Privacy Policy - Metlifecare

METLIFECARE LIMITED PRIVACY POLICY

INTRODUCTION

Metlifecare Limited is committed to safeguarding personal information and complying with the privacy principles set out in the Privacy Act 2020 (Act), together with the requirements of the Health Information Privacy Code 2020 (Code). This privacy policy explains how Metlifecare collects, uses, disclosures and stores personal information, including health information.

You, acknowledge that you have read this privacy policy carefully and that you understand and consent to the collection, use, disclosure, storage, and retention of your personal information as described in this privacy policy when you access or use our website, products, or services. If you do not agree with any term set out in this privacy policy, you should not share personal information on our website, or in connection with our products and/or services. This privacy policy applies in addition to, and does not limit, our rights and obligations under the Act and the Code (as amended or replaced from time to time) or any specific authorisation that you provide to us when you interact with us or use our services.

You are not required to provide us with any personal information. However, if you do not provide us with certain information that we request, you may not be able to access or use some parts or all of our website, or our products or services.

In this privacy policy:

“health information” has the meaning given to that term in the Code. This includes information about your health (including your medical history), information about any disabilities you have (or have had), information about any health services or disability services that are being (or have been) provided to you, or information about you which is collected before or in the course of (or incidental to) the provision of any health service or disability services to you;
“Metlifecare”, “we”, “us” and “our” means Metlifecare Limited and, if applicable, our successors and assignees;
“Metlifecare group” means any company within the group of companies of which Metlifecare Limited forms part, at any time;
“personal information” means any information about an identifiable individual, including health information. For example, this includes your name and financial information;
“Residents” means individuals who are resident at any of our retirement villages or care homes;
“website” means https://www.metlifecare.co.nz and any other website or application (including any applications for mobile devices) that are owned or operated by us or any company in the Metlifecare group; and
“you” and “your” means the individual that this Privacy Policy applies to, including Residents and your authorised representatives (including pursuant to a power of attorney), as well as individuals who are not Residents but have expressed interest in, or applied for, our products or services.

CHANGES TO THIS PRIVACY POLICY

We may amend this privacy policy from time to time by posting a revised version of this privacy policy on our website. The revised version of this privacy policy will take effect immediately upon publication (or, if applicable, on the date specified in the revised privacy policy) and will apply to all personal information that we hold about you (unless you notify us that you do not agree to the changes). If the changes are material, we may also take additional steps to bring the changes to your attention, as required by law, including by notifying you directly.

You are responsible for reviewing this Privacy Policy regularly to ensure you are aware of any updates.

TYPES OF PERSONAL INFORMATION WE COLLECT

The personal information we collect will vary depending on the services that you use, and your interactions with us. For example, we may collect your:

name, email address and telephone number;
address;
age/date of birth;
gender, ethnicity and spoken languages;
job title and employer/organisation;
for Residents, details of your bank account and other payment information;
details relating to your authorised representatives, including copies of any enduring powers of attorney, together with relevant contact details of the appointed attorneys;
details of any enquiries you have made to us, and our response to you;
CCTV footage at our facilities; and
any other personal information that we request or you provide to us or authorise us to collect.

Health information

Wemay also collect health information from you, including your medical history, medication and prescription details, clinical notes, and health services you are currently being or have been provided, but only to the extent that such health information is required for us to provide you with the requested products or services.

HOW WE COLLECT PERSONAL INFORMATION

Where possible, we collect personal information directly from you, including when you access or use the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you register or use our products or services.

We also collect personal information from other persons or sources, with your authorisation or in accordance with the Act and the Code.

CCTV monitoring

We may use CCTV and IP cameras to record footage at our facilities. This footage is considered personal information and is therefore subject to the Act and this Policy. We may use CCTV footage for the purposes of investigating, deterring and detecting criminal behaviour at our villages and care homes, for the wellbeing, safety and security of our Residents, staff, property and visitors.

We will ensure that the monitoring of CCTV does not unreasonably intrude on situations where there is an expectation of privacy. Signage advising that cameras are in operation will be installed in accordance with the Privacy Act. Only approved persons will be permitted to access CCTV images and CCTV footage.

Collection of information about other People

If you provide us with or authorise us to collect personal information about another person, you confirm you have obtained their consent to provide us with, or that they have authorised us to collect, their personal information and that you have informed them of their rights to access and request correction of their personal information, as set out below.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes:

for the general operation of Metlifecare and our relationship with you – including to contact you about and enable you to apply for, and use, our services and products, to provide you with, and monitor, the products or services that you have requested and to communicate with you and your authorised representatives;
considering any application from you or on your behalf for any of our services and products, including to establish and verify your identity and, if applicable, to assess your creditworthiness and financial position from time to time;
exercising our rights and fulfilling our obligations under any agreement with you and under applicable laws;
providing you with information about our other products services, or the services provided by the Metlifecare Group and selected third parties, that we think you may be interested in, including by post, telephone, text, email and other electronic messages – you can opt out of receiving information about our other services and/or the services of selected third parties by telling us in writing;
to improve the services and products that we provide to you;
to bill you and to collect money that you owe us, including authorising and processing credit card transactions;
to respond to communications from you or on your behalf, including in relation to requests, enquiries, or complaints, or to otherwise contact you about our products or services;
to conduct research and statistical analysis (using anonymised information);
to protect and/or enforce our legal rights and interests, including defending any claim;
for any other purpose authorised by you or by the Act or Code; and
to carry out any activity in connection with a legal, governmental or regulatory requirement or in connection with legal proceedings or inquiry, or the investigation, prevention, detection or prosecution of crime.

We will not use personal information for any other purpose, unless we have your consent to do so, or we are permitted or required to do so by law.

If you consent to us using your personal information to market and promote our services and products, you can opt out at any time by notifying us at privacy@metlifecare.co.nz or by clicking the unsubscribe function included in our electronic marketing communications.

COLLECTION OF IMAGES AND PHOTOGRAPHS

We may at times record the image of Residents, unless Residents opt out by notifying us at privacy@metlifecare.co.nz .These images will be used for publicity and advertising purposes, including (but not limited to) on our social media platforms, in our annual reports and in our marketing material. If you are a Resident who has not opted-out, you consent to the use of your image, and give us the right and unrestricted permission to use, display, distribute, transmit, publish and copy your image through any media or medium for publicity and advertising purposes at any time. You irrevocably waive any and all moral and performers’ rights in relation to the images to the fullest extent permissible at law and confirm that you are not entitled to compensation or other remuneration, now or in the future, in return for any use of the images.

DISCLOSING YOUR PERSONAL INFORMATION

We may disclose your personal information to:

another company within the Metlifecare group, which may use your information for the purposes set out above;
our service providers or any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products;
a credit reporting agency for the purpose of credit checking you – credit reporting agencies may retain information (including default information) and use it to provide their credit reporting services;
insurers;
your authorised representatives (including pursuant to a power of attorney);
other third parties, in an aggregated and anonymised form for statistical purposes;
a person who can require us to supply your personal information (e.g. a regulatory authority);
any other person authorised by you or to whom we are permitted or authorised to disclosure personal information in accordance with the Act, Code or any other law(e.g. a law enforcement agency).

PROTECTING YOUR PERSONAL INFORMATION

Storage

Personal Information that we collect is either held by us at our head office (refer to the Contact Us section below) or is stored by third-party service providers on our behalf. Some information we hold will be stored on our behalf by third parties based overseas. The use of these services, and the transfer of information overseas (if applicable) will not relieve us of our obligations under the Act and this privacy policy.

Security

We will take reasonable steps to ensure the personal information we hold is accurate, complete, up to date, stored in a secure environment and is safe from loss, unauthorised access, use, modification or disclosure, or other misuse, in accordance with our obligations under the Act and the Code.

Some of the personal information we collect and hold about you may be considered particularly ‘sensitive’ personal information and subject to additional protections and requirements under New Zealand law (such as health information). Where required by law or regulation, we will handle this type of personal information to a higher standard than other types of personal information due to its special nature.

We will only retain your personal information for as long as it is required to achieve the purposes set out in this privacy policy, for our record keeping purposes or as otherwise required by law.

Although we take reasonable steps to ensure personal information in our possession is protected and held securely, we do not make any warranties in relation to the security of any information you disclose or transmit to us and we are not responsible for theft, destruction, or inadvertent disclosure of your personal information where our own reasonable security measures have been breached. Any transmission of personal information is at your own risk.

Updates

We rely on you to update us if your contact details change (please refer to the Contact Us section below).

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

Subject to certain grounds for refusal set out in the Act or Code, you have the right to access personal information that we hold about you, and to request that we correct your personal information. Before you exercise this right, we will need evidence to confirm you are the individual to whom the personal information relates (or that you are authorised to access the personal information on their behalf).

If you want to exercise either of the above rights, email us at privacy@metlifecare.co.nz. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

We may charge you reasonable costs for providing you copies of your personal information or correcting that information, subject to the Act and the Code.

USE OF OUR WEBSITE AND SOCIAL MEDIA PLATFORMS

If you post any personal information on our website’s message board, chat room or social media platforms, you acknowledge and agree that the information you post is publicly available and may be read or used by other users of our website or social media channels.

Our website may have links to third party sites. Our privacy policy does not apply to those sites and we accept no responsibility or liability for the content or privacy practices of those sites. The owner of the third-party site will have its own privacy policy relating to your personal information which we suggest you review before you provide any personal information.

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website for the purposes of providing more customised content to you on our website and conducting business and marketing analysis. All information collected via cookies will be held by us. This information will not be made available to any third party in a manner that enables you to be identified. If you do not wish to allow cookies, you may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

HOW TO CONTACT US

If you have any queries or concerns about our privacy policy, or our handling of your personal information, please contact us at Metlifecare Limited at Level 4, 20 Kent Street, Newmarket, Auckland, 1023, New Zealand, attention Metlifecare Privacy Officer, or call us on 09 359 8000, or email us on privacy@metlifecare.co.nz.

This privacy policy was last updated on 3rd May 2021