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What Is A Privacy Collection Notice?
If your business collects personal information from clients or customers for a specific purpose, you may need a Privacy Collection Notice. In 2025, with increasing digitalisation and stricter privacy regulations, having transparent data handling practices is more critical than ever.
A Privacy Collection Notice is a document provided to individuals that summarises the personal information being collected and outlines the purposes for which it is being collected. It serves as a clear and concise snapshot of your data collection practices, ensuring that both you and your clients are on the same page regarding privacy expectations.
Understanding when you need a Privacy Collection Notice, a Privacy Policy, or both can be complex – especially with evolving regulatory requirements. We’ll clarify this for you and show you how to adopt best practices in line with the latest guidelines provided by New Zealand’s Office of the Privacy Commissioner.
When Do You Need A Privacy Collection Notice?
Under New Zealand law in 2025, a Privacy Collection Notice is not strictly mandatory for all small businesses unless they handle personal information in ways that may pose a higher privacy risk. Organisations that process large volumes of personal data, sensitive information, or operate as publicly reporting agencies are more likely to require a specific notice. This requirement is part of the updated New Zealand Privacy Principles, which continue to guide how you manage personal data.
We’ve discussed Privacy Policies in detail here and you might also find our legal tips helpful when reviewing your data protection strategy.
Nevertheless, it is considered best practice for all businesses to adopt robust privacy practices to protect both their operations and their customers’ information. Increasingly, companies are voluntarily adhering to strict privacy practices as a mark of quality and trust, thereby positioning themselves as a ‘privacy compliant’ organisation. If your business falls into this category, the updated New Zealand Privacy Principles apply fully to you.
Why Do You Need A Privacy Collection Notice If You Have A Privacy Policy?
To comply with the New Zealand Privacy Principles, you’ll need a Privacy Policy that comprehensively outlines how your business collects, uses, and manages personal data. A robust Privacy Policy demonstrates your commitment to transparency and lawful data processing practices.
The key difference between a Privacy Policy and a Privacy Collection Notice is specificity. While your Privacy Policy covers your overall approach to data protection, a Privacy Collection Notice specifically details how an organisation manages personal information collected for a particular purpose. For example, if you are collecting personal details to address a customer complaint or to sign up individuals for newsletters, your Privacy Collection Notice will explain the process and intended use of that data in clear, plain language. You might also check out our intellectual property and contracts pages for information on how tailored legal documents can further protect your business.
What’s In A Privacy Collection Notice?
Below is an outline of key elements typically included in a Privacy Collection Notice:
- The entity’s identity and contact details: This should include details of a contact person who handles enquiries and requests relating to the Privacy Act. Alternatively, a generic company email for privacy matters can be provided. For further guidance, our business setup page offers tips on maintaining clear communication channels.
- Facts and circumstances of collection: Describe how, when, and from whom the personal information was collected. It is particularly important to disclose this if the information is obtained from a third party.
- If collection is required or authorised by law: If there are legal requirements for collecting certain information, the relevant legislation should be cited. This ensures compliance with statutory obligations.
- Purposes of collection: Be transparent about why you are collecting the information. The Privacy Collection Notice should clearly state the precise purpose for which the personal information is being collected.
- Consequences for individuals if personal information is not collected: Outline any significant outcomes that may occur if the required information is not provided, such as the inability to process an application or deliver a service.
- Other entities, bodies or persons to which the personal information is usually disclosed: If the information is regularly shared with other entities, those entities should be named. For instance, our data privacy services highlight best practices in third-party data sharing.
- Information about access and correction in the entity’s Privacy Policy: Explain how individuals can access their personal information and request corrections, as detailed in your Privacy Policy.
- Likely cross-border disclosures of the personal information: Where applicable, indicate whether the information will be shared with recipients overseas, including details of the destination countries.
In addition to the above, consider including a brief section on how frequently the notice is updated to reflect any changes in your data handling practices – a recommendation that coincides with our advice in the business setup guides.
Enhanced Privacy Practices in 2025
Now, more than ever, businesses are expected to stay ahead of evolving privacy standards. In 2025, the focus has shifted towards not only complying with the letter of the law but also building customer trust through proactive transparency. Regular reviews of your Privacy Collection Notice as part of your overall compliance efforts – similar to the approach detailed in our legal tips – can help keep your business ahead of regulatory changes and industry best practices.
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There is no specific requirement for where a Privacy Collection Notice must be displayed or delivered in New Zealand. It is sufficient to demonstrate that reasonable steps have been taken to notify the individual or ensure they are aware of the Privacy Collection Notice.
Navigating New Zealand’s privacy laws and ensuring your company’s compliance can be challenging. At Sprintlaw, our team of experienced lawyers can assist you with drafting or reviewing your Privacy Collection Notices. We invite you to explore our guides and contract services to further understand how we can support your business’s legal needs.
Contact one of our consultants for a free, no-obligation chat on 0800 002 184 about how we can help with a Privacy Collection Notice and any other legal issues your business may face. You can also visit our contact page for more information or to book a consultation.
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