Surveillance policy

Scope

Ryman Healthcare (‘Ryman’, ‘we’, ‘us’) uses Closed Circuit Television (CCTV) and other surveillance devices to support the safety, security, and wellbeing of residents, employees, contractors, visitors, and property. This policy explains how surveillance is used, how footage is managed, and the rights of individuals.

This policy complies with all current New Zealand laws and appliable regulations.

In this policy, CCTV refers to camera surveillance devices that capture images of people and activity, and includes other surveillance devices of the same or similar nature. CCTV operates 24 hours a day, seven days a week. Footage of events and the movements of people will be captured. Ryman does not use any facial recognition technology or other ‘intelligent surveillance’ technology, or audio recording unless explicitly stated and absolutely necessary.

Surveillance by Ryman

CCTV is operated by Ryman and used throughout Ryman’s premises, including villages and construction sites to:

• Help ensure the safety and security of our residents, employees, contractors, visitors and property
• Detect and deter criminal behaviour
• Investigate and manage complaints, misconduct and challenging behaviour
• Support emergency or incident response; and
• Meet our obligations under applicable legislation and regulations.

Any footage collected will be used solely for these purposes or as required or permitted by law.

Footage that sufficiently identifies individuals which is collected via CCTV is considered personal information and is therefore subject to the Privacy Act 2020 (the Privacy Act) and governed by Ryman’s Privacy Policy (available here).

CCTV cameras are located throughout Ryman premises, including villages and construction sites, but are not installed in bathrooms or other personal areas, including resident’s rooms. In areas where CCTV footage is being collected, Ryman will ensure that we display clear, visible signage that such areas are being monitored by CCTV.

Footage will not be linked to or accessible via any person’s file or records, except as set out below.

Footage collected via CCTV will be kept securely for up to 90 days. Stored footage can only be accessed by authorised Ryman managers and employees. It will only be reviewed if required to investigate an incident or complaint, if a security problem is identified, to review construction work that has taken place or as otherwise required or permitted by law. It will only be retained for longer than 90 days if needed for evidential purposes and, with the approval of the Privacy Officer, may be stored in the investigation file. Once footage is no longer required, Ryman will ensure it is securely deleted.

Covert surveillance devices may be used in exceptional circumstances where all other reasonable options have been exhausted and management has strong grounds to suspect that theft or misconduct is occurring. In these circumstances a surveillance device may be installed and used without the knowledge of employees. Approval from a General Manager Operations is required before a covert surveillance device may be installed. Consent will always be obtained from residents (or their families where there is an activated enduring power of attorney) before covert surveillance devices are used in residents’ rooms.

If any criminal behaviour is recorded via CCTV, the footage may be provided to the Police.

Surveillance by third parties

Surveillance devices (either visual or audio) installed and operated by a third party without Ryman’s knowledge and consent are prohibited in Ryman villages and on Ryman construction sites in any areas where the devices may:

• Record Ryman employees without their knowledge or consent
• Record residents (or anyone else) without their knowledge or consent in such a way that is intrusive or breaches their privacy.

Ryman has the right to immediately disconnect any such devices, and ask that they be removed effective immediately.

Who to contact

If you have any questions or complaints about the use of CCTV or other surveillance devices within Ryman’s sites, please contact Ryman’s Privacy Officer and we will respond as soon as possible to resolve the issue. We also welcome any questions and comments you may have about our privacy practices.

You can contact us at:

Privacy Officer
Ryman Healthcare
PO Box 771
Christchurch 8140
privacy@rymanhealthcare.com
0800 588 222

If you are not satisfied with our response you can contact the Office of the Privacy Commissioner.

Ryman may revise or update this Privacy Policy from time to time. Any changes will apply from the date Ryman posts the updated Policy on its website. This Policy was last updated in April 2026.