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BTIT Personnel Vetting Policy

1. Purpose

The purpose of this policy is to outline BTIT’s personnel vetting process, ensuring that appropriate background checks are conducted to mitigate risks based on the role's sensitivity and data access. This policy provides a guideline for vetting employees and contractors prior to engagement in activities involving sensitive information, government systems, financial data, or vulnerable communities.

2. Applicability

This policy applies to all employees, contractors, and third-party personnel who are engaged by BTIT to provide services.

3. Risk Categories

Each role within BTIT is assigned a risk category based on the nature of the data or systems the individual will access. The following matrix outlines the checks required for each risk category:

4. Vetting Process Matrix

Risk CategoryDescriptionChecks RequiredFrequency
Low Risk- General administrative roles with no direct access to sensitive information.- Identity Verification (Passport or NZ Driver's License)
- CVCheck
Once at onboarding
Medium Risk- Roles with access to non-sensitive customer data.
- IT roles with limited system access.
- Identity Verification (Passport or NZ Driver's License)
- CVCheck 
- MoJ Criminal History Check
Once at onboarding
Periodic review every 2 years
High Risk- Roles involving access to sensitive data (e.g., financial, health, legal data).
- IT administrators.
- Individuals working with vulnerable populations.
- Identity Verification 
- CVCheck
- Credit Check 
- MoJ Criminal History Check
Once at onboarding
Periodic review every 1 year
Critical Risk- Senior roles with significant access to sensitive government systems or classified data.
- Project roles for security-sensitive contracts.
- Financial controllers.
- Identity Verification
- CVCheck
- Credit Check
- MoJ Criminal History Check
- National Security Clearance (if applicable)
- New Zealand Police Vetting
Once at onboarding
Periodic review every 1 year
Special cases as required

5. Explanation of Checks

  • Identity Verification: Ensures the identity of the individual by verifying documents such as passports or New Zealand driver's licenses.
  • CVCheck: A background check service that verifies employment history, qualifications, and references.
  • MoJ Criminal History Check: A Ministry of Justice criminal history check is required for all medium-risk and higher roles, ensuring no past criminal offenses.
  • Credit Check: Assesses an individual’s financial stability and risk based on their credit history. Recommended for roles handling financial data or transactions.
  • New Zealand Police Vetting: Required for roles involving work with vulnerable individuals (e.g., schools, healthcare) or access to high-security data.
  • National Security Clearance: A clearance check for personnel working on classified or high-security government projects.

6. Review Process

BTIT will conduct periodic reviews of personnel records in alignment with the matrix frequency. Employees and contractors are required to report any changes in their circumstances that may affect their vetting status.

7. Exceptions

Any deviations from this policy require written approval from the Managing Director or a designated senior manager.

8. Policy Ownership and Review

This policy will be reviewed annually or as required to ensure its effectiveness and alignment with legal requirements and business needs.