Charitable purpose is more than a line in a trust document. It is the beating heart of an organisation, its North Star, and the aim which it must legally pursue.

What is a Charitable Purpose?

New Zealand’s Charities Act defines what purposes are charitable, drawn from centuries of case law dating all the way back to the Statute of Elizabeth in 1601. Those four heads are:

  • Advancing religion
  • Advancing education
  • Relieving poverty
  • Any other purpose benefiting the community

That fourth category is not a catch-all. It is heavily shaped by case law and can be a difficult category to qualify under in some circumstances.

Importantly, a charitable purpose is not simply a values statement or a marketing message. If you are a trustee, you are legally required to advance those purposes in perpetuity. That is what sets a charity apart from a business. There are currently around 29,300 registered charities in New Zealand. With charitable status comes a significant privilege, including tax benefits, and with that privilege comes accountability.

The Trust at the Heart of It All

The word “trust” is not incidental. When a founder establishes a charitable trust, they are entrusting others with their gift, their vision, and their intention. Trustees have been entrusted to carry that forward.

This means that as a trustee, your job is not to ask what you feel like doing. It is to ask what the founder was trying to do, and then do that.

The founding gift sets the aim and defines the purpose. Trustees must look back to understand what was originally intended, and then operate within those boundaries.

What Can Go Wrong: Scope Creep and Purpose Drift

One of the most common issues we see is purpose drift. A charity is set up to run a preschool. Funding becomes available for high school students. Then more funding arrives for another initiative. Over time, an organisation can drift far from its original purposes, and no longer operate within the legal protection those purposes provide.

A helpful analogy is to think of your charitable purpose as a driver’s licence. If you hold a motorbike licence, you are not permitted to drive a car, even if it would be more comfortable or practical. The same applies to a charitable trust. You can only use the assets for the purposes for which they were established.

This is not just a governance concern. It is a legal one.

Reviewing Your Governing Rules

The Charities Act now requires officers of a charity to review their governance procedures every three years. The first cycle of that review concludes around October 2026.

Key things to look for include:

  • Whether your purposes still reflect what your charity actually does
  • Whether the language is current and appropriate
  • Whether your rules assist you to comply with the Charities Act
  • Whether your amendment clause gives you the flexibility you need

Charitable purpose is not a formality. It is the legal and moral foundation of everything a charity does. Understanding what your purposes are, whether they remain fit for purpose, and what options are available if they need to change is one of the most important things a trustee can do.

If any of this raises questions about your own organisation, we would be happy to talk it through. Parry Field Lawyers has teams across five offices and works with charities of all sizes on governance, trust law, and purpose-related questions.

 

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The information contained in this outline is of a general nature, should only be used as a guide and does not amount to legal advice. It should not be used or relied upon as a substitute for detailed advice or as a basis for formulating decisions. Special considerations apply to individual fact situations. Before acting, clients should consult their Parry Field Lawyer.

Society changes. Language evolves. Gold rush towns become ghost towns. What made sense in 1950 may be impossible, impractical, or simply no longer appropriate today. If a charity’s purposes have become outdated and there is no power in the trust deed to amend them, trustees can apply to the High Court under Section 32 of the Charitable Trusts Act 1957.

The Three Legal Tests

The court can make changes if one of three tests is met:

  1. Impossible: The purpose can no longer be carried out at all. For example, a trust established to support a district health board that has since been disestablished.
  2. Impracticable: The purpose could technically be carried out, but it is not feasible in practice. For example, a trust set up to establish a school in a specific town that has since become a ghost town.
  3. Inexpedient: The purpose is no longer suitable, advisable, or useful. This is a value judgement by the court. Examples include trusts that impose conditions that no longer make sense given advances in medicine or society.

When assessing any application, the court will try to make the smallest possible modification, staying as close as it can to the original intention of the founder, while taking into account changed circumstances and who the founder intended to benefit.

The Role of the Attorney General

Before a court will make changes to charitable purposes, the Attorney General must be notified and given the opportunity to provide their view. The Attorney General effectively acts as the conscience of charities in New Zealand, ensuring that the public benefit rationale for charitable status is being upheld. If the Attorney General raises concerns, the court will take those seriously.

Section 32 vs Section 33: Purposes vs Powers

It is worth understanding the distinction between two key provisions in the Charitable Trusts Act 1957:

  • Section 32 deals with amending purposes (also called objects). This is the harder test, requiring one of the three grounds above to be met.
  • Section 33 deals with amending administrative or management powers. The test here is lower. A court can amend these powers if doing so would facilitate the objects of the trust, meaning it simply needs to make it easier to advance the charitable purposes.

Reviewing Your Governing Rules

The Charities Act now requires officers of a charity to review their governance procedures every three years. The first cycle of that review concludes around October 2026.

When reviewing your trust deed, start with the amendment or variation clause. This tells you what you are permitted to change and under what conditions. Some clauses only allow administrative changes. Others may ring-fence the purposes entirely, meaning any change to those would require a court application.

Key things to look for include:

  • Whether your purposes still reflect what your charity actually does
  • Whether the language is current and appropriate
  • Whether your rules assist you to comply with the Charities Act
  • Whether your amendment clause gives you the flexibility you need

In some cases, particularly where a trust deed is very old and has no variation provision at all, it may be more practical to establish a new charitable trust and transfer assets across, rather than attempting to amend the existing one.

What Does a Court Application Actually Involve?

Going to court to change charitable purposes is not a quick process. Here is a realistic picture of what is involved:

  • Gathering background information about the founder’s original intentions, which may require going back through archives or historical records
  • Preparing a well-articulated application that explains where the trust started, where it is now, and why a change is needed
  • Liaising with the Attorney General’s office, which may involve back-and-forth correspondence or meetings with Crown Law
  • Filing documents in the High Court and waiting for a hearing date, which is typically several months away from the time of filing
  • Responding to any interested parties who may appear in response to advertising requirements

Before committing to a court application, it is worth obtaining legal advice on: what can be done; what should be done; and what is most cost-effective.

If any of this raises questions about your own organisation, we would be happy to talk it through. Parry Field Lawyers has teams across five offices and works with charities of all sizes on governance, trust law, and purpose-related questions.

 

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The information contained in this outline is of a general nature, should only be used as a guide and does not amount to legal advice. It should not be used or relied upon as a substitute for detailed advice or as a basis for formulating decisions. Special considerations apply to individual fact situations. Before acting, clients should consult their Parry Field Lawyer.

Adopting and adhering to recognised charitable purposes is an essential requirement for organisations in New Zealand to become registered charities.

Beyond compliance, however, charitable purposes can also be understood as Kaupapa. They guide the organisation’s decisions, shape its priorities, and provide a clear foundation for how it operates.

Having worked with hundreds of charitable organisations, our key message is this: the heart of the organisation is the purpose. It is what motivates people to do the work and is often the first thing that comes to mind when explaining why their organisation exists.

This purpose then becomes a lens for decision making. It helps determine how resources are applied, how financial and operational choices are made, and determines who sits on your Board. It also informs the activities a charity undertakes to fulfil its charitable purposes and meet one of the four recognised purposes to be registered as a charity:

  • advancing education
  • reduction of poverty
  • advancing religion
  • purposes beneficial to the community

Clearly defining your purposes is, therefore, a key first step for charities.

Those familiar with management terms will know the importance of having an organisational mission. The mission is the guiding light for employees and provides a lure to would-be customers. While a vision looks to the future, mission statements embed action into purpose.

This is no different for a charitable organisation. Being able to clearly communicate purpose or purposes allows an organisation to tell the world (and potential donors) what it does and why.

More fundamentally, it allows those who run or govern charitable organisations to fulfil their legal obligations when it comes to acting in the best interests of the charity.

Recent changes to the Charities Act 2005 require charities to undertake governance reviews every three years. Charities should use this an opportunity to ensure that any policies, procedures, and capability are consistent with their purposes.

Equally, charities might identify where gaps exist and how these can be filled to help better fulfil their purposes.

For well-established or long-standing charities, a governance review is also an opportunity to ask whether the organisation’s purposes remain fit for purpose. Over time, organisational focus can shift. A review allows charities to consider whether their kaupapa still reflects the work they do today and the impact they seek to have in the future.

If you’d like to find out more about how clearly stated charitable purposes can better serve your organisation, get in touch with our experienced Impact team. We would be happy to answer any questions that you have.

 

This article is provided for general informational purposes only and does not constitute legal advice. The information provided may not be applicable to your specific circumstances. You should seek independent advice from a qualified New Zealand lawyer before making any investment or immigration decisions.

From 1 June 2026, migrant investors applying under New Zealand’s Active Investor Plus (AIP) Visa will have broader options to support philanthropic causes. The Government has updated the immigration instructions to allow:

  1. Growth Category applicants to invest up to 20 percent of their total investment in philanthropy. For a minimum NZD $5 million investment, this means up to NZD $1 million may be donated.
  2. Balanced Category applicants, with a minimum NZD $10 million investment, can continue to allocate any portion to eligible philanthropy.

Changes have also been made in that there are new requirements for philanthropic investments which apply to both the Growth and Balanced categories.

Which charities can receive philanthropic investment?

The charity must:

  • be a New Zealand registered charity;
  • have at least five years of compliant annual returns for the five years immediately before the investor’s application;
  • have current Inland Revenue donee status;
  • report to Charities Services under Tier 1, Tier 2 or Tier 3; and
  • use the donated funds exclusively for domestic causes within New Zealand, which must be evidenced by a written agreement between the principal applicant and the receiving charity.

Department of Conservation projects

In addition to registered charities, philanthropic investment may support specified Department of Conservation (DOC) initiatives, providing a pathway for conservation and environmental contributions.

Conflicts of interest and existing links

Applicants and certain family members must disclose pre-existing affiliations with recipient organisations, including membership, trusteeship, or close family connections. Immigration New Zealand may decline applications if donations result in direct private benefits, financial or in-kind, to the applicant or family.

What this means for charities

These changes create new funding opportunities, but only compliant charities qualify. Charities should ensure they maintain compliant returns, donee status, Tier reporting, and processes to manage conflicts of interest. Preparing template donation agreements or confirmation letters is advised to confirm funds are used domestically.

What this means for migrant investors

The changes offer flexibility to include charitable and conservation contributions in investment strategy. Donations must comply with the new requirements to count toward the investment and visa eligibility. Investors should verify recipient eligibility and assess potential benefits to themselves or family members before donating.

If you are considering this visa and want to understand how philanthropic giving might fit into your investment structure, we would be happy to help you work through the detail. You can reach out to our experienced team here.

 

This article is provided for general informational purposes only and does not constitute legal advice. The information provided may not be applicable to your specific circumstances. You should seek independent advice from a qualified New Zealand lawyer before making any investment or immigration decisions.

29 May, 2026

Donation tax credits allow for a percentage of charitable donations to be claimed back as a reduction in income tax or as a refund. For a person who donates to charity, this means that they can receive one third back if they claim it at the end of the financial year. For example, if you give $300 to charity then you can claim back $100.

As part of the New Zealand Government’s 2026 Budget there are big changes to donation credits for donors who make large donations. Under the new changes, a donor who donates $100,000 or more in a year to any organisation will only be able to claim back a tax credit of $33,333.33, with the change coming into effect from 1 April 2027. Once they go above that threshold they will not be able to claim back additional amounts. The Government’s rationale for this change is to ensure the donation tax scheme is financially sustainable and avoid “donor controlled” situations, where a person donates money to a charity they control but receives the one third back.

Of course, this will not affect most donors. However, that justification ignores some of the likely impacts of this which signal a broader shift. It seems likely that the proposed change will disincentive the biggest donors from making large donations. It also signals a subtle message about support of charities and reduces the incentives to do so. The reality is that the biggest donors give the biggest amounts, so it will have an outsized impact on charities.

For a charity, it is worth considering the following:

  • If you were expecting large donations, perhaps contact those donors to have them give in this financial year, before the changes come into effect? (Recognising IRD have stated they will monitor this “in case it gives rise to any integrity concerns.”)
  • Will this actually affect your charity? Perhaps not, given few charities have these sorts of large scale donors. But maybe take this as a challenge to reconsider your strategy for fundraising and see if you can attract some of the donors who can give $100,000?
  • What is your strategy when it comes to fundraising – how can you proactively consider different forms? For example, via wills/bequests, large gifts, one-offs, or fundraisers.

Every year, many eligible donors do not claim back their donation tax credits through IRD. Donation tax credits can be claimed back for any donation made to a donee organisation for donations over $5. We are currently preparing a paper regarding the introduction of a ‘Gift Aid’ system here, which would be similar to the UK.

It is worth noting that the regulatory statement issued has the following comments on what was considered but rejected: “Other options, including multiple rates, removing certain charitable purposes, or introducing a United Kingdom-style gift aid scheme, were considered but not progressed due to complexity, or fiscal or timing constraints. Removing all donation tax concessions was also considered but rejected as inconsistent with the Government’s objective of supporting charitable giving. Increasing direct funding by Government support was not considered, noting this approach is preferred by the community and voluntary sector.”

Some of those points are worth being aware of. For example, we can guess but wonder what is meant by considering “removing certain charitable purposes”?

It is challenging times for charities and the cost of living crisis is having a dampening effect on charitable giving. This change will likely have a more chilling effect for charities than the likely positive impact to the Government of how much they pay to generous donors as tax credits.

It is worth mentioning that there are always green shoots of innovation and hope. We recently released the Changing Paradigms book (downloadable here) with 24 leaders describing how our paradigms of thinking need to change. Last week, we also held the Seeds Impact Conference with a panel on innovation and charities which was most encouraging (you can listen here). There are good things happening in this sector, we just need to tell the stories and get the information out about what is being done.

Our team supports hundreds of charities and if you would like to discuss anything in this article please let us know. We are also helping many charities go through a “governance review” that involves looking at the rules of the charity to consider if changes are needed to keep them fit for purpose (a recent change that requires all Charities to confirm this by October 2026).  You can find out more about our resources for charities on our website.

 

To read more visit:

 

Please note that this article is not a substitute for legal advice and you should contact your lawyer about your specific situation.

29 May, 2026

Charter Schools offer an alternative way for education to be provided to the next generation. A key hurdle can be raising the funds needed to start such a school. Impact Investing could offer a solution to this.

This approach involves individuals investing for impact – in other words, instead of donating or giving money to the cause of setting up the new Charter School, they invest in a legal structure which will allow them to have financial return while also enabling impact.

The way this works is:

  • Individuals invest into a limited partnership structure. In the diagram below these individuals are shown at the top of the diagram.
  • There is a general partner which is a company who actually runs the limited partnership.
  • In this case, the subject of the limited partnership is the new school.
  • Over time the school receives income and becomes sustainable after the initial kick-start from investors, and so is able to provide financial return to the investors.

Limited partnerships are a corporate structure that combine some key features of companies (such as separate legal personality) and partnerships (such as tax pass-through treatment).

Each situation will be unique and different, but this model could provide an alternative approach to allow a new Charter School to get off the ground. It might even be that institutional investors might be interested in investing, or religious organisations if there is an alignment of beliefs with the proposed school.

It is important to ensure compliance with fundraising rules (administered by the Financial Markets Authority), such as ensuring investors qualify as wholesale investors, or come under another exemption. Also, if it were to be open to retail (such as parents) then it would be more complicated.

An alternative to this would be to introduce a charitable entity, such as a trust, which could also play a role in such a structure as the owner of the general partner.

We have expertise in this and other legal structure types and would be happy to discuss the options available. Reach out to our experienced team here.

 

The information contained in this outline is of a general nature, should only be used as a guide and does not amount to legal advice. It should not be used or relied upon as a substitute for detailed advice or as a basis for formulating decisions. Special considerations apply to individual fact situations. Before acting, clients should consult their Parry Field Lawyer.

If your organisation is listed on Schedule 32 of the Income Tax Act 2007 and you are thinking about a name change, the good news is that the process is more straightforward than many people assume. Here is a practical overview of what is involved.

What is a Schedule 32 entity?

Schedule 32 status gives qualifying charities, whose purposes are mainly overseas, the ability to issue receipts to their donees for donations made to the charity. The donees can use those receipts to claim a credit or deduction against their income tax.

Can a Schedule 32 entity change its name?

Yes. There are generally no restrictions from Inland Revenue’s perspective on a Schedule 32 entity changing its name. However, there are a couple of practical considerations to keep in mind. The proposed name also should not create confusion for the public by being too similar to another existing organisation.

Does the legislation need to change first?

Ultimately, yes, to formally update Schedule 32 to reflect the new name, an amendment to the legislation is required. That means the change needs to be included in a Parliamentary Bill, which then goes through the full legislative process. This can take time.

However, the legislative update does not need to happen before your organisation starts using the new name. In practice, once the name has been changed on the relevant registers (the MBIE register and the Charities Service register), your organisation can start operating under the new name right away.

What about IRD?

Once the register updates are done, you or your adviser should notify IRD’s operational team. You can do this through myIR or by emailing charities.queries@ird.govt.nz. IRD will then update their systems to reflect the new name for tax purposes and will also update the Approved Donee Organisations list on their website.

The legislative amendment to Schedule 32 can then be progressed in due course. IRD’s policy team can initiate that process, but it is important to let them know the new name as soon as possible. IRD has noted that they sometimes do not hear about name changes until years after the fact, which can cause complications.

Summary

In summary, the process would roughly follow the these steps. Firstly, consider your new name and receive advice on whether it is likely to be approved. If the new name will likely be approved, then proceed with updating your name on the MBIE and Charities Service registers. Once that has been done, then you can notify IRD’s operational team via myIR or the charities queries email. Also make sure IRD’s policy team are informed, so the Schedule 32 legislative amendment can be initiated. From this point the legislative change can follow in due course and does not hold up the name change itself.

We can help

If your organisation is considering a name change and you would like advice on the process or any related legal matters, we would be happy to assist. This article is a general guide only and is not intended as legal advice. Please get in touch with our team if you would like to discuss your specific situation.

For many people, the idea of philanthropy and immigration feel like separate worlds. But under New Zealand’s Active Investor Plus Visa, they can go hand in hand. If you are looking to relocate to New Zealand and want your investment to do some good along the way, this visa pathway is worth understanding.

Note: as at 29 May 2026, there have been changes to philanthropic investments for the Active Investor Plus (AIP) Visa. Read more here. 

What Is the Active Investor Plus Visa?

The Active Investor Plus (AIP) Visa is designed for wealthy individuals who want to invest in New Zealand and, in return, gain the right to live here indefinitely. It is open not just to the applicant but also to their partner and dependent children aged 24 and under. As with most residence visas, applicants need to be of good health and character and be considered a fit and proper person.

Two Ways to Invest

There are two categories under this visa, and the one that allows philanthropic donations is the Balanced Category.

The Growth Category requires a minimum investment of NZD $5 million, which must go into managed funds or direct investments into New Zealand businesses. Philanthropy is not an option under this category.

The Balanced Category requires a minimum of NZD $10 million but opens the door to a much wider range of investments, including listed equities, bonds, property development, managed funds, direct investments and, importantly, philanthropy.

Note that previously, there was a maximum cap of $7.5 million for philanthropy, but now the total required investment can be invested into philanthropy.

The different requirements for both categories can be seen in this table below.

Growth Category Balanced Category
Minimum investment NZD $5 million NZD $10 million
Acceptable investments Managed funds, direct investments Listed equities, philanthropy, bonds, property development, managed funds, direct investments
Time to invest 6 months from Approval in Principle (with option to extend 6 months) 6 months from Approval in Principle (with option to extend 6 months)
Retention period 36 months 60 months
Time in New Zealand Minimum 21 days over investment period Minimum 105 days over investment period (reductions available)
Checkpoints 24 and 36 months 24 and 60 months

 

What Counts as a Philanthropic Investment?

Not every charitable donation will qualify. It must meet the criteria set out in the immigration operational manual instructions. To be considered an acceptable investment for the purposes of the Balanced Category, the funds donated as part of this visa must go to organisations that are a registered charity with at least two years of annual returns filed, and that hold current Inland Revenue donee status.

Donee status is granted by Inland Revenue to organisations that use at least 75% of their funds on charitable or public good purposes within New Zealand. It is the same status that makes donations tax-deductible for ordinary New Zealanders, so it is considered an indicator of legitimacy.

One thing to be aware of is that Immigration New Zealand does not maintain a list of approved charities for this purpose. That means the responsibility sits with you and your advisers to confirm that any organisation you intend to support meets both criteria before funds are committed.

A Meaningful Way to Invest

For investors who are drawn to giving back, the Balanced Category offers an opportunity to combine residency with purpose. New Zealand has a strong charitable sector, and directing a portion of a $10 million investment toward an established, compliant charity is a rewarding way to meet the visa requirements.

You can find out more details on the New Zealand immigration, and trade and enterprise websites.

If you are considering this pathway and want to understand how philanthropic giving might fit into your overall investment structure, we would be happy to help you work through the detail. You can reach out to our experienced team here.

 

This article is provided for general informational purposes only and does not constitute legal advice. The information provided may not be applicable to your specific circumstances. You should seek independent advice from a qualified New Zealand lawyer before making any investment or immigration decisions.

Independence on a charity board is essential for building trust and promoting transparency. It supports good decision-making by providing objective oversight and managing potential conflicts of interest, giving stakeholders confidence that the charity’s choices are genuinely in its best interests. A common question is: how many independent board members are needed when a company becomes a charity?

There is no universal rule, but becoming a charity represents a significant shift in mindset. In a private company, a small group of people may hold multiple roles such as, directors, shareholders, and employees, without much public scrutiny. Once an entity registers as a charity, the organisation exists to advance charitable purposes for the public benefit and ideally continues beyond the founders’ involvement. Registration brings benefits such as tax concessions and credibility, but it also entails greater accountability, transparency, and public scrutiny.

Risks of a Non-Independent Board

If the same individuals act as directors, shareholders, and employees, conflicts of interest can arise, particularly regarding remuneration, contracts, or other benefits. For example, it is inappropriate for people to decide their own salaries or employment terms. Any remuneration should be set at market rate, and those receiving it should not participate in the decision-making process.

Managing Conflicts of Interest

Charities Services’ guidance explains that conflicts of interest can be actual, potential, or perceived, and may be financial or non-financial. While conflicts are common in charities, poor management can lead to disputes, bad decisions, or reputational damage.

To manage conflicts effectively, a charity should:

  • Maintain a clear conflict of interest policy and an interests register
  • Ensure conflicts are declared at the start of meetings
  • Exclude conflicted individuals from discussions or decisions
  • Record how conflicts are handled in the minutes
  • Report significant conflicted transactions as related party transactions in the financial statements

Practical Guidance on Board Composition

For a company converting to a charity, it is generally expected that around half the board be truly independent. This ensures that conflicted individuals can step aside from decisions affecting their own pay or position while leaving enough independent members to make valid decisions.

Our experienced team help many charities with their governance. If you would like to talk through your situation, feel free to reach out.

A Privacy Law change which affects all organisations in New Zealand has was implemented in May 2026. In this article we outline what it means and why it matters.

The change – indirect information

The change boils down to “IPP3A”, which is an acronym that refers to an addition to the third privacy principle (collection of information). As a reminder, the privacy obligations in New Zealand are overseen by the Office of the Privacy Commissioner and consists of several privacy principles contained in the Privacy Act 2020.

Those 13 privacy principles cover how an organisation collects data, who it tells about that, how people can update their information and more. We outlined exactly what they are and how they work in this overview. A few years ago, when the Privacy Commissioner visited and ran a seminar at Parry Field, he summarised everything with “don’t be creepy”, which is still the best summary we’ve heard when it comes to the approach to collecting private information.

This new addition privacy principle helps to clarify and strengthen the collection and notification obligation to “indirect” information. Essentially what this means is that if your organisation collects information indirectly about someone and stores it, then you have to let them know unless an exception applies

When would this apply?

The Privacy Commissioner gives this example in their helpful guidance here – obviously adapt it for your context and business or charity, but you can see the general principle that emerges:

 “Sally makes a claim to her insurance company, Trusted Insurance Co, about damage to her car. She tells them she has taken it to Mater’s Motors for repairs. Trusted Insurance Co asks Mater’s Motors for information about the damage to the car, including whether they thought Sally was responsible for the damage. Mater’s Motors view on whether Sally was responsible for the damage is personal information about Sally. Trusted Insurance Co has indirectly collected Sally’s personal information.”

In this case the insurance company will now have an obligation by taking “reasonable steps” to notify Sally about what it collects about her including (this list is the summary from the Privacy Commissioner’s site).

  • the fact that the information has been collected,
  • the purpose of the collection,
  • the intended recipients of the information,
  • the name and address of the agency that is collecting the information and the agency that holds the information,
  • if the collection is authorised or required by law, which particular law, and
  • their rights of access to, and correction of, their information.

It is worth taking a few minutes to pause and consider if there is any part of your organisation which might collect such information indirectly about people. If so, how do you let people know?

In limited circumstances, an organisation may not be required to notify the individual concerned – for example: if information is publicly available information.

Do you need to disclose where you collected the information from?

If you have collected information indirectly, there is no requirement to disclose where you collected the information from you will always need to be considering what information you collect and why (see IPP 1 and 2 for more information about this).

Some final reflections / challenges since you have read this far relating to privacy:

  • Do you have a privacy officer in your organisation?
  • When was your policy last reviewed and updated?
  • Have you thought through what you would do if there was a hack of your data and it got disclosed?

We often help organisations with their privacy-related questions. If you would like to discuss your situation or would like assistance to create a bespoke privacy policy for you, feel free to reach out to our team.

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