Privacy Policy

Our mission is to support individuals to recognise and develop their potential. Our vision and values are what get us there. Good privacy practice supports our values; privacy underpins our values of self-worth, integrity, dignity of the person, preservation of Te Reo and social responsibility.

We must collect, use and share personal information about you, our clients, in order to deliver important services that support people to grow in a safe environment. We are committed to managing this personal information with care and respect. We must be able to share personal information to deliver our services and make sure we can protect our staff, our clients and our communities.

Our privacy practices are based on a set of key principles we use to guide us every day:

• We will only ask you for personal information we really need to do our jobs
• We will try always to be clear, open and honest with you about the way we use your information
• We will try our very best to keep your information safe and secure at all times
• You can see and correct your information at any time
• We need to share personal information, but we’ll do so with care
• We will only ever use your information in the ways set out here, unless we are required by law to use it in other ways
• We will be upfront with you about any data breaches that affect your information

The personal information we collect about you

We collect personal information from you directly when you apply for and undertake our programmes or courses, or when you engage with us using our website or other methods of contact. We may generate information about you internally when we’re delivering services. We may also collect information about you from third parties, including your employers, your whanau or other government agencies (including the Ministry of Social Development, Tertiary Education Commission, Ministry for Pacific Peoples and the NZ Qualifications Authority).

In all cases, we’ll only ever collect or generate the minimum amount of personal information necessary to meet our purposes.

We may collect the following information about you when you apply for or use our services:

• full name;
• physical address;
• phone number;
• email address;
• information about your previous learning;
• iwi affiliation;
• bank details for making payments;
• identity verification documents;
• photographic images;
• emails or other correspondence relating to the services you receive from us;
• internal notes about the services you receive from us;
• information about your benefits;
• information about your employment;
• information about drug or other testing we have asked you to complete as part of a programme or job placement; and
• information from your whanau or representatives that may be relevant to the services you receive from us.
• IP address;
• language spoken;
• location; and
• cookies (see below).

We also collect the following information about you when you use our websites or online services:

Cookies are small data files that our website sends to your browser, which may then store it on your system for later retrieval. We only use cookies to give you a simpler and easier online experience. While you can disable cookies in your browser, your experience of our website may be affected.

We use Google AdWords remarketing service to advertise our services on third party websites you visit after visiting our website. Google uses cookies to do this. To manage your preferences in relation to Google Adwords, including to opt out entirely, go to www.google.com/settings/ads/onweb/.

How we use your personal information

To meet our purposes – developing the potential of our people by delivering youth, employment, educational and training services – we need to use the personal information collected when you apply for or use our services to:

• identify you;
• consider your application for services, including verification of previous learning or training;
• manage and deliver any services you request from us;
• contact you if required for the purposes of delivering services;
• investigate and resolve any queries or concerns you raise with us;
• continuously improve our products and services;
• inform you about special offers, updates or new services from Solomon Group;
• meet our reporting obligations in respect of the services we deliver on behalf of government agencies, including agencies that provide us with funding; and
• comply with our legal and regulatory obligations and any lawful requests from government agencies or regulators.

We use the personal information collected when you use or website or online services to:

• provide you with a seamless and easy online experience;
• assist you to find online services and information quickly;
• create and deliver content relevant to you;
• inform you about special offers, updates or new services from Solomon Group; and
• continuously improve our website and online services.

We may use photographs of you participating in our programmes in our marketing and promotional material, but we will only ever do this with your consent.

Who we share your personal information with

We need to share personal information to deliver the services requested from us and to comply with government or regulatory requests or reporting requirements. Where we need to share information with an agency we have not anticipated here, we will only do so if required or permitted by law.

We may share your information with:

• government agencies, such as the Ministry of Social Development, the Ministry of Education, the Ministry for Pacific Peoples, the NZ Qualifications Authority, Inland Revenue, and the Tertiary Education Commission;
• other youth services providers or education providers that you transfer to or from, for verification purposes;
• industry training organisations;
• service providers which we use to perform services on our behalf (such as IT service providers);
• other entities within the Aspire 2 Group;
• your current or new employers, where this is necessary to deliver services;
• your whanau, care givers or representatives; and
• in the event of an emergency, or where we believe there may be a risk of harm to you other others, the Police or any other government agency that we believe may be able to assist.

Where we ask you to complete drug testing as part of a programme or job placement that requires this, we will not share your results with a potential training provider or employer but we may not put you forward for a programme or job if you test positive.

Where we store your personal information and how we keep it safe

Storage and location

We store all the personal information we collect or generate on password-protected servers located in New Zealand and overseas (where the IT service providers we use host our information in other countries). We recognise that we’re accountable for your personal information wherever it is in the world. Where we can, we will send personal information only to countries that have adequate privacy laws in place (such as NZ or Australia). However, where we cannot do this, we take reasonable steps to ensure that any third-party service providers we use can meet our privacy and security expectations.

We retain personal information only for as long as we have a lawful purpose to use it. Generally, this is the duration of your enrolment on one of our courses or services, plus a further 7 years. Where we are processing personal information on behalf of a government agency, such as the Ministry of Social Development, we retain your personal information on our servers only for as long as we are providing that service.

Security

Wherever your personal information is stored, we take reasonable steps to ensure that it is protected against loss or unauthorised access, modification, use or disclosure. These steps include the following:

• All our systems are protected by passwords, access limitations, firewalls and encryption.
• Staff are required to ensure that they access personal information for legitimate business purposes only, and we audit and monitor access to our servers.
• Staff are required to adhere to our Information Security Policy at all times, including when taking personal information, or accessing personal information, offsite.
• Staff are required to attend regular training in in privacy and security.
• We have a data breach management procedure that ensures we promptly identify, manage and notify data breaches.  

Accessing and correcting your personal information   

You have the right to ask us for a copy of the personal information we hold about you. You also have the right to ask us to correct your information if you believe it is wrong. To exercise any of these rights, or to make a complaint or ask a question about your information, please:

• call us on 0800 747 687;
• email us at privacyofficer@solomongroup.co.nz; or
• write to us at Solomon Group, PO BOX 75-239, Manurewa 2243.

We may need to verify your identity or authority before responding to your request. Once we’ve verified who you are, we’ll try and respond to your request or query as soon possible, and no later than 20 working days after we receive it.

Making a complaint

If you have any concerns about the way we’ve collected, used or shared your personal information, let us know and we’ll try our best to resolve them. If we can’t resolve your concerns, you can also make a complaint to the Office of the NZ Privacy Commissioner by:

• completing an online complaint form at www.privacy.co.nz; or
• writing to the Office of the Privacy Commissioner, PO Box 10-094, The Terrace, Wellington 6143, NZ.