29 July 2024
Mason Helm
[FYI request #27448 email]
Dear Mason
I refer to your email of 1 July 2024 requesting information under the Official Information Act 1982
(OIA), as fol ows:
Please provide:
a) the PIA relating to the provision of Loan-Level data to the Reserve Bank of New Zealand. This
PIA contains discussion on why the data given under a unique numerical identifier is not
considered personal information under the Privacy Act; and
b) any material held that indicates any processes, practices, or procedures that allow the unique
identifier to be de-anonymised (via a name or other identifiable characteristic). This part of the
request includes internal or external request process (such as seeking further data from a
financial institution).
Part b may be answered by providing a list of processes rather than a substantial response.
Response
Privacy assessments, and the policy, processes and procedures pertaining to such assessments,
contain sensitive information relating to RBNZ’s operations. Should the information be shared, it
could be misused or give someone an improper advantage. For example, this could compromise
the security of the personal information, including access, by opening up RBNZ to malicious attacks
on our network and systems. As this information relates to the receipt, use and storage of personal
information, it is crucial the RBNZ maintains security around these policy areas.
In light of the above, your request is refused under section 9(2)(k) of the OIA, to prevent the
disclosure or use of official information for improper gain or improper advantage.
You have the right to seek an investigation and review of this decision by the Ombudsman.
Information about how to make a complaint is available at
www.ombudsman.parliament.nz or
freephone 0800 802 602.
Ref #21473984 v1.0
Please note that we intend to publish a copy of this response on the RBNZ website at
www.rbnz.govt.nz/research-and-publications/of icial-information-requests. Responses to requests
are published in order to improve public transparency and provide an additional resource for anyone
seeking information.
Yours sincerely
Government and Industry Relations
Reserve Bank of New Zealand – Te Pūtea Matua
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