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Data sources11 November 2024·DEIS Compliance

NZBN lookups: privacy obligations when searching the business number register

The NZBN register contains personal information about sole traders and partners. Here is what you need to know.

NZBNsole traderpartnerships

The New Zealand Business Number (NZBN) register is a central directory of all NZ businesses. While company information is relatively straightforward, the register also contains personal information about sole traders and partners — including names, addresses, and contact details.

When does IPP3A apply?

If you search the NZBN register and the results include personal information about an individual (e.g., a sole trader's home address), you are collecting personal information from a third-party source. IPP3A applies.

For company searches that only return the company's registered details and director names (which are on the Companies Register), the publicly available exception may apply — but you should still document your reliance on it.

Sole traders and partnerships

Sole traders and partnerships present the highest privacy risk because the NZBN record often contains the individual's home address, personal phone number, and personal email address. This information is more sensitive than a company's registered office address.

DEIS integration

DEIS connects to the NZBN register and prompts users to select the appropriate IPP3A pathway. For sole trader and partnership lookups, the system flags the higher privacy sensitivity and recommends notification rather than relying on the publicly available exception.

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