This Biometric Data Collection Privacy Policy explains how our Law Firm, Gina Jansen Lawyers Ltd (“we”, “us”, “our”), collects, stores, uses, and protects your biometric data. It outlines your rights under the New Zealand Privacy Act 2020 and the Biometric Processing Privacy Code 2025.
We use Real AML Limited (“Real AML”), a third-party identity verification provider, to help satisfy our statutory compliance obligations.
Important Compliance Statement: This biometric identification process is carried out solely to satisfy identity verification obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act). Your biometric information will never be used for marketing, commercial profiling, or tracking emotional responses.
We process facial geometry and verification metrics exclusively to confirm that the person presenting an identity document is the true owner of that document. This mandatory verification fulfills our duty under Section 16 of the New Zealand AML/CFT Act 2009.
When you utilize the digital verification path via Real AML, the following data is processed:
Your participation in electronic biometric matching is completely optional. If you object to the use of biometric facial processing, you will suffer no adverse legal or service outcomes. You may select a non-biometric validation path, which includes:
All personal and biometric data is encrypted both while in transit and while stored at rest. Access is limited strictly to authorized AML compliance administrators within our firm and certified engineers operating Real AML platforms.
Under Section 92 of the AML/CFT Act 2009, records demonstrating compliance must be kept for a statutory period of five (5) years following the conclusion of our professional business relationship. Raw biometric transient files or temporary video components are systematically purged or anonymized by Real AML within safe operational limits once verification completes, while the final cryptographic confirmation ledger remains attached to your compliance file.
You possess the right under the Privacy Act 2020 to request immediate access to, or correction of, any personal information held within our systems. To initiate an inquiry, correct an entry, or file a standard inquiry, please contact our designated Privacy Officer:
If you are unsatisfied with our response, you have an explicit right to escalate the matter directly to the Office of the Privacy Commissioner (OPC) online via privacy.org.nz.
