Privacy & Biometric
Information Policy

Why we do this

1. We do this to meet our obligations under the Gambling Act 2003, not on the basis of consent.
2. Cameras operate only in the gaming room and, at some venues, at the ATM — so if you do not enter the gaming room, nothing is collected about you.
3. If you are subject to an exclusion order, staff will act on it when the system identifies you. Exclusion orders are made under the Gambling Act 2003 and venues are required to enforce them.

What the system does

Gaming rooms operated under the Gambling Act 2003 must take active steps to prevent gambling harm and to enforce exclusion orders. EZYSWEEP™ helps venue staff do that. It is used for three things:

1. Exclusions — checking whether someone entering the gaming room is subject to an exclusion order, and alerting staff so the order can be enforced.
2. Player monitoring — recognising the same person across the regular checks gambling law requires venues to carry out, so staff can see how long someone has been playing and watch for signs of harm.
3. Harm-minimisation records — creating the records gambling law requires when staff identify signs of harm or have a conversation with a player. These records include a photograph.

Where the cameras are

1. At the gaming room entrance, inside the gaming room, and at its exit.
2. At some venues, at the ATM — which by law is located outside the gaming room.
3. The Department of Internal Affairs, which regulates gambling and may inspect those records.
4. Where an exclusion is involved, the national exclusion system operated for Health New Zealand.

We do not sell this information, use it for advertising, or share it for any purpose unrelated to gambling harm minimisation.

What is collected

1. A cropped image of your face.
2. A face template — a mathematical representation of your face, which is what lets the system recognise it again. It is a string of numbers and cannot be turned back into a photograph of you.
3. The system does not use fingerprints, iris scans, voice, or the way you walk.
4. It does not attempt to judge your age, ethnicity, gender, mood, or health, and it is not permitted to.

How long it is kept

What	How long | Then
Your photograph, where no record is made about you	72 hours, then permanently deleted
Your face template, where no record is made about you	28 days, then permanently deleted
Photograph and template, where staff record an interaction with you	3 years, permanently deleted. Gambling law sets this period.
Information about people subject to exclusion orders	Until the order expires, then permanently deleted

Deletion is permanent. There is no archive or recycle stage the information can be recovered from.

Who can see it

1. Trained venue staff, who see an alert and a photograph so they can confirm whether the system is right.
2. The gaming society that runs the venue, which is legally responsible for the harm-minimisation records.
3. The Department of Internal Affairs, which regulates gambling and may inspect those records.
4. Where an exclusion is involved, the national exclusion system operated for Health New Zealand.

We do not sell this information, use it for advertising, or share it for any purpose unrelated to gambling harm minimisation.

Is it sent overseas?

Some of the processing takes place outside New Zealand, using service providers that act only on our instructions and are not permitted to use the information for their own purposes. They are contractually required to protect it to the standards New Zealand law requires.

Does it always get it right?

No. Facial recognition is not perfect, and accuracy can vary between people. We take that seriously, and we have built the system so that a mistake by the software does not become a mistake by the venue:

1. The system only raises an alert at a high confidence level.
2. Every possible exclusion match is checked a second time by the software before staff see it.
3. A staff member must confirm identity before anything happens. The system never acts on its own.

If you think the system has got it wrong — ask to speak to the venue manager at the time, and contact us using the details below. You can ask us to correct information we hold about you, and if we do not agree to change it you can ask us to attach a statement noting that you disagree.

Your rights

What happens if something goes wrong.

1. Ask us to confirm whether we hold biometric information about you, and what type it is.
2. Ask for access to it.
3. Ask us to correct it — which includes asking us to delete it.
4. If we do not make a correction you have asked for, you can give us a statement saying you asked. We will attach it to the information so it is always read alongside, and tell anyone we have disclosed the information to.

Timing and cost

1. We will respond within 20 working days.
2. If a request is complex or covers a large amount of information and we need longer, we will tell you within that time and give you a new date.
3. Requests are generally free, though we may charge reasonable costs for providing copies or making corrections. If so, we will tell you before we do any work.

More information you can ask for

1. A summary of the assessment we carried out on whether this use of facial recognition is necessary and proportionate, including its impact on Māori.
2. Our full Privacy and Biometric Information Policy.
3. This statement in another format.

Contact us

1. Privacy Officer - Go Gaming Limited, 1066G Great South Road, Mount Wellington, Auckland 1060
2. Email - privacy@gogaming.nz
3. Full policy - Available on request from the Privacy Officer

If you are not satisfied with how we handle your enquiry or complaint, you can complain to the Office of the Privacy Commissioner at privacy.org.nz.