Draft for Hayden to complete. This is a starting point written from what the PadClock app actually does. It is not legal advice. Everything highlighted needs filling in or checking, and the whole policy should be reviewed against the Privacy Act 2020 before it's published.

Privacy policy

Last updated [date]

Who we are

PadClock is run by [company legal name], a New Zealand company (NZBN [number]), at [address]. When this policy says “we”, it means us. You can contact our privacy officer at [privacy email].

PadClock is used by businesses (our customers) to record their employees' hours. For employee time records, the business that employs you decides what is recorded and why. We hold that information on the business's behalf.

What we collect

How we use it

To run the service: record hours, work out unpaid breaks, show the dashboard, send timesheets to the business's Xero Payroll account when an admin pushes them, send the emails a business has turned on (such as trial reminders and the daily open-shift email), and bill the subscription. We don't sell personal information and we don't use it for advertising.

Who we share it with

Some of these providers store data outside New Zealand. [Describe the safeguards relied on under IPP 12.]

How long we keep it

We keep a business's records while its account exists, including after a subscription ends, so the business can still download them. When the owner deletes the account as its only member, the organisation and its data are deleted. [Confirm backup retention period.]

Security

Access is limited to signed-in admins of each organisation. Kiosk tablets use a device token rather than an admin login, and leaving the kiosk needs the admin PIN. [Add encryption, access-control and breach-notification details.]

Your rights

Under the Privacy Act 2020 you can ask to see the personal information we hold about you and ask us to correct it. If you're an employee, it's usually quickest to ask your employer, who can see and correct your time records. You can also contact us at [privacy email]. If you're not happy with our response, you can complain to the Office of the Privacy Commissioner.

Changes

If we change this policy we'll update the date above, and tell account owners by email about anything significant.