Privacy Policy & Incident Response Plan
Privacy Policy & Incident Response Plan

Privacy Policy & Incident Response Plan

Welcome to YJ Consulting.
We value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, Notion or download our app (coming soon).
Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. You can find an overview here.

Privacy Policy

For a simplified overview, visit
Privacy Policy | Overview
Privacy Policy | Overview
This Privacy Policy has been reconciled against our canonical site policy and aligned to the Independent privacy evaluation checklist. It maps concrete policy statements and processes to the Trust Framework Rules (Rule 12) and relevant Privacy Act 2020 obligations.

1. Information We Collect

1.1 Personal Information

We may collect the following personal information:
  • Name
  • Email address
  • Phone number
  • Shipping address
  • Billing address
  • Payment information (e.g., credit card details)

1.2 Non-Personal Information

We may also collect non-personal information about you, including:
  • Browser type
  • Device type
  • IP address
  • Browsing behaviour (e.g., pages viewed, links clicked)
Contact YJ Consulting if you have any questions about this Privacy Policy.
Access our Terms and Conditions here:
Terms & Conditions
Terms & Conditions

5. Responsible person for privacy

(Rule 12(5))
  • Role: Privacy Lead responsible for privacy governance and incident coordination

6. Privacy training

(Rule 12(6))
  • Training is mandatory for employees and contractors with access to our clients’ personal information
  • Training content includes lawful purpose and use, access and correction handling, storage and disclosure standards, and complaint/incident handling and reporting to the privacy contact
  • Training is role-based and refreshed annually, with earlier refreshers after material policy or process changes

7. Privacy statement

(Rules 12(1) and 12(11))
  • Tracker scope: Google Analytics only
  • Cookie notice: Uses Notion’s default cookie banner and controls on Notion-hosted pages, as well as Wordpress cookies and controls on Our website
  • Public privacy statement is this page
  • A concise website notice links users here and to cookie controls

8. Privacy Policy provided to personnel

(Rules 12(6)-(7))
  • An internal Privacy Policy is issued to all personnel and made available in the company handbook and knowledge base
  • Change notification: personnel are notified of policy updates and must acknowledge material changes
  • Policy covers: lawful purposes and uses, access and correction requests, storage and disclosure, and privacy complaints and incidents procedures

9. Privacy Incident Response Plan

(Rules 12(8)-(9); Reg 20; Privacy Act 2020 Part 6)
Owner: Privacy Lead () • Contact: privacy@consultyj.com • Alternate: info@consultyj.com
Scope: All YJ Consulting operations, systems, people, suppliers, and client engagements.
Objective: Rapid containment, accurate assessment, lawful notification, and measurable learning.

9.1 Definitions and scope

  • Privacy incident: Any event that compromises, is suspected to compromise, or risks compromising personal information confidentiality, integrity, or availability.
  • Notifiable privacy breach: Likely to cause serious harm to affected individuals per Privacy Act 2020. Requires notification to OPC and affected individuals.
  • Systems covered: Website, email, productivity suites, storage, CRM/knowledge bases, client data rooms, and supplier-managed services used by YJ Consulting.

9.2 Roles and responsibilities

  • Privacy Lead (Incident Manager): Coordinates end-to-end response, decision maker on notifiability, approves notifications, owns regulator liaison.
  • Technical Lead: Performs containment and forensics support, preserves evidence, coordinates with suppliers.
  • Account/Engagement Lead: Client communications, scope and data mapping, contractual impact check.
  • Communications Lead: Drafts internal and external notices using approved templates.
  • All personnel: Immediately report incidents, preserve evidence, do not delete or disclose externally without authorisation.

9.3 Severity and notifiability matrix

  • S0 Near miss: No personal data exposure. Track and fix.
  • S1 Low: Limited personal data, promptly contained, unlikely serious harm. Internal notice only.
  • S2 Medium: Personal data exposed to limited unauthorised party, harm uncertain. Triage for notifiability within 48 hours.
  • S3 High (Notifiable likely): Sensitive data or broad exposure, indicators of serious harm. Notify OPC and individuals as required.
Determinants of serious harm (consider together):
  • Data sensitivity and volume
  • Security controls in place (e.g., encryption at rest/in transit)
  • Who accessed/received the data and likelihood of misuse
  • Whether the data is recoverable or has been published
  • Potential harm types: financial loss, identity risk, physical safety, discrimination, distress

9.4 6-Step incident workflow (target clock starts at detection)

1) Detect and report (T+0–1h)
  • Capture initial facts using the Triage Form.
2) Contain and preserve (T+0–4h)
  • Isolate affected accounts, revoke tokens/API keys, rotate credentials, disable sharing links.
  • Quarantine malicious artifacts, block indicators of compromise.
  • Preserve evidence: export system logs, email headers, access logs, timestamped screenshots. Do not alter source data.
3) Assess impact and notifiability (T+4–24h)
  • Map data subjects, categories of personal information, jurisdictions, and contractual duties.
  • Apply severity matrix and serious harm test. Document rationale.
  • Decide if notifiable under Privacy Act 2020. If uncertain, treat as likely and escalate.
4) Remediate and eradicate (T+24–48h)
  • Remove malware, close vulnerabilities, correct misconfigurations, revoke persistence.
  • Coordinate with suppliers for corrective actions and assurances.
5) Notify (if notifiable) (as soon as practicable; without undue delay)
  • OPC notification: submit via OPC online form with facts, harms, and mitigations.
  • Affected individuals: clear, plain-language notice and recommended protective steps.
  • Contracted clients/partners: per contract SLAs and regulatory requirements.
6) Learn and improve (within 10 business days)
  • Post-incident review (PIR) with actions, owners, and due dates.
  • Update policies, controls, and training. Track to closure.

9.5 Communication and notification artefacts

  • Triage Form fields: reporter, timestamp, system, description, indicators, data types, estimated records, attachments.
  • Decision log: notifiability rationale, alternatives considered, approvals.
  • Notification templates:
    • OPC template: summary, incident timeline, data categories, affected counts, containment, harm assessment, mitigations, contact.
    • Individual notice: what happened, what information, risks, what we’ve done, what you can do, contact and complaints pathway.
    • Client notice: contractual reference, impact to engagement, next steps, points of contact.

9.6 Evidence handling and forensics

  • Chain of custody: unique evidence IDs, hash values (where feasible), custodian, timestamps.
  • Store evidence in a restricted incident folder with least-privilege access.
  • Avoid production system changes until evidence captured unless immediate safety requires.

9.7 Supplier and subcontractor management

  • Require suppliers to notify YJ Consulting of incidents affecting our data within 24 hours.
  • Maintain a contact roster and escalation paths for key suppliers.
  • Obtain written incident summaries and corrective action attestations post-event.

9.8 Data subject rights during incidents

  • Continue to honour access, correction, and deletion requests where safe and lawful.
  • If fulfilment would aggravate risk, record justification and defer with explanation to the requester.

9.9 Recordkeeping and metrics

  • Record every incident and near miss in the Privacy Incident Register with severity, root cause, and actions.
  • Metrics reviewed quarterly: time-to-detect, time-to-contain, time-to-notify, recurrence by cause, training coverage.

9.10 Training and exercises

  • Onboarding and annual refresher training covering this plan and reporting duties.
  • Tabletop exercise at least annually with one supplier-involved scenario.

9.11 Quick-reference playbooks

Email misdirect
  • Immediate: recall if available, contact unintended recipient requesting deletion and non-use, disable link access.
  • Assess data sensitivity and likelihood of further disclosure. Consider notifiability.
Lost or stolen device
  • Immediate: remote lock/wipe, revoke tokens, rotate passwords.
  • Verify encryption status and last backup. Assess exposed data and notifiability.
Cloud file oversharing (public link / wrong permissions)
  • Immediate: revoke public links, correct permissions, review access logs.
  • Determine exposure window and access events. Assess notifiability.
Credential compromise / phishing
  • Immediate: reset credentials, enforce MFA, block sender domain/URLs, run containment across related systems.
  • Review mail rules, OAuth grants, and API tokens.
Supplier breach
  • Immediate: obtain details and containment status, disable integrations if needed.
  • Assess contractual and regulatory notifications.

9.12 Retention

  • Incident records, evidence, and notifications retained for 7 years unless legal hold requires longer.

9.13 Governance

  • Plan owner: Privacy Lead. Review at least annually or after any notifiable breach.
  • Change control: updates recorded with version, date, approver, and summary of changes.

10. Privacy Incident Register

(Rules 12(9)-(10))
  • A register records all incidents and near misses
  • The register is reviewed regularly and drives policy and process improvements
Privacy Incident Register

11. Privacy Impact Assessment

(Rule 12(2)-(4))
  • A PIA is required for services in scope for accreditation and must be approved by the provider
  • The PIA describes the service, information held and collected, purposes, information flows, storage and disposal controls, identified risks, and mitigating controls
  • Review: at least every 2 years from last review, or earlier on service change
  • Codes of Practice: any relevant Codes are explicitly considered per Privacy Act s32

12. Information used to inform this alignment

  • Provider application responses and attachments
  • Internal policy documents and training materials
  • PIA and risk assessments
Last updated: 10 November 2025
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:
  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Crescellere Limited, 64 Bob Charles Drive.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: New Zealand
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
  • First name and last name
  • Email address
  • Phone number
  • Identification
  • Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
  • Google
  • Facebook
  • Instagram
  • Twitter
  • LinkedIn
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store information about our clients and visitors. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:
  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about the differences in our article,
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Confused about Cookies?
We use both Session and Persistent Cookies for the purposes set out below:
  • Necessary / Essential Cookies
      • Type: Session Cookies
      Administered by: Us
      Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies
      • Type: Persistent Cookies
      Administered by: Us
      Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies
      • Type: Persistent Cookies
      Administered by: Us
      Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:
  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:
  • By phone number: 02108368491
Reviewed by at Nov 10, 2025
 
Designed by Steffanie Zhang c/o YJ Consulting. Crescellere Ltd. © 2025.
 
 
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Privacy Incident Register
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Notification template — OPC (Notifiable privacy breach)
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Notification template — Individuals
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Notification template — Clients/Partners