal information we hold about you is accurate and current, please notify us of any changes to your personal information as soon as possible.
14. UPDATES TO THIS STATEMENT
SHIFT may update this Privacy Statement from time to time to take account to reflect, among other things, changes to our business practices. Any change we make applies from the date the updated Privacy Statement is posted on our website. If we propose to make any change which may affect you in a significant way, we will give you reasonable advance notice of that change via email. By continuing to engage with us and/or use our services after you have received that notification, you will be deemed to have accepted any such change.
This Privacy Statement was last updated on 28 November 2022.