We, us, our, and Real Living mean Real Living Group Villages and its subsidiaries. ‘Personal information' is information about an identifiable individual (a natural person).
Real Living is bound by the Privacy Act 2020 (Privacy Act) and the Health Information Privacy Code 1994 (Code).
2. Acceptance of this Policy
By using our services or otherwise providing us with your personal information, you agree to be bound by this Policy.
3. Collection – How we collect information about you
Who we collect information about
We may collect and hold personal information about:
- current, potential and former residents, and their families and other representatives;
- service providers, suppliers and their employees and contractors;
- current and prospective employees and contractors of Real Living, and their next-of-kin or emergency contacts;
- individuals we deal with in the course of carrying on our business; and
- other people who come into contact with Real Living.
Information we collect
We collect personal information in order to manage and conduct our business, to provide and market our services and to meet our legal obligations. Depending upon the nature of your relationship with Real Living, the type of personal information we collect and hold may include:
a) information as required for our relationship with you, such as:
- your name, address, contact details, date of birth, and documents that verify your identity and other personal details;
- your IRD number, tax status and citizenship or residency details;
- diversity information, which might include gender, ethnicity, languages spoken, relationship status etc;
- your bank account details (for direct debits or payments, as applicable);
- any other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations;
- details of your religious beliefs or affiliations;
- your health and medical information, including medical history, condition and treatment plan, and contact details for your medical practitioners and treatment providers;
- information we create in the course of our relationship with you, such as details or evaluations of your interactions with us.
For current or prospective residents
b) information to help us assist you with the application process and to enable us to deliver the best support and service for your needs. This may include:
- details of your family medical history;
- your NHI number and Veterans Affairs number (where applicable);
- name and contact details for your family members, attorneys, next of kin, emergency contacts and others acting on your behalf. We may also collect copies of any relevant enduring powers of attorney;
- any relevant details relating to your residence at our facilities (for instance, assessment of suitability to use certain facilities such as swimming pools).
For current or prospective staff members, contractors or suppliers
c) information for the purpose of commencing and conducting a business or employment relationship with you. This may include:
- information about your occupation, employment history, education and suitability for the role or relationship, including criminal history and social media profiles;
- name and details of emergency contacts;
- information about your performance in the role or relationship, including results of drug testing (if applicable).
Who we collect personal information from
We will generally collect personal information from you directly. However, we may also collect personal information:
a) from you indirectly (including through the use of services and facilities available through our websites and social media channels);
b) from current, potential and former residents, residents’ families, service providers, suppliers and their employees and contractors, employees, individuals we deal with in the course of carrying out our business and other people who come into contact with Real Living;
d) from CCTV cameras that may be placed on our premises, which includes our retirement villages and care facilities; and
e) from publicly available websites.
If you have provided us with information about another person, you must have that person’s permission to do so, and if applicable you must comply with your obligations under the Privacy Act and the Code (if applicable), for instance, you may need to tell that other person that you have done so, that they have a right to access their information and that we will handle their personal information in accordance with this Policy.
4. Use – How we use and disclose information that we collect about you
In general, we collect, hold, use and disclose your personal information for the following purposes:
- to communicate with you;
- to conduct our business and help us manage and enhance our services;
- to provide and market our services to you;
- to process, administer, collect payments from or make payments to you, and if applicable, make appropriate taxation deductions;
- to ensure health and safety on our premises;
- to engage third parties on your behalf (where authorised);
- to provide joint marketing initiatives with other service providers;
- to perform data analysis;
- to perform market research;
- to identify, prevent or investigate any actual or suspected fraud, unlawful activity or threats to our systems or any person; and
- to comply with our legal obligations, including our reporting obligations.
For current or prospective residents
- to assist you to apply to live in a Real Living village or care centre;
- to assess your requirements, needs, health status and how we can best provide you with our services;
- to provide you with or facilitate the provision of healthcare services, treatments or care;
- to conduct appropriate checks for credit-worthiness;
- to maintain and administer your record, including (where relevant) your clinical record.
For current or prospective staff members, contractors or suppliers
- to assess suitability or performance of potential or current employees, contractors or suppliers;
- to manage and meet obligations in relation to our employees and contractors;
- to purchase goods or services; and
- to perform drug and alcohol searching and testing, in accordance with relevant Real Living policies.
In addition, CCTV footage specifically may be used for the following purposes:
a) detecting and deterring criminal or inappropriate behaviour on our premises and at our retirement villages and care facilities;
b) monitoring the safety and security of our staff, residents, contractors and visitors, and completing incident investigations; and
c) reviewing the actions of our staff or contractors.
All information collected by Real Living from any drug and/or alcohol testing or search will be kept confidential to the extent required by law, provided that relevant information may be disclosed to that individual’s supervisor or manager.
5. Who we may disclose your personal information to
We may disclose your personal information:
a) to you, or your attorneys or authorised representatives. If you are a prospective, current or former resident and you do not have an attorney or representative, we may also disclose your personal information to your family members or carers if we consider it necessary or desirable for the purposes of your care or wellbeing;
b) to other members of Real Living;
c) if you are a resident or staff member, to third party health providers where necessary for your treatment or insurance companies to assist with the processing of a claim in connection with treatment (this is done with your permission where appropriate);
d) if you are a resident, to the DHB for the purposes of fulfilling our obligations under our contract with the DHB;
e) to other third parties who provide services to or for Real Living or who act on our behalf;
f) to courts, tribunals and regulatory authorities;
g) to anyone who assists us to identify, prevent or investigate any actual or suspected fraud, unlawful activity or threats to our systems or any person;
h) to government agencies and our statutory supervisor (such as when making tax payments relating to you or when meeting reporting obligations, such as under financial markets legislation);
i) to industry associations or other third parties, for benchmarking, statistical analysis and reporting purposes (provided your information is first anonymised);
j) if you are a staff member, to professional organisations which you are a member of, where necessary for any registration or assessment requirements;
k) if you are a staff member, to any third parties who provide benefits or services to our staff;
l) anyone else to whom you authorise us to disclose it; and
m) where we are required or permitted to do so by law.
6. Security of your personal information
We take reasonable steps to protect personal information held by us from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records.
Where we no longer require your personal information we will use reasonable endeavours to comply with our legal obligations in respect of that information.
7. Access, correction and retention of your personal information
We endeavour to ensure that the personal information we hold is accurate, complete and up-to-date. We encourage you to contact us in order to update any personal information we hold about you. Contact details are set out below. You have the right to correct any personal information we hold about you in accordance with the Privacy Act and the Code.
Subject to the exceptions set out in the Privacy Act and the Code, you may seek access to the personal information which we hold about you by contacting:
- if you are a current resident, your Village Manager; or
- in all other cases, on email@example.com, and put Privacy Officer in the subject line.
We will require you to verify your identity and to specify what information you require. A fee may be charged for providing access. If a fee is to be charged, we will advise you of the likely cost in advance.
8. Changes to this Policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located at https://www.real living.co.nz/privacy-policy/ and can be obtained by contacting our Head Office firstname.lastname@example.org
9. How to contact us and complaints
If you have any questions about privacy related issues or wish to complain about the handling of your personal information by us, please contact us on email@example.com. We may ask you to lodge your complaint in writing. Any complaint will be investigated by our Privacy Officer and you will be notified of the decision in relation to your complaint as soon as practicable after it is made, usually within 20 working days of receipt.
If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Privacy Commissioner at: PO Box 10-094, The Terrace, Wellington 6143, phone 0800 803 909, http://privacy.org.nz/
The address of Real Living, as the person collecting and holding your personal information, is: Real Living Fortunes Road, Pakuranga, Auckland 2012