Purpose & data minimization
Scope the business purpose first, then assess what data can be reduced, de-identified or simply not collected.
Sources & accuracy
Key answers keep their sources, versions and test evidence wherever possible; when evidence is thin, design refusal or hand-off paths.
Human review & accountability
For high-impact decisions, name an accountable approver and keep the responsibility boundary in the design.
Permissions & isolation
Assess isolation by role, client and task — with least privilege as the design target.
Logs, exceptions & rollback
Keep the operating evidence the risk and contract require; design exception handling, human fallback and rollback paths.
Ongoing review
Re-assess when models, knowledge, vendors or purpose change; one acceptance test is never a permanent guarantee.
Make the important steps explainable and reviewable
Within project scope, record the key input, processing, review and retention steps. Specific vendors, regions, retention periods and training usage must be confirmed per project and contract.
Private or managed? How do you choose by data, control and operational responsibility?
Customer / controlled cloud
Run in a cloud and region the client approves, with identity, logging, keys and vendor responsibility made explicit.
On-premise or offline
Use the word “offline” only when models, hardware, updates, operations and feature limits are all explicit.
Managed service
Make data flow, sub-processors, retention, exit and service responsibility explicit; convenience never replaces scrutiny.
Why do New Zealand businesses need a continuously updated Privacy Impact Assessment?
A Privacy Impact Assessment (PIA) is a structured review of how a system collects, uses and retains personal information. New Zealand’s Privacy Act 2020 took effect on 1 December 2020 and sets out 13 information privacy principles. The Privacy Commissioner recommends conducting — and continuously updating — a PIA before using AI on personal information. When the process, fields, vendors or purpose change, so should the assessment.