133 Molesworth Street
PO Box 5013
Wellington 6140
New Zealand
T+64 4 496 2000
23 July 2024
Mason Helm
By email: [FYI request #27453 email]
Ref: H2024045451
Tēnā koe Mason
Response to your request for official information
Thank you for your request under the Official Information Act 1982 (the Act) to the Ministry of
Health – Manatū Hauora (the Ministry) on 1 July 2024 for information regarding Privacy Impact
Assessments. You requested:
“The PIA that considered the privacy implications of NHI numbers or other unique
identifier. It is my understanding that a PIA took place in the 1990's and concluded that
NHI numbers are personal information. There may be something more recent.”
The document you have requested is attached to this letter and is released to you in full.
Please note that the Health Information Code 2020 (the Code) now specifically references the
National Health Index number in rule 13(3) and expressly authorises use of the NHI and the
agencies that may use it (keeping use of the NHI within the health sector) so there is no longer
a need for a specific PIA, as it is now an authorised use.
The NHI itself can fall within clause 4(1)(e) of the Code and is usually treated in a similar way to
other health information when it comes to consideration of the rules (although it is considered
privacy enhancing in some settings to use the NHI rather than a name as it is a less direct
method of identification).
I trust this information fulfils your request. If you wish to discuss any aspect of your request with
us, including this decision, please feel free to contact the OIA Services Team on:
[email address].
Under section 28(3) of the Act, you have the right to ask the Ombudsman to review any
decisions made under this request. The Ombudsman may be contacted by email at:
[email address] or by cal ing 0800 802 602.
Please note that this response, with your personal details removed, may be published on the
Manatū Hauora website at:
www.health.govt.nz/about-ministry/information-releases/responses-
official-information-act-requests.
Nāku noa, nā
Phil Knipe
Chief Privacy Officer
Government and Executive Services | Te Pou Whakatere Kāwanatanga
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