About Your Privacy

Below is a list of Spark services to help you manage your privacy.

As you use our services, we collect data about your use of our mobile network, including mobile location data. We use this information, in an aggregated and anonymised way, to optimise our network and enhance our customer service experiences.

Insights gained from analysis of aggregated, anonymised data can also help other organisations better understand, plan for and meet their customer needs, and the needs of the public (e.g. to help improve the planning for public transport services).

We provide anonymised data to our trusted partner Qrious, a Spark-owned data and analytics organisation, who provide data insights to organisations using a range of anonymised and aggregated data sets from a variety of sources. Qrious sometimes uses aggregated and anonymous information to help New Zealand organisations improve infrastructure and services. Examples include improving transport decisions, helping organisations better understand their customers, and supporting tourism in regional New Zealand.

If you would like to opt-out of your information being used by Qrious, or if you have any queries or concerns, please email privacy@spark.co.nz

As part of our commitment to providing the best possible service to our customers we record all telephone calls answered in our contact centres and Live Chat between our contact centres and customers. This helps us to identify ways that we can provide you with a better service.

We record calls and Live Chat:

• for staff training, helping us to improve the quality of our customer service and to ensure the information we provide is consistent and accurate;
• for reporting on the types and numbers of enquiries we receive;
• so we can find ways to simplify and improve our service to you.

We understand your personal information is important and we are committed to protecting your privacy.  We generally store the recordings securely for up to 60 days and delete them after this period unless the recording is needed:

• for the purposes of more particular coaching or complaint investigation;
• as required under legislation or industry codes.

Our Web Privacy Policy applies to anyone visiting our Spark website.

Information about how we manage privacy for specific Spark Products and Services is set out in the Terms and Conditions for each product and service.

Background

In New Zealand, there are 2.5 million calls per year to the emergency 111 number.  Calls are transferred to Police, Fire, or Ambulance systems as required and are answered by a call taker whose first task is to establish the location and nature of the event.   

For calls from landlines, verification is greatly sped up by an existing system where the subscriber name and address is presented automatically to the Emergency Service Provider when the call is answered (as allowed for by Rule 11((h) of the Telecommunications Information Privacy Code 2003.) However, 80 percent of emergency calls are from mobile devices and for these only the broad region of call’s origin on the mobile network (e.g. ‘Taranaki mobile’) is presented to call takers. This means that the caller’s location must be established by question and answer before the event can be accepted into dispatch.   This can delay the emergency response to the caller, and potentially to other callers.

Emergency Caller Location Information (ECLI) system

When you dial 111 (or 911 or 112) from your mobile phone, where there is sufficient mobile network connectivity, the Emergency Caller Location Information (ECLI) system enables information about the location of your handset to be shared with the Ministry of Business, Innovation and Employment (MBIE) and Emergency Services Providers to help Emergency Services Providers verify where you are as quickly as possible and facilitate a response to your call.  (Please note that callers will still need to try to provide their address or location as first priority – the ECLI system is an additional location verification mechanism).

Spark together with Google provides this ECLI through a 111 Location Area Service system operated by MBIE.  The 111 Location Area System collates the ECLI and sends it to the applicable Emergency Service Provider.   The ECLI that we provide to MBIE:

• is GPS based location data from smartphones that are running the Android operating system. This is based on Google‘s Emergency Location Service using GPS, Wi-Fi or cell site information (location information switches on when the 111 call is made and switches off when the 111 call ends);
• is cell-site location data generated by the 111 call from your handset (from August / September 2017);  
• will only be used for the purpose of helping Emergency Services Providers identify the location of callers to 111 in order to respond to their request for assistance;
• will not be retained by the 111 Location Area System; and
• may be retained by Spark, together with a record of its delivery to the 111 Location Area System for operational purposes for up to a year.   

The Privacy Commissioner has amended to the Telecommunications Information Privacy Code to authorise the provision of ECLI to Emergency Service Providers using the 111 Location Area Service system (Telecommunications Information Privacy Code Amendment No 5.)

More information about how ECLI system operates is available from MBIE here  

Information requests and complaints

You can request access to any information held by Spark following our standard process (see Access to and correction of your personal information below).

Any complaints relating to the services provided by Spark can be made here. Complaints concerning Emergency Service Providers should be made to the relevant organisation as set out here.  Any general complaints about the ECLI system should be emailed to info@mbie.govt.nz.

You can request access to, and correction of, the personal information that we hold about you.  To request access to, or correction of, your personal information contact the Spark Investigations Centre, P.O Box 550, Wellington 6011, or email cic@spark.co.nz. A member of the Spark Investigation Centre team will contact you:

• to confirm your request, and make sure we provide you with all the information you are seeking, and;
• to advise of any charges that may apply before processing your request.

We will provide you with access to your personal information.  Occasionally we may withhold information on one of the grounds set out in the Privacy Act 1993.  Your request will be processed within 20 working days, and provided to the address that we hold for you by courier.

We work hard to ensure all customer data is kept safe and we follow industry best practice in this regard.  If we become aware of a data breach that we consider could compromise customer security, our policy is to report this to affected customers at the earliest opportunity.  We may also report the breach publicly, where we consider it is appropriate to do so.

We understand you value your privacy, and we have robust and thorough processes to manage the personal information we hold about you.   If you have any concerns about your privacy, or if you feel your privacy has been breached, we have a Spark Privacy Complaints Process in place to ensure we investigate and address your concerns as quickly as possible – you can view our Privacy Complaints Process, or contact us with your feedback.