Check overseas disclosure against IPP 12 before a tool processes client data
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Extract the vendor's stated storage locations and subprocessors from the contract.
- What the lawyer must review
- Check IPP 12 for any disclosure outside New Zealand, including AI prompts
- Do not apply APP 8 or an EU adequacy finding as the test
- Keep personal data out if the destination is unclear
- Written for / version
- New Zealand versionNZCth
Rules that apply
The document starts from the task name. Change it if this piece of work is different.
Who does what
| Role | What they do |
|---|---|
| Assistance | Potential support includes extracting and organising information. Confirm the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Confirm that the actual tool, feature and processing terms permit use of this information, including access, retention, training and disclosure conditions.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.