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The Guardian and Concern Privacy Statement

The Guardian – Facial Recognition System for Identifying Excluded Players
Concern – National Problem Gambling Database


‘Concern’ is a national problem gambling database, the entire database is secure and encrypted.

Personal information collected from you must include the following;

  • Name

  • Date of Birth

  • Photo/s

  • The expiry date or duration of the exclusion order

We may also collect personal information from third parties authorised by you, or where a third party can provide information by law.

Where you do not provide us with all the information requested or the information provided to us is incorrect, we will be unable to provide services to you.

Your personal information is used to help venue staff identify you as an excluded person, entering their gaming area.

Each photo you provide is encrypted and assigned a unique identification number. A person can have multiple photos assigned. The unique identification number is recorded in the Concern Database only and will not be used for any other purpose other than the enforcement of the exclusion request.

Your contact details may be recorded, such as address, phone or email, so you can be contacted in regard to your exclusion/s.

The Guardian facial recognition cameras installed within Class 4 gaming venues extract faces from live video stream. These faces are checked against images stored in the Concern Database. These images are automatically deleted within 24 hours.

Besides our staff, we share this information with:

  • The relevant Class 4 venues and Societies which are required to keep records of persons they issue with exclusion orders as per the Gambling Act 2003.• Authorised problem gambling treatment providers

  • Any other authority as determined by regulation from time to time

We keep your information for the exclusion period at which point we automatically destroy it.

Anonymised data may be collated for reporting purposes.

We reserve the right to modify or amend this statement at any time. All changes will be uploaded to our website (www.coms.net.nz) and will be marked with an effective date. Any information collected prior to the change in statement will be treated in accordance with the previous statement. Any information collected after the effective date of the statement will signify acceptance of the updated statement.

You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong. If you’d like to ask for a copy of your information, or to have it corrected, please contact us at info@coms.net.nz, or 0800 266797. Within 20 working days of that request we will notify you of our decision. There may be circumstances where that timeframe is extended, and we will notify you of that.

Access may be refused or all or part of your information requested may be withheld in limited circumstances provided for under the Privacy Act 2020.

More information on privacy can be found on the Office of the Privacy Commissioners website https://www.privacy.org.nz

Updated December 2020.