When we use the terms Rabobank New Zealand, entity, we, our, us; it means each member of the Rabobank Group based in New Zealand, being:
Rabobank New Zealand entity collects and processes the Personal Information it holds about you in accordance with its legal obligations under relevant New Zealand legislation.
Personal Information
Personal Information means any information about an identifiable individual. This includes an opinion, whether the information or opinion is true or not; or recorded in a material form or not. Common examples include your name and address, email, date of birth and also information such as your income.
Additionally, information relating to a sole trader or partnership is also considered Personal Information. Information relating to a legal entity (e.g. a company) is not Personal Information, but information relating to a legal entity’s directors, contact person or representative does count as Personal Information.
Processing of Personal Information
Processing of Personal Information means any action that is performed on Personal Information. This includes the collection, recording, storage, organisation, alteration, use, transfer, disclosure (including the granting of remote access), transmission or deleting of Personal Information.
We process Personal Information if we have or have had a business relationship with you. We also process Personal Information if we have had contact with you and/or your representatives or you wish to establish a business relationship with us.
We process Personal Information of:
Types of Personal Information | What kind of Personal Information might be involved? | Examples of how we use Personal Information |
Information that allows an individual to be identified directly or indirectly | Name, address, telephone number, e-mail address, information provided in your identity document such as driver’s license number or passport number and biometric information. |
• For identification purposes in compliance with laws; • To prepare an agreement; or • To contact you. |
Location information | Information that shows where you are. | To find out where and when you used your debit card. We do this to combat fraud. For example, the information provided by the ATM using your debit card. |
Information relating to or used for providing financial products and services | Information about your financial situation, the products you have, your investment profile and information used for obtaining finance, such as pay slips and the value of your property. This could also include Sensitive Information such as health information if relevant. | To assess whether a product is suitable for you e.g. if you have, or apply for, a loan with us, we want to determine whether this loan is appropriate. We may also record your sensitive personal information where we have your consent, or where we have a lawful purpose to do so. Sensitive personal information may include information about your health and/or disabilities or other personal data which might be considered sensitive. Purposes for which this information may be recorded include; • Providing extra care and helping you to access your banking services when you are experiencing a vulnerability; • Reasons relating to financial hardship; or • If you want to use a modified security token to assist with a visual impairment |
Payment and transaction information | When a payment is made, information about the person you paid or who paid you, when the payment took place and what the balance in your account is. |
• To execute a payment for you; • To be able to check whether the bank account number entered matches the name that is specified in a payment instruction; • To pass your information on to the other bank; • For your security and ours. For example, if a payment is made in New Zealand and in another country at the same time, we may be able to take steps to help remediate; or • To identify financial difficulty early. |
Information that tells us about the use of our website and the app |
• Cookies • IP address • Information relating to the device on which you use our online services or our website. • Information about browsing behaviour, browsing capabilities and preferences pages viewed, and browser type such as chrome or safari. |
• To understand your behaviour (e.g. webpages you have visited) and track your preferences on our website. For more information refer to our Cookies page; • To combat fraud; • To improve the functionality of our website; • For displaying targeted adverts or banners; or • We use web analytics packages and our content management system to enable us to analyse information, learn about our visitors and measure the performance of our website and web content. |
Information we receive from other parties |
• Information obtained from public registers (e.g. New Zealand Company Office) or an individual’s credit history from a credit reporting body. • Information contained from other businesses who you have given consent to share your information with us. |
• We use this information to check whether you can be granted credit, or to check the value of a property; or • We may receive the Personal Information of multiple directors or ultimate beneficial owners of a company from one representative within that company such as the CFO for the purposes of on boarding that company as a client. |
Information we share with other parties |
• Financial information • Loan information • Information we provide to other parties that we engage to help us provide services • Information you have asked us to share with another party • Information we have to share with our regulators or enforcement agencies (e.g. Police) |
• Regulators include the Reserve Bank of New Zealand (RBNZ), the Financial Markets Authority (FMA) and the Department of Internal Affairs (DIA); • Other parties (such as marketing agencies) that process information on our behalf because they are involved in the provision of our services; • You may also ask us to share specific information with a third party; or • We many need to use or disclose your information in order to detect, prevent or investigate any suspected or actual fraud, crime, misconduct or unlawful activities. |
Information we require to combat fraud, to ensure your security and ours, and to prevent money laundering and the financing of terrorism |
• The information we keep in our internal and external registers, fraud detection systems, sanction lists, location information, transaction information, identity information, camera images, cookies, IP addresses. • Information relating to the device on which you use our online services. |
• In order to comply with legal obligations and protect you, the financial sector, Rabobank New Zealand or our employees, we check whether you appear in our internal or external registers and whether your name appears in sanction lists; • We use location and transaction information in order to monitor payments to prevent fraud, money laundering and terrorist financing; or • We may use your IP addresses and device details to combat online fraud and scams. |
The collection of most Personal Information will be directly from you and with your consent, which will usually be obtained at or around the time you contact us or take out a product or service with us. Examples include information when you enter into an agreement with us, information you enter on our website so we can contact you, and information arising from the services we provide in areas such payments.
With your consent, we may also receive your information from:
We may also obtain your information from public sources like newspapers, public registers (e.g. New Zealand Companies Register), websites and open sources of social media.
At or before the time or, if that is not practicable, as soon as practicable after, we collect Personal Information about an individual, we will take reasonable steps in the circumstances to let that individual know we have their Personal Information.
If your business or organisation transfers any Personal Information concerning employees, executive directors or ultimate beneficial owners to us, we expect your business or organisation to inform them about this. You can give this Privacy Statement to them so that they can learn how we deal with their Personal Information.
To provide you with the best possible service, we need to know you well and develop our client insights about you. In order to do that, we collect and process your Personal Information only where we have a lawful purpose to do so and when we deem it reasonably necessary for one or more of our functions or activities.
To enter into a business relationship and agreement with you
We need to have your Personal Information if you want to become a client, or if you want to use a new product or service, or for us to contact you.
To perform agreements and carry out instructions
We execute the instructions we receive from you and perform the agreements we have entered into with you. We process Personal Information to achieve this purpose.
To ensure your security and integrity as well as the security and integrity of the bank and the financial sector
We collect and use your Personal Information to protect you, the Bank and the security of the financial sector. We also do this for the purpose of preventing fraud, money laundering and the financing of terrorism.
i. Customer Due Diligence
We check whether we can accept you as a client when we enter into a business relationship with you and during that business relationship. For example, your transaction information may cause the Bank to conduct an enhanced due diligence on your account(s) and relationship with the Bank.
If you do not provide the Bank with all of the required information, we may not be able to continue our banking relationship with you.
ii. Internal and external registers and warning systems
If you seek to become a client, or are already a client of ours, we will consult our internal registers and warning systems and, additionally, external registers available within the financial sector.
In addition, public authorities send us lists of individuals, which we have to enter in our internal registers and warning systems. These are individuals with whom financial institutions must not do business, or to whom the financial sector must pay extra attention.
iii. Publicly accessible sources
We consult publicly accessible sources, such as public registers, newspapers, the internet and public profiles of your social media, in an effort to combat fraud, money laundering and terrorism financing and protect the bank.
iv. Fraud, Money Laundering and Terrorism Financing
We may perform analysis aimed at preventing fraud, money laundering and terrorism financing to assist in protecting you and the bank. For example, we may collect information in respect to your usual transaction behaviour in order to detect and reduce money laundering and terrorism financing. If the observed behaviour differs from your usual transactional behaviour or there are other indicators, this may form grounds for suspending or blocking payments by fully automated means.
We make recordings of telephone and video conversations, e-mail messages and camera images (at our branches), for example, and may document these recordings. We do this in the context of investigating fraud. We may also do this to fulfil legal obligations, monitor and improve the quality of our products and services, improve our assessment processes and train, coach and assess our employees.
To help develop and improve products and services
In order to provide you with the best possible service and to continue to innovate and develop as a bank, we are constantly improving our products and services. We do this for our clients, ourselves and other parties.
For account management, promotional and marketing purposes
We process your Personal Information for account management, promotional and marketing purposes. In doing so, we use information we have directly obtained from you, such as payment information or information we have indirectly obtained via cookies, for example your activity on our website. We also collect Personal Information not obtained directly from you, including public registers and publicly available sources (such as the internet and social media).
If you do not want your information to be used by us for the purpose of direct marketing or by post, e-mail or telephone, you can let us know, refer to section ‘What rights do you have to your Personal Information?’ of this Statement for details or alternatively visit our Individual Rights portal.
Please note that from time to time, we may be legally obligated to contact you even if you have opted-out of direct marketing messages. These are known as service messages, which we need to send you.
To enter into and perform agreements with suppliers and other parties we work with
If you have contact with us in the context of a supplier arrangement or business partnership, we may process your Personal Information, for example so that we can establish whether you are permitted to represent your business or whether we can give you access to our locations. Where necessary, we may consult internal and external registers and warning systems before we enter into an agreement with you and also while the agreement is in effect.
To comply with legal obligations
i. Legislation
We have to collect and analyse a large amount of information relating to you and sometimes transfer such information to government authorities under various national and international legislation and regulations that apply to us and other members of the Rabobank Group.
For example, we must comply with legislation designed to combat fraud, crime and terrorism, such as anti-money laundering legislation in order to be able to offer you financial products and services.
We are required to perform customer due diligence and to conduct further enquiries if you hold specific assets or if an unusual transaction takes place in your account. If we observe an unusual transaction, we must notify the relevant law enforcement agency. We may be required by law to establish who the ultimate beneficial owner is of a business or organisation with which we have a business relationship.
We may receive requests for information from regulators and government agencies. If we receive such requests, we are required by law to cooperate with any request or investigation, and transfer information relating to you.
ii. Risk models
New Zealand regulations allow for us to produce risk models if you apply for a loan or credit or if you have received a loan or credit from us. This is so that we are able to determine which risks we are exposed to and the size of the buffer we need to maintain. We process your Personal Information as part of this purpose.
We can also use these risk models before we offer you a credit. We may also use these models when determining the price for business financing, to prevent situations in which you are unable to repay your financing, or are unable to repay it on time. We may also use profiling and techniques for making decisions in partially automated manner.
These risk models may also predict how likely it is that you will fall behind on your payments. We can use the information they provide to prevent or deal more quickly with any payment problems, for example in consultation with you. We will then process your Personal Information for this purpose. We will do this for various reasons. These include performing our agreement with you and because we are required to do this by law.
iii. Providing information to the government
Legislation and regulations may require that we transfer information (analysed or otherwise) relating to you to a Government institution, a tax authority or a regulator within or outside New Zealand.
iv. Making and documenting recordings
We make recordings of telephone conversations, e-mail messages and video chat sessions to comply with any legal obligations. We may also do this to fulfil legal obligations linked with record keeping, to monitor and improve the quality of our products and services, to combat and investigate fraud, or to train, coach and assess employees.
To carry out business processes and for the purpose of management reports and internal management
i. Determining credit risk associated with loans and credit facilities
Lending involves credit risk. We have to determine what that risk is, so that we can calculate the security we need to maintain. In connection with this, we process Personal Information relating to your loans and credit facilities.
ii. Audits and investigations
We also use your Personal Information to perform our internal and external audits and investigations, for example in order to examine how well new rules have been introduced or to identify risks. We may engage a third party to assist with this.
iii. Improving our own business processes
We also use information to analyse and improve our business processes so that we can help you more effectively or make our processes more efficient, and to build management reports. We also have to validate the models we use. Where possible, we will de-identify or aggregate your Personal Information first.
We do not keep your Personal Information for longer than is necessary to fulfil the purposes for which we collected the information or the purposes for which information is reused. We are required to keep some of your Personal Information for certain periods of time under certain legislation. We may keep the information for longer if, for example, we are requested by authorities for information to assist in an investigation, or if you have submitted a complaint, or there are ongoing legal proceedings.
When we no longer have a legal basis for using your Personal Information, we will delete, destroy or de-identify your Personal Information.
Automated decisions are decisions that are made about you solely by computers without any human intervention. If these decisions have legal consequences for you, then we are not allowed to use automated-decision making. If automated-decision making is necessary to enter into or perform a contract, is authorised by law, or if you give us your explicit consent, then you have the right to consult someone at the bank and to express your point of view and contest the decision.
In the following situations we might use automated decision making that might affect you:
Within Rabobank New Zealand, your Personal Information can be accessed only by employees or individuals who need to have access, owing to their position. All of these people are bound by a duty of confidentiality. We have practices and policies in place to provide a high level of security to protect Personal Information.
We take all reasonable precautions to protect your Personal Information by:
If we want to use Personal Information for any purpose other than the purpose for which it was obtained, we may do this as long as the two purposes are closely related and you consent to us using the Personal Information for this purpose. We may also be required to do so in compliance with laws.
If there is not a sufficiently strong connection between the purpose for which we obtained the information and the new purpose, we will ask you to give your consent if we still want to use this information. You can always withdraw your consent. Please visit our Individual Rights Portal or section ‘What rights do you have to your Personal Information?’ of this Statement for more information on the rights available to you.
Depending on the product or service we provide to you, we may, with your consent, disclose your Personal Information to:
We may disclose your Personal Information to third party service providers when we outsource certain tasks and operations, including mailing, printing, direct marketing and information technology services.
Where we disclose your Personal Information to a third party service, we enter into contracts with confidentiality arrangements in place, so that these providers meet our privacy standards in protecting your Personal Information, comply with the New Zealand privacy legislation, and use or disclose Personal Information only for the specific service we have asked them to perform, or the product/service we have asked them to provide.
Securitisation involves the pooling and selling of assets such as loans to a special purpose vehicle. To undertake this process, we may disclose Personal Information to any person to whom our rights in pooled assets are to pass or proposed to pass and to any ratings agencies, trustees, investors and advisers involved in the transaction.
We need to determine whether or not you are able to repay your loan when you apply to us for credit. We base our decision on your current financial position and on your credit history. This means that we will consider the information you give us in your application and may make enquiries with, and obtain further information, from a credit reporting agency.
We may collect, hold and disclose your credit-related information as reasonably necessary for our business purposes and as permitted by law, such as to make decisions as to whether to provide you with credit, evaluate your credit-worthiness, manage credit provided to you, participate in the credit reporting system and providing information to credit reporting agencies.
We can only give your credit-related information to a credit reporting agency if we have told you first that we will do so and we can only obtain information about you from a credit reporting agency if we have your consent.
We may disclose Personal Information to overseas recipients, including to:
Where we disclose Personal Information overseas we take reasonable steps to ensure the recipient meets our privacy standards in protecting your Personal Information and complies with the New Zealand privacy legislation.
You may ask us whether we process Personal Information relating to you and request access to your information. If you believe your Personal Information has been processed incorrectly or incompletely, you may request that we change or supplement the information (correction).
You may request that we delete your Personal Information that we have recorded, for example if you object to the processing of your Personal Information. We may not be able to do this, for example, if we still have to store your information due to legal obligations relating to record keeping. We will inform you if this is the case.
You may request that we temporarily restrict the Personal Information relating to you that we process. This means that we will temporarily process less Personal Information relating to you.
If we process your information it is because we have a legitimate interest in doing so. You may object to processing of your Information, in that case, we will reassess whether it is indeed the case that your information can no longer be used for a specific purpose. We will inform you of our decision, stating the reason. The operation of this right may impact the way we continue to provide you with products and services, we will inform you if this is the case so you may make an informed decision.
You have the right to request that we stop using your information for direct marketing purposes. If you advise us that you do not want to be contacted for direct marketing purposes, we will then take steps to ensure you are no longer contacted through the relevant channel.
We may be legally required to contact you even if you have opted-out of direct marketing messages. These are known as service messages, which we need to send you.
How do you make a rights request?
To make a rights request to your Personal Information please visit our Individual Rights Portal. You may also contact us through the channels described in the section below.
If you make an Individual Rights request, we will answer this within 20 working days after we have received the request.
If you have a general concern or complaint about the processing of your Personal Information held by us, we want to hear from you. In the first instance, please contact us by using the details below.
Rabobank New Zealand | Rabobank Online Savings |
Phone 0800 500 933 MON - FRI 8am - 5.30pm (New Zealand time) If you're overseas call +64 4 819 2783 |
Phone 0800 22 44 33 MON - FRI 8am - 6pm (New Zealand time) If you're overseas call +64 4 819 2870 |
Alternative contact methods can be found here: Contact Us
We are committed to resolving any concern you may have quickly and fairly. We will acknowledge your complaint within two business days and our goal is to resolve it within five business days.
If we cannot resolve your complaint when we first hear about it, we will regularly update you about the progress of resolving the complaint.
In exceptional cases, we might require more time than we first anticipated to review a complaint and find a resolution. We will let you know if that happens and why. We will also let you know by what date we will have finalised our investigation.
If you are not satisfied with the resolution offered by Rabobank, you have the following options:
We will review our Privacy Statement on a regular basis and that means that it may change from time to time. We will keep you informed of material changes to this Statement. You can always find the most current version of our Privacy Statement at www.rabobank.co.nz.
Latest Version: August 2023
If you have any general feedback or queries regarding the way Rabobank handles your Personal Information, you may also contact the Privacy Officer by email at newzealand.privacy@rabobank.com.