Updated Privacy Policy and Google Data Disclosure

1. Purpose and Scope of Policy

In the highly regulated landscape of immigration advisory services, maintaining transparency and fulfilling professional obligations are the cornerstones of operational integrity. This policy is established within the strategic context of the Immigration Advisers Licensing Act 2007 and the Privacy Act 2020, ensuring that the handling of personal information meets the highest regulatory standards. As a licensed entity, the firm recognizes that clear communication regarding data practices is essential to building client trust and mitigating the professional risks associated with information management.

The primary objective of this document is to provide a clear and comprehensive disclosure of how Google user data is accessed, utilized, and protected in the context of immigration advisory services. By integrating these services, the firm streamlines the complex data requirements inherent in visa applications while ensuring full compliance with the Licensed Immigration Advisers Code of Conduct 2014. This policy affirms our commitment to the professional and ethical conduct mandated by the Registrar of Immigration Advisers.

2. Google User Data: Access and Integration

To facilitate efficient immigration application workflows, the integration of Google services is a strategic necessity. Modern immigration processes require the management of vast amounts of personal and biographical data; leveraging Google’s ecosystem allows for a seamless transition of information from client-provided sources to formal representation.

The application accesses specific Google user data required to support the provision of immigration services. In accordance with our actual data collection practices, this includes:

• Name
• Contact information
• Location
• Billing or purchase information

Access to this data is necessary to minimize manual data entry errors and enhance the accuracy of submissions to government bodies. By automating the population of complex forms, the firm ensures that the data submitted is consistent with the records provided by the client, thereby directly preventing the risk of misrepresentation—a critical professional violation under Clauses 29–32 of the Code of Conduct. This accessed data is mapped directly to specific fields within official forms for Immigration New Zealand (INZ) and Immigration and Citizenship Australia (ICA) and is stored in accordance with Clause 26 of the Code.

3. Functional Application of Google User Data

In the immigration sector, data utilization serves as a critical “useable trail” of actions. Effective risk management requires that every piece of information—including that derived from Google services—contributes to a transparent and chronological record of the services provided. This operational rigor ensures that the firm can defend its advice and actions should they be questioned by regulatory authorities.

The application utilizes Google user data to support the following functions:

• Application Pre-population: Automatically filling immigration forms, appeals, and requests with accurate user profile data to ensure technical precision and consistency.
• Document Management: Organizing digital copies of personal documents, such as birth certificates and educational qualifications, within a secure electronic filing system.
• Communications Tracking: Maintaining copies of all written and electronic communications to fulfill the requirement for a complete record of material discussions and advice.

These functional applications are designed to provide quality advice at reasonable prices, utilizing technology to reduce administrative overhead while maintaining the high standards of the IAA Code of Conduct 2014. Once processed, this information is governed by strict protocols to ensure it remains within authorized environments.

4. Disclosure and Data Sharing Protocols

The strategic management of client trust requires a “limited disclosure” model. While the firm must share information with government authorities to fulfill its service obligations, it maintains a strict boundary against unauthorized third-party access.

Personal information and Google-derived data are used internally and shared only with the following appropriate immigration authorities:

• Immigration New Zealand (INZ)
• Immigration and Citizenship Australia (ICA)

The “So What?” Layer: The company does not sell or disclose personal information to unauthorized third parties. This strict limitation serves the client’s interests by protecting sensitive legal and personal information during a high-stakes legal process. By restricting data flow to these specific entities, the firm ensures that information is utilized exclusively for its intended purpose: the support of official visa applications and statutory submissions.

5. Sensitive Data Protection Mechanisms

Data security is a primary strategic priority, reflecting the “document security” requirements outlined in the IAA Code of Conduct Toolkit. Protecting the integrity of client information is a regulatory mandate that covers the entire lifecycle of the data.

The firm employs several protection mechanisms:

• File Transition: Electronic data derived from Google services is archived into a “unique client file” as required by Clause 26. These well-managed files are maintained in hard copy, secure electronic storage, or both.
• Secure Handling of Personal Documents: Specific protocols govern the handling of sensitive documents such as passports and birth certificates. These are processed and stored in a “secure manner” to prevent unauthorized access or loss.
• Verified Return: Evidence of the safe return of original documents is mandatory, utilizing track-and-trace courier confirmations or signed receipts to maintain a complete audit trail.

These safeguards ensure that the “useable trail” of client data remains protected from the point of initial collection through to the eventual conclusion of the immigration matter.

6. Data Retention, Deletion, and Access Rights

The firm balances the principle of data minimization with the legal requirement for long-term record keeping. In the immigration sector, records must be preserved to satisfy both professional standards and statutory obligations.

Pursuant to the IAA Code of Conduct 2014, the retention policy is as follows:

• Retention Period: All client files, including data derived from Google services, are maintained for no less than 7 years from the date the file is closed.
• Compliance Rationale: This duration ensures the firm meets the inspection requirements of the Immigration Advisers Authority (IAA) and the financial record-keeping mandates of the Inland Revenue Department (IRD).

After the 7-year threshold, data is securely deleted or archived according to internal disposal protocols. Clients maintain the right to access and correct their personal information at any time. Requests for copies of information or corrections should be directed to the firm through the following channels:

Just Immigration Consulting Limited

• Physical Address: Level 8, 139 Quay Street, Auckland, New Zealand
• Email: info@jicl.co.nz
• Phone: +64 21 0224 8196

Note: This policy is subject to periodic updates to reflect changes in New Zealand or Australian immigration instructions or privacy legislation.