Privacy policy

This Privacy Policy explains:

• how, when and why Spencers collects, uses, discloses and stores private information of its employees, Contractor company principals (Contractors), Contractors’ employees (trades workers), customers (tenants), job applicants and others;
• the period for which this information is retained;
• what we will do when someone whose private information we hold requests to access or change it; and
• what we will do if private information is breached, lost, or destroyed.

This policy applies to private information of employees, Contractors, trades workers, tenants, job applicants and any other person whose private information we obtain for business- or employment-related purposes.

Spencers respects and supports the protection of the privacy rights of its employees, Contractors, trades workers and customers, job applicants and others.

• We only collect, store, use and disclose private information as necessary to prudently operate our business.
• We store private information securely while we need it for business purposes, and for the period following that during which we are legally required to retain it. We take reasonable steps to keep it safe from loss, unauthorised activity, or other misuse.
• We fulfil requests to provide access to or correct information made under the Privacy Act 2020, investigate allegations of privacy breach, and advise any privacy breaches to those affected by them as required by the Privacy Act 2020 and its amendments and successors.
• Nothing in this policy limits or excludes anyone’s rights under the Act. Information is available here: www.privacy.org.nz

Spencers only uses private information for the purpose for which it was requested or collected.

3.1 Personal Documents

Employees

• Employees complete a number of forms (such as Personal Information Forms, Induction Form, KiwiSaver and tax forms, and Induction Form, and provide personal documents (such as CV, qualifications, birth certificate, passport, visa, driver licence) to help us assess their suitability for employment, for employment-related, immigration and induction purposes.
• Employees complete a Ministry of Justice conviction history request form so that we can assess their suitability to work on our maintenance contracts as required by those contracts.
• To help us protect employees’, take care of their health and ensure their work will not negatively impact their wellbeing, we request employees to provide, and regularly update, information about their health, medical conditions and any medication they carry or use regularly.
• To help us manage the impact of accidents and illnesses we also store employees’ medical certificates, ACC forms and other related and relevant documents.
• Personal Information Forms ask for personal contact details so that we can contact them outside of normal work hours. We will not unnecessarily intrude into people’s private time, however, we will contact them if the following circumstances:
  • There is an emergency such as a Civil Defence alert, a sudden pandemic alert level change, or a business-related emergency that might immediately affect them.
  • There is something important the employee needs to know while they are on annual leave or parental leave, such as a change process that could affect them.
  • The employee has not arrived at work and has not made contact with us.
• Personal Information Forms ask for contact details of employees’ emergency contact people, so that we can meet our duty of care responsibilities. If an employee is involved in an accident or becomes unwell at work, or is unexpectedly absent from work, we may need to contact their emergency contact.

Contractors

• Contractors complete documents relating to their businesses to ensure their suitability to work on our maintenance contracts. These include, but may not be limited to, a Service Level Agreement (including bank account, GST, tax and contact information), and usually a client pledge.
• Contractors complete forms and provide personal documents required to verify identification and citizenship or immigration status to evidence eligibility to legally work in NZ (birth certificate, passport, visa, citizenship certificate, driver licence).
• Contractors complete a Ministry of Justice conviction history request form so that we can assess their suitability to work on our maintenance contracts as required by those contracts.
  ● Other private information relates to induction and issuance of ID cards (induction form, photograph and identification document – driver licence or passport).

Trades WorkersTrades Workers

• A Ministry of Justice conviction history request is completed so that we can assess suitability to work on our maintenance contracts as required by those contracts.
• An Induction Form is completed and personal documents (such as birth certificate, passport, visa, citizenship certificate, driver licence) are provided to verify eligibility to legally work in NZ.
• A photograph is provided relating to issuance of ID cards.

Job Applicants

• Job applicants to provide some private information to assess suitability for the role applied for (CV, Application Form, Qualifications). This is shared with hiring managers.

3.2 Personal Identification Photographs

Employees

• Employees who attend clients’ properties for training or work purposes must carry a Spencers ID card, showing their photograph, to verify their authority to be there for work purposes. It is not shared outside of the company without written permission.
• These may appear on hiring announcements, office floor plan charts and the company intranet, and may be used for other purposes from time to time, within the business.

Contractors

• Contractors who attend our clients’ properties must carry a Spencers ID card, showing their photograph, to verify their authority to be there to carry out work. It will not be shared with any party outside of the company without their written permission.
• Photographs may be used within our organisation to identify Contractors.

Trades Workers

• Trades Workers who attend clients’ properties must carry a Spencers personal ID card, showing their photograph, to verify their authority to be there to carry out work. It will not be shared with any party outside of the company without their written permission.

3.3 Job-related Electronic Data

Tenants

• The nature of our residential social housing maintenance work necessitates that our job management system holds relevant information about the tenants of those properties (names, addresses, contact information). This data is made available to our job management system by our clients. Our employees necessarily have access to it so that they may contact tenants and visit their homes during the course of their work.
• Spencers and its employees are bound to protect any information provided about tenants.

3.4 References

Job Applicants

We ask job candidates to provide contact details of their referees. We request references only from those whose contact details have not been provided by candidates. We so not disclose the content of reference check conversations to candidates.

3.5 Personal Relationships

We promote friendships at work and promote social interaction. If a personal relationship at work or outside work could become a problem, for instance if a manager or team leader enters into a relationship with someone who reports to them, we expect the people concerned to advise their senior leadership team member, or the Human Resources and Trades Manager. The business may take steps to minimise any negative impact, such as changing reporting lines or roles.

Website users

When you visit this website, we may use automated technology (such as usage monitoring software, cookies, and sessions) to collect and store certain information about your visit.

Employees

• Private information is collected directly, with the exception of Conviction History Reports which are obtained, with employees’ consent, in electronic form (pdf) from the Ministry of Justice of New Zealand via the Ministry’s internet portal.
• We collect some private information directly through the induction processes, which includes statistical data such as gender, age and ethnicity.

Documents and ID photographs are stored electronically in personnel files. Data and some documents are stored in the CRM section of our job management system (CRM). Photographs are stored in CRM and in a network drive accessible by all employees.

Contractors

• Private information we obtain directly by email or via our internet portal is through our probity, onboarding and induction processes. It includes statistical data such as gender, age and ethnicity.
• We collect Conviction History Reports, with Contractors’ consent, from the Ministry of Justice of New Zealand, via the Ministry’s internet portal in electronic (pdf) format.
• We obtain trade registration data from applicable publicly accessible websites.

Paper documents are scanned, stored electronically, and shredded as soon as practicable. Data, photographs and documents are stored in CRM. Photographs and documents (including conviction history reports), are stored in a secure network drive that is accessible by the Trades Department team only. Photographs are stored in a network drive accessible by all employees.

Trades Workers

• We collect reporting and statistical data, such as gender, age and ethnicity, directly from Trades Workers via the induction process/form.
• We collect Trades Workers’ names, occupations, email addresses, trade qualification and registration details, and personal identification documents, from their employers – our Contractors – who provide them by email or via our internet portal.
• We collect Conviction History Reports with trades workers’ consent, from the Ministry of Justice of New Zealand, via the Ministry’s internet portal in electronic (pdf) format.
• We obtain trade registration numbers from publicly accessible websites.

Paper documents are scanned, stored electronically, and shredded as soon as practicable. Data, photographs and documents are stored in CRM. Documents are stored in a secure network drive that is accessible by the Trades Department team only. Photographs are stored in a network drive accessible by all employees.

Tenants

• Our social housing maintenance work necessitates that our job management system holds contact details and occasionally other information about tenants. This is made available to our job management system, by our clients. Our employees access to it to contact tenants and when visiting properties during the course of their work.
  This data is not normally stored outside the job management system.

Job Applicants

• We collect private information directly from job applicants and we collect some from referees. We retain this (including of referees and our conversations with them) only as long as required to make hiring decisions.

Information is generally received electronically and stored in a secure network drive. It is deleted when the recruitment process is completed.

Web Site Users

We will not use or disclose your personal information except in accordance with the New Zealand Privacy Act 1993. We may use your personal information to:verify your identity and to assist you if you forget your username or password for any of the services we provide to you via the internet; communicate with you; analyse usage of this website; provide you with further information, news, and promotional material; and improve the content of this website and to customise this website to your preferences.

We will not sell, rent, or lease your personal information to third parties. Your personal information will be made available internally for the above purposes and we may also disclose your personal information to third parties, who have agreed to treat your personal information in accordance with this privacy policy, for similar purposes. By providing us with your personal information, you consent to our using and disclosing your personal information in the manner set out above.

We will only use or disclose personal information that you have provided to us, or which we have obtained about you (for the above-mentioned purposes):

• if you have authorised us to do so;
• if we have given you notification of the intended use or disclosure and you have not objected to that use or disclosure;
• if we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for national security in the performance of their functions;
• if we believe that the use or disclosure is reasonably necessary to enforce any legal rights we may have, or is reasonably necessary to protect the rights, property and safety of us, our customers, or others; or
• if we are authorised, required or permitted by law to disclose the information.

Employees, Contract ors, Trades Workers , Tenants , Job Applicants , Others

• We only disclose a person’s private information to a party outside of our business with their knowledge and written consent.
• We use appropriate security safeguards to protect private information against loss, unauthorised access, use, modification, disclosure, or misuse – refer to our IT Policy.
• We retain private information as long as it is required for the purposes of operating our business.

After the period for which it is required to be retained by contractual obligations or by law, we delete it from our records and systems according to our Document and Information Destruction Procedure.

Employees, Contract ors, Trad es Workers, Tenants, Job Applicants, Others

• Requests for access to private information, must be made in writing to the Privacy Officer and should provide evidence of identity. We may charge our reasonable costs of providing copies of personal information.
• Requests to access private information will be granted unless there are reasonable grounds to deny it. We will respond to requests within 20 working days.
• Requests for correction of private information must be made in writing to the Privacy Officer. Requests must provide evidence that the information is incorrect and evidence of identity. We will action reasonable correction requests within 20 working days.

Employees, Contract ors, Trades Workers, Tenants, Others

• If we believe your privacy has been breached and that the breach could cause harm to you, we will notify you and advise the steps we are taking to mitigate the breach.
• If we believe we have breached your privacy and that the breach could cause harm to you, we will notify you and the Privacy Commissioner as required by law.
• If it is alleged that you breached the privacy of another party whose privacy is protected by this policy, the matter will be investigated. Outcomes of such an investigation could include termination of your relationship with Spencers and legal action.

Employees

• If you cause a breach to the privacy of another party whose privacy is protected by this policy, the matter will be treated seriously and could constitute serious misconduct.

Contractors

• You are responsible for ensuring you have the consent of anyone in your organisation whose private information you share with us.