Privacy

Types of personal information BOS collects includes:

• your name, address, email address, and telephone numbers;
• details of your complaint and interactions with your bank or financial service provider;
• information about your interactions with us, such as when you visit our website or when you call us, email, post or meet with us in person;
• your feedback provided to us in surveys, comments, and complaints.

BOS is a free and independent dispute resolution service. We look into complaints by customers about their banks or financial service providers. Sometimes we make formal decisions, but often we facilitate agreed outcomes between the customer and the bank before that. We also help in other ways, such as offering information and guidance on banking matters.

Most of our collection, use and disclosure of personal information is done for the purpose of effective complaint investigation and resolution. It might also be used for related purposes, such as: 

• evaluating the effectiveness of the scheme, or aspects of the scheme
• reporting to stakeholders on the operation of the scheme, or
• promoting the scheme, including communication with the public, stakeholders and the media via websites and social media.

We take safety very seriously so we will contact Police or other emergency intervention services in circumstances where a person threatens harm to themselves or other people. If a threat is made to a bank or organisation, we will notify them of the threat.

BOS anonymises information used for promotion or any public disclosure, including all public reporting on complaints. We de-identify (remove obvious identifiers like your name) whenever possible for our evaluation practices.

You can call us and not provide us with identifying information (though the call will be recorded). You can also read information on this website and we only use aggregated (eg totals of everyone who reads it) information.

When you make a complaint with us, you get to tell us in your own words what your complaint is about and provide us with any relevant information or documents. You also must decide about giving us authority to provide and gather relevant information with the bank you are complaining about. You can also indicate to us what information is sensitive or confidential that you would not like us to disclose.

We will make sure you are fully informed when you make a consent decision. This includes:

• knowing what we will do with your information before you decide; and
• knowing what the consequences are of your decision – how agreeing will help and what will happen if you do not agree.

You can change your decision at any time by contacting us about it.

Our Board monitors our privacy risks and measures our privacy performance.

We ensure our systems and processes support us to properly manage your information and promote your privacy.

We ensure our staff are properly trained and have access to support in order to get it right. We have appointed a Privacy Officer to promote privacy within our organisation.

We acknowledge the trust you have placed in us by providing us with information about you. We recognise the need to manage it well in order to demonstrate professionalism in our service.

We obtain independent assurance from time to time about our practices.

We urgently fix any mistakes we make, and we learn from them. We take feedback and complaints seriously.

If you wish to make a complaint about your bank or financial provider, you should only send information relevant to the dispute and keep to a minimum information concerning third parties.

BOS will not accept personal information obtained by any person in any way which is unlawful or improper.

We keep records relating to complaints for up to 6 years.

Web complaint form

You can submit details of your complaint through our web form. We receive this as an email, which we will provide to your bank (copied to you where you provide an email address) to begin the resolution process.

Agents or representatives

You are welcome to have an agent or other person to represent or support you during your interactions with us.

Call recordings

We record all inbound and outbound telephone calls. We record calls:

• to ensure we have an accurate record of your call, which we can use for the purpose of investigating and resolving your complaint
• for staff training purposes, to help us improve our service and to ensure the information we provide is consistent and accurate
• for reporting on the types and numbers of enquiries we receive.

Copies are held for up to one year.

Website analytics

We gather information to administer the website and to gain a better understanding of visits. We collect user internet addresses, browser type and internet service provider details and other technical information. We generate statistics about page use, eg what is accessed, what documents are opened, and what tools are used. This assists us to understand what is important to users and help us to improve our website.

We keep the aggregated reports but do not receive or keep identifying information (eg IP address).

Cookies

Cookies and other session tools may be used for security and performance to improve user experience when accessing our website.

A cookie is a small piece of text stored on a user's computer by a web browser. It is sent by a web server to a web browser and then sent back unchanged by the browser each time it accesses that server and is used for remembering data about the computer user (such as IP address; dates and times of visits, pages accessed, documents opened and links clicked). 

You can prevent cookies being used by updating your browser settings.

We use the following third-party platforms for the following purposes:

SurveyMonkey – we use SurveyMonkey to conduct customer satisfaction surveys. We disclose your name, email address (unless you have indicated otherwise), and bank to SurveyMonkey to generate and conduct the survey. SurveyMonkey is based in the United States. The responses you provide to the survey are anonymous and we only receive aggregate, statistical information. To find out more, see the SurveyMonkey privacy policy.

MailChimp – we use MailChimp to generate and distribute newsletters and undertake bulk email campaigns. We provide MailChimp with your name, email address (unless you have indicated otherwise), and bank to generate We do not use the analytics tools offered by MailChimp. To find out more, see the MailChimp privacy policy.

Google Analytics – we use Google Analytics services to understand how our website is used. To find out more, see the Google Analytics privacy policy.

SilverStripe – we use SilverStripe to manage our website. Information you submit through our website is hosted on servers in New Zealand and Australia.

Xima Chronicall phone system– we use this software to record our inbound and outbound calls. Copies of relevant calls are transferred into our CMS files. Call recordings are held online at our officers in Wellington and backed up to servers in Auckland. 

Facebook, Instagram – we use our social media platforms to promote our services and interact with members of the public. Interactions with us on social media platforms will remain stored with those platforms and will be subject to the privacy policies of the platform provider.

Complaints

We will only disclose information about a complaint to the customer or their authorised representative, and parties to the complaint.

From time to time we are contacted by persons who advise that they represent a complainant and who seek information about the progress of a complaint, for example, Members of Parliament and/or their electorate office staff, legal and financial advisers, friends and family members. We will not discuss any aspect of a complaint with any person other than the complainant unless we have explicit authority from the complainant to do so. We do not regard a person copied into correspondence as being authorised to discuss the complaint or receive information about the progress of the complaint.

We will not disclose personal information to another party if you explicitly deny consent for the disclosure. However, where you deny consent, we may be limited in the assistance we can offer with resolving your complaint.

In order to investigate or resolve a complaint, we may disclose personal information to providers, third party experts/advisors or other agencies, such as external law firms, who are subject to their own professional obligations.

Reporting

We provide anonymised information in reports to scheme participants and other relevant bodies, such as government agencies or regulators. 

Evaluation of services – customer satisfaction

To ensure BOS provides an effective and efficient level of service, we may disclose customer information to market research companies for the purposes of customer satisfaction surveys. The market research company is required to sign a confidentiality agreement before we provide them with access to any information.

BOS does not engage in any direct marketing activities and will not provide customers’ personal information to another body for the purposes of direct marketing.

Case notes

Before we publish case notes we anonymise all personal information.

Media enquiries

We do not provide media with personal information relating to a complaint, unless the information is already publicly available or authorised by the individual. This is either proactively or in response to a request for comment.

We will take reasonable steps to make sure that the personal information collected, used or disclosed is accurate, complete and up-to-date.

We will make the necessary changes to personal information details held where you or your provider notifies us of errors or changes required. We will make the changes as soon as practicable.

If a change is not made, we will ensure you have the opportunity to provide us with what you believe the correction should be and we will attach it to the information you believe needs to be corrected.

It assists us if you make information requests in writing but we will also receive requests over the phone.

We will provide you with the information you ask for as soon as possible, and no later than 20 working days. Some information may be withheld or removed if one or more of the exceptions in the Privacy Act applies - for example, where it is confidential information.

We may provide you with the information you request as a summary, in documents, or by allowing you to view the information at our offices. We will undertake best endeavours to provide you with the information in the format you have requested.

We will provide you a written summary of calls.  You can request a copy of a call recording.  If a call recording exists, we will provide access to the recording unless we have a lawful reason for withholding this information. 

If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.

If we decide that a complaint should be investigated further, the complaint will usually be handled by a senior member of staff who was not involved in the original investigation.

We will tell you promptly that we have received your complaint and then respond to the complaint within a reasonable timeframe.