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2 How this privacy impact assessment relates to the data integration policy

The Data Integration Policy defines Statistics NZ's policy on integrating personal data. It applies to all integration of personal data that Statistics NZ undertakes for statistical or related research purposes.

The data integrations described in this PIA will provide new insights into agricultural land use and freshwater quality changes in New Zealand. The privacy impact risks with matching names and addresses (described as stage 1 in this data matching) are similar to those identified in other Statistics NZ privacy impact assessments. However, potentially there are significant strategic and public relations risks for Statistics NZ with this particular data matching.

This is due to the sensitive nature of the outputs. While the focus of this PIA is individual privacy, it also describes a wider range of risks.

The policy states that data integration should be considered in the production of official statistics when the following principles are met:

Principle 1: The public benefits of integration outweigh both privacy concerns about the use of data and risks to the integrity of the Official Statistics System, the original source data collections, and/or other government activities.

Principle 1 Rationale for this data matching:

  1. This data integration will explore if there are statistically robust relationships, such as patterns of change or likely impacts between agricultural land use and freshwater quality changes in New Zealand.
  2. These data integration outputs are likely to be of interest to most New Zealanders – in particular, government agencies, local authorities, Māori, farmers, farmer organisations, media, politicians, and environment advocacy organisations. They will have better information on which to base decisions relating to fresh water. Water quality monitoring agencies and policy makers will also be able to make more informed decisions on water quality policy and practices. Interest may extend beyond New Zealand and have an impact on this country’s export and tourism sectors.
  3. New Zealand, without environmental reporting legislation, lags behind a number of countries in its environmental reporting. Proposed legislation that is expected to be passed into law by the end of 2015 will pave the way for New Zealand to be in a leading position internationally.

These data integration outputs will inform the ‘soon-to-be’ legislative requirement to publish data about the pressures, state, and impacts on New Zealand’s environment. There is a risk to privacy, but legislative protection (eg the Statistics Act 1975) and secure practices (eg locked databases and secure Data Lab conditions) are being used to mitigate accidental or deliberate breaches.

Principle 2: Integrated data will only be used for statistical or research purposes.

Principle 2 Rationale for this data matching:

  1. Outputs will provide information on agricultural land use and freshwater quality in New Zealand by showing the changes over time in these two important aspects of New Zealand’s economy and well-being.
  2.  The information will add to New Zealanders’ knowledge of the pressures, state, and impacts on New Zealand’s environment and empower informed decision-making around agricultural land use and freshwater quality.
  3. Results will be published at regional and national level, providing they meet Statistics NZ’s strict confidentiality provisions (to protect the identity and location of farms) and that the outputs meet Statistics NZ’s rigid quality assurance and data integrity standards. Publication is at the sole discretion of Statistics NZ and this information will be published in the first Freshwater Domain Report due in 2016, or sooner if results are ready well ahead of the report.

Principle 3: Data integration will be conducted in an open and transparent manner.

Principle 3 Rationale for this data matching:

The process and procedures used for this data matching are set out in this PIA. The process is described as a three stage procedure.

  1. Researchers from the Ministry for the Environment (MfE) and the Ministry for Primary Industries (MPI) have been seconded to Statistics NZ to complete stage 1, at Statistics NZ. The researchers seconded to Statistics NZ work under the provisions of the Statistics Act 1975.
  2. MfE staff will undertake stage 2 (the modelling and mapping stage). These bona fide researchers will work under s37C of the Statistics Act 1975 (working in secure Data Lab conditions) to complete stage 2.
  3. NIWA personnel (also working under s37C of the Statistics Act 1975 and in secure Data Lab conditions at Statistics House, Christchurch, New Zealand) will complete the research and analysis for stage 3.
  4. Stages 1–3 are jointly project managed by the Manager, Evidence Reporting, Water Directorate, MfE and the Manager, Customer Policy and Research, Statistics NZ.
  5. Publication of results will be at the discretion of Statistics NZ and based solely on the statistical integrity (including confidentiality) of the outputs.
  6. Confidentiality assurance will be provided by Statistics NZ. Published outputs will be in the form of aggregated statistics and any tabulated cells that contain small numbers (for example at some regional levels) will be confidentialised using standard methods.
  7. All datasets produced during stages 1–3 will be held securely at Statistics NZ and be used solely for the purpose of producing new insights into agricultural land use and freshwater quality changes in New Zealand.
  8. The use of the aggregated data for purposes not already defined in this PIA will require a new PIA to be completed.
  9. Two researchers from Landcare Research, contracted to MfE, will undertake and document an independent review of the process and methodology used to produce the outputs from this data matching. They will be seconded to Statistics NZ, during stage 1, working under the provisions of the Statistics Act 1975, and as researchers under s37 of the Statistics Act 1975 during stages 2 and 3.

Principle 4: Data will not be integrated when an explicit commitment has been made to respondents that prevents such action.

Principle 4 Rationale for this data matching: 1.

  1. The commitments made to respondents and data providers for all databases that contribute to this data matching are listed later in this paper. It should be noted that from the completion of stage 1 of this data matching, personal information is removed. Prior to publication, confidentiality provisions are applied and farm location identifiers removed so that the information consists of summary statistics used only for statistical purposes.
  2. Additionally, the Agricultural production survey (APS) is a joint collection by Statistics NZ and the Ministry for Primary Industries (MPI) under section 9 of the Statistics Act 1975. As such, individual information may be released to MPI, however, respondents may object (in writing to the Government Statistician) to the release of their information to that department. Data released to MPI continues to be protected by the Statistics Act 1975 s37, in that it must only be used for statistical purposes and must not be released in any way which identifies individual information.
  3. Statistics NZ’s Data integration policy is based on the United Nations Economic Commission for Europe's Principles and guidelines on confidentiality aspects of data integration undertaken for statistical or related research purposes (2009).
  4. Results of this data integration will be released in accordance with the policy for the release of official statistics – Principles and Protocols for Producers of Tier 1 Statistics – that underlie the release of all official statistics.
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