ComVoices paper highlights issues with govt requiring individual client level data

Thu 24 Nov 2016

ComVoices has published an issues paper on the Ministry for Social Development (MSD) requiring community organisations to provide Individual ...

ComVoices has published an issues paper on the Ministry for Social Development (MSD) requiring community organisations to provide Individual Client Level Data (ICLD).

ComVoices says "This Issues Paper has been developed to summarise the key issues for the community sector as the basis for engagement with MSD and, potentially, other government agencies.  We are aiming to reach an agreed data collection system that meets MSD’s needs for information, is ethically appropriate for the service users, complies with Privacy Act considerations and is practical, transparent and mitigates risk exposure for MSD and service providers."

The issues outlined in the paper relate to:

  • The rationale for collecting individual data
  • MSD’s protocols for collecting and holding personal information
  • Compliance and infrastructure
  • Privacy considerations
  • Liability if privacy is breached
  • Lack of consultation
  • Potential for rationing of services

The paper states, "Whilst the community sector understands the benefits of collecting individual client data in some situations, it does not believe it is appropriate or necessary to obtain this level of detail in all situations. In fact, it could be highly detrimental in situations where organisations are providing confidential services to people who are disclosing sensitive information about their personal circumstances, such as a risk of abuse, domestic violence, self-harm or suicide. ICLD requirements impact on organisations who are providing highly effective virtual, text or phone based services. These organisations provide an essential component of both crisis based and preventative services, especially for young people. Care must be taken to address these issues prior to implementing any contractual requirements."

The background information explains:

"Over the past few years the Government has actively increased the amount of data it collects in order to inform its social investment approach. The data has mainly been mined from the information stored by government agencies, but those government agencies are now requiring the community sector organisations they contract with to collect data from their clients on the government’s behalf.

This year the Ministry of Social Development (MSD) has begun incorporating clauses requiring the collection of individual client data into its contracts with providers. If a client does not give permission for their data to be collected and passed on to MSD, then the provider will not be funded to provide a service to that person. MSD has also announced that, as from next year, the data it collects will not be aggregated or anonymised and it will be possible to identify and target individuals. MSD has also advised that this contract requirement will apply to all providers from 1 July 2017."

ComVoices provides further information: "This Issues Paper was provided to MSD on 11 November. MSD has responded positively to the invitation to engage on the issues set out here and a joint working group is now being set up between MSD, the ComVoices group that drafted this paper, and the NGO Advisory Group that has also been in discussion with MSD on this subject."

ComVoices is a network of national organisations in the tangata whenua, community and voluntary sector. 


In March 2017, ComVoices published a second issues paper - see Concerns and public meeting on NGOs and provision of individual client level data for details.

Related information

The Green Party has started a petition asking the Government to stop making community groups hand over clients' information. Jan Logie MP highlighted concerns with the requirement in terms of client confidentiality, trust and safety.

An article on The Wireless discusses uses of data, Weapons of math destruction? The problem with algorithms (24 November 2016)

A blog discusses Control, surveillance and "professional agency hopping" (26 October 2016)

Previous media coverage and opinions on the requirement are listed in the previous NZFVC News Story, MSD to require individual client level data from community agencies (October 2016)

Image: Pixabay