Tūhono│Connect
We have two consultations open right now.
Schedule 4 of the Telecommunications Information Privacy Code 2020
We’re listening between 7 May – 6 June 2025.
Please email your thoughts to tipc@privacy.org.nz
The Privacy Commissioner is considering making some minor amendments to Schedule 4 of the Telecommunications Information Privacy Code 2020.
We would like to know whether you agree with our proposals.
Schedule 4 enables emergency services to access information about people’s location either from 111 calls or from their smartphones if they cannot make an emergency call and there is a serious threat to their safety. Sharing location in this way enables emergency service providers to find and help people.
Location information is sensitive, and the Schedule contains some strict privacy protections. We are not proposing changes to those protections. However, we think the wording of the Schedule needs to be changed so that:
- The rules support search and rescue operations: in particular so that it makes sure an emergency service provider can share general location information with volunteers or others working on its behalf where this is necessary to support a search and rescue operation.
- The rules work as intended under the new operational structure for emergency location information. This includes making sure the Police can still share location information with other emergency responders as they do now, but also making sure that when device location information is used it still has to be logged in every case.
We also propose to fix some typos in Schedule 4.
How to make a submission
Submissions are due by 5pm on 6 June 2025.
To make a submission, read our background documents below and then email your comments to tipc@privacy.org.nz in the body of an email, or as a PDF or Word document.
Links and documents
• Our Information paper on the proposed changes to Schedule 4 (opens to PDF, 580 KB)
• A marked up copy of Schedule 4 with proposed changes visible as tracked changes (opens to PDF, 357 KB)
• The full version of the current Telecommunications Information Privacy Code 2020
Privacy Amendment Bill (IPP3A) draft guidance
We’re listening between 30 April – 25 June 2025.
Please email your thoughts to IPP3A@privacy.org.nz
Although the Bill has not passed yet, Parliament has indicated that IPP3A will come into force on 1 May 2026, and all organisations will need to have their systems in place to meet the new requirements by then. We’re aiming to have the guidance developed and published on our website to allow organisations plenty of time to implement the requirements of the new Act.
We aren’t expecting further changes to the Bill before it passes, but if there are any changes we’ll update the guidance to reflect this. After the consultation period has ended, the guidance may change before we release the final version. This guidance is only a draft.
About the guidance documents
The draft guidance is in a PDF format for the purpose of consultation, but it will be published as web content once it’s finalised.
We’ve tried to keep the language as simple as possible while still aligning to the wording of the Bill. Let us know if anything isn’t clear.
Have your say on the draft IPP3A guidance
Previously we asked agencies to email us if they would like to be on the list for this. Due to a significant amount of interest in the draft guidance, we’ve decided to publish it on our website for the duration of the consultation period, as well as send it directly to everyone who signed up to our list.
We’re asking agencies to have their say about our draft guidance on IPP3A. We’d like you to consider:
- Is the guidance fit for purpose? How could it be improved?
- Are there any parts of the guidance that need more clarity, or are hard to understand?
- Are there more key terms we need to define or concepts that need more clarity?
- Are the examples provided meaningful for you? If not, what kinds of examples would you want to see instead?
- Any other relevant feedback or comment
These questions are a guide for what we’d like to know, but you don’t have to answer all of them. You can share other feedback you have on the guidance too.
When providing feedback, please keep in mind that OPC cannot amend the Privacy Amendment Bill or make changes to the wording or concepts defined in the Bill itself. We cannot change what the law requires, but we hope that this guidance helps you understand the requirements.
Watch a video that was recorded during Privacy Week about IPP3A.
We’re listening between 30 April – 25 June 2025.
Please email your thoughts to IPP3A@privacy.org.nz
