16 December 2021

Clearview, OAIC and the Federal Police

The Office of the Australian Information Commissioner has, somewhat belatedly and with uncertain effect, issued a Determination under the Privacy Act 1988 (Cth) regarding use by the Australian Federal Police of Cleaview. 

The Determination states 

110. I find that the Respondent interfered with the privacy of individuals whose images it uploaded to the Facial Recognition Tool, by failing to take reasonable steps under APP 1.2 to implement practices, procedures and systems relating to its functions or activities that would ensure that it complied with Clause 12 of the Code. 

 Disquietingly but unsurprisingly the Determination states

116. While these appear to be constructive developments, on the evidence before me, I cannot be satisfied that steps the Respondent has taken to date will ensure that the breaches of clause 12 of the Code and APP 1.2 are not repeated or continued.

It notes

There is a disagreement between the OAIC and the Respondent about whether an interference with privacy has occurred, and this determination allows this question to be resolved. There is a public interest in making declarations setting out my reasons for finding that an interference with privacy has occurred and the appropriate response by the Respondent. 

Further it states 

According to a media article dated 21 January 2020, a spokesperson for the Respondent [ie the AFP] had advised at that time that it did not use the Facial Recognition Tool (see paragraph 13). The Respondent refused 3 FOI requests on 13 February 2020 on the basis that no information relating to the third party service provider had been identified, notwithstanding that the Facial Recognition Tool had been used by several Trial participants (see paragraph 15). There were limited records of how this novel technology was used. For example, the dates of registration for  Trial participants are unknown;  the Respondent did not have logs recording details of access and/ or use of the Facial Recognition Tool; and for many uploaded images, the Respondent had no record of the particular image that had been uploaded. 

Regrettably the OAIC is not using the Determination as an opportunity to encourage best practice in FOI responses.

The OAIC states 

96. I am not satisfied that during the Trial Period, the Respondent had appropriate systems in place to identify, track and accurately record its use of new investigative technologies to handle personal information. 

97. I consider that the Respondent should have instituted a more centralised approach to identifying and assessing new and emerging investigative techniques or technologies that handle personal information. This would have assisted the Respondent to identify new high privacy risk projects within its organisation and take a consistent approach to risk assessment. It would also have supported the Respondent’s compliance with APP 1.2 in future, by enabling it to explain why a new or changed way of handling personal information did not have the potential to be high privacy risk (noting that it is the responsibility of each agency to be able to demonstrate whether a new or changed way of handling personal information was a high privacy risk project). 

98. In addition, the Respondent’s policies should have specifically addressed the use of free trials and other freely available online search applications, for investigative purposes. The privacy risks of using such applications (such as those outlined in 69 to 73), were foreseeable given that search tools and applications are easily accessible on the internet, and noting the ACCCE’s commitment to exploring ‘new and innovative solutions’ to meet challenges posed by offenders evolving their operating methods to avoid detection. 

95 The policies should have explained how attendant privacy risks should be assessed to enable compliance with Clause 12 of the Code, and the controls and approval processes in place to support such privacy risk assessments.  ...

Privacy training 

99.Under the Respondent’s written policies that applied during the Trial Period, functional areas were responsible for ensuring that PIAs were undertaken for all high privacy risk projects. The policies clearly stated that personnel could contact the Privacy Officer for assistance in determining whether a PIA is required, and included their contact details. 

100. Notwithstanding this, none of the 10 members of the ACCCE who registered for trial accounts conducted a threshold assessment or a PIA (see paragraph 64). Given this omission, I have considered the steps the Respondent took to implement its written policies about privacy risk assessments, including through staff training and other communications about requirements under the Code. 

101. While I recognise that the Respondent’s written policies contained some information about requirements to undertake a PIA under clause 12 of the Code, the Respondent’s online training module:

  • did not include sufficient information to enable staff to identify whether a planned project may involve high privacy risk, such as factors indicating that a project may be high privacy risk, 

  • information about the process of conducting threshold assessments and PIAs, or relevant operational examples did not set out clear pathways and triggers for functional areas to consult with appropriate legal and technical experts, before engaging in new or changed personal information handling practices 

  • did not clearly identify who was responsible for undertaking threshold assessments and PIAs, and for keeping relevant records 

  • did not include information about the potential privacy risks of novel high privacy-impact technologies, or the risks to individuals of uploading personal information held by the agency to a third party service provider in the absence of a Commonwealth contract (as discussed in paragraph 71). 

102. The Respondent’s submissions also indicate that at least 3 of the Trial participants had not received privacy training in the 12 months leading up to the Trial Period. 

103. Based on the Respondent’s submissions and documentation provided, I cannot be satisfied that adequate training was provided to functional areas about how to undertake such an assessment, when to do so, and when to involve the Privacy Officer or other privacy experts. 

PIA 

104. In addition to being a discrete obligation under the Code, an example of the practices, procedures and systems that an APP entity should consider implementing to comply with APP 1.2, is a commitment to conducting a PIA for new projects in which personal information will be handled or when a change is proposed to information handling practices.  A PIA can assist in identifying the practices, procedures or systems that will be reasonable to ensure that new projects are compliant with the APPs. 

105. I have concluded at paragraph 76 above that the Respondent breached clause 12 of the Code by failing to undertake a PIA for a high privacy risk project. 

What additional steps were reasonable in the circumstances? 

106. The requirement in APP 1.2 is to take ‘reasonable steps’ to implement practices, procedures and systems to ensure compliance with the APPs and the Code. 

107. I have considered the seriousness of decisions that may flow from use of the Facial Recognition Tool (see paragraph 71), the fact that the personal information of victims (including children and other vulnerable individuals) was searched, and the likelihood that the Trial involved the handling of sensitive biometric information for identification purposes. I would expect the Respondent to take steps commensurate with this level of risk under APP 1.2, to ensure any privacy risks in using technologies like the Facial Recognition Tool are carefully identified, considered and mitigated against. In some circumstances, the privacy impacts of a high privacy risk project, may be so significant that the project should not proceed. 

108. I consider that having regard to these heightened risks and the deficiencies outlined above, the Respondent should have at least taken the following additional steps before the Trial Period:

  • The Respondent should have implemented a centralised system to identify, track and accurately record its use of new investigative technologies to handle personal information. 

  • The Respondent’s written policies should have specifically identified the privacy risks of using new technologies to handle personal information as part of its investigative functions (including on a trial basis and when a service is available free of charge) and included controls and approval processes to address these risks. 

  • The Respondent should have ensured that staff who were responsible for assessing privacy risk received appropriate privacy training on a regular basis, which covered at least the matters outlined at paragraph 101. 

  • The Respondent should have conducted a PIA in relation to the Trial. 

109. I have taken into account the relevant circumstances, including the Respondent’s role as a federal law enforcement agency, its use of the Facial Recognition Tool to search for victims, suspects and persons of interest for investigative purposes, the sensitive nature of the biometric information collected and used by the Facial Recognition Tool, and the time and costs of implementing appropriate policies, procedures, and training. Having regard to these circumstances, I am satisfied that the Respondent did not take steps as were reasonable in the circumstances to implement practices, procedures and systems relating to its functions or activities that would ensure that it complied with clause 12 of the Code, as required under APP 1.2. ... 

Remedies 

111. There are a range of regulatory options that I may take following an investigation commenced on my own initiative. In determining what form of regulatory action to take, I have considered the factors outlined in the OAIC’s Privacy Regulatory Action Policy103 and the OAIC’s Guide to Privacy Regulatory Action. 

112. I am satisfied that the following factors weigh in favour of making a determination that finds that the Respondent has engaged in conduct constituting an interference with the privacy of an individual and must not repeat or continue such conduct: The objects in s 2A of the Act include promoting the protection of the privacy of individuals, and promoting responsible and transparent handling of personal information by entities.

Specified steps  

113. Under s 52(1A)(b) I may declare that the Respondent must take specified steps within a specified period to ensure that an act or practice investigated under s 40(2) is not repeated or continued. 

114. I recognise that the Respondent is proactively working to build the maturity of its privacy governance framework and embed a culture of privacy compliance across the agency. I particularly acknowledge the Respondent’s commitment since the Trial Period, to reviewing and strengthening parts of its privacy governance framework. This includes reviewing and updating its privacy management plan (1 July 2021 to 1 July 2022), which identifies specific, measurable privacy goals and targets and sets out how the agency will meet its compliance obligations under APP 1.2. 

115. In addition, the Respondent submitted during the investigation that it:

  • had appointed a dedicated position within the ACCCE, who would be responsible for undertaking software evaluations of similar kinds of applications in future 

  • was undertaking a review of existing internal governance processes and documents to specifically address the use of free trials in the online environment 

  • had commissioned a broader review of the Respondent’s privacy governance with the assistance of an external legal services provider 

  • was reviewing its training module to ensure operational relevance to all staff by including sufficient context and explanation. 

116. While these appear to be constructive developments, on the evidence before me, I cannot be satisfied that steps the Respondent has taken to date will ensure that the breaches of clause 12 of the Code and APP 1.2 are not repeated or continued. 

117. The Respondent has not provided the OAIC with specific information about how any steps it has taken or is taking, will prevent similar breaches occurring again in the future, by addressing the deficiencies in paragraphs 95 to 105 above. For example, during this investigation, the OAIC was not provided with details of how the Respondent’s policies, decision making processes, and approval processes in relation to the use of new technologies have changed since January 2020.  In addition, while the OAIC’s preliminary view contained findings about additional steps that should have been taken to train staff about privacy impact assessments, the Respondent did not provide any updated information about changes to its training program. 

118. Without a more coordinated approach to identifying high privacy risk projects and improvements to staff privacy training, there is a risk of similar contraventions of the Privacy Act occurring in the future. This is particularly the case given the increasing accessibility and capabilities of facial recognition service providers and other new and emerging high privacy impact technologies that could support investigations. 

119. For these reasons, I consider that it is reasonable, proportionate and appropriate to make the declarations in paragraph 2(c) of this determination, under s 52(1A)(b) of the Privacy Act, requiring an independent review of the changes made to the Respondent’s relevant practices, procedures, systems (including training) since the Trial Period. The declarations will provide the OAIC with ongoing oversight of updates to the Respondent’s privacy governance framework. The independent review may also provide additional assurance to Australians that the deficiencies identified in this determination have been addressed. These specified steps will help the Respondent to prevent similar contraventions, and ensure any privacy risks in using high privacy impact technologies are carefully identified, considered and mitigated against.

In October the OAIC in a separate Determination addressed data collection by Clearview, with the OAIC subsequently commenting

Clearview AI, Inc. breached Australians’ privacy by scraping their biometric information from the web and disclosing it through a facial recognition tool. 

The determination follows a joint investigation by the Office of the Australian Information Commissioner (OAIC) and the UK’s Information Commissioner’s Office (ICO). 

Commissioner Falk found that Clearview AI breached the Australian Privacy Act 1988 by: collecting Australians’ sensitive information without consent collecting personal information by unfair means not taking reasonable steps to notify individuals of the collection of personal information not taking reasonable steps to ensure that personal information it disclosed was accurate, having regard to the purpose of disclosure not taking reasonable steps to implement practices, procedures and systems to ensure compliance with the Australian Privacy Principles. 

The determination orders Clearview AI to cease collecting facial images and biometric templates from individuals in Australia, and to destroy existing images and templates collected from Australia.  

Clearview AI’s facial recognition tool includes a database of more than three billion images taken from social media platforms and other publicly available websites. The tool allows users to upload a photo of an individual’s face and find other facial images of that person collected from the internet. It then links to where the photos appeared for identification purposes. 

The OAIC determination highlights the lack of transparency around Clearview AI’s collection practices, the monetisation of individuals’ data for a purpose entirely outside reasonable expectations, and the risk of adversity to people whose images are included in their database. 

“The covert collection of this kind of sensitive information is unreasonably intrusive and unfair,” Commissioner Falk said. 

“It carries significant risk of harm to individuals, including vulnerable groups such as children and victims of crime, whose images can be searched on Clearview AI’s database. 

“By its nature, this biometric identity information cannot be reissued or cancelled and may also be replicated and used for identity theft. Individuals featured in the database may also be at risk of misidentification. 

“These practices fall well short of Australians’ expectations for the protection of their personal information.” 

Commissioner Falk found the privacy impacts of Clearview AI’s biometric system were not necessary, legitimate and proportionate, having regard to any public interest benefits. “When Australians use social media or professional networking sites, they don’t expect their facial images to be collected without their consent by a commercial entity to create biometric templates for completely unrelated identification purposes,” she said. 

“The indiscriminate scraping of people’s facial images, only a fraction of whom would ever be connected with law enforcement investigations, may adversely impact the personal freedoms of all Australians who perceive themselves to be under surveillance.” 

Between October 2019 and March 2020, Clearview AI provided trials of the facial recognition tool to some Australian police forces which conducted searches using facial images of individuals located in Australia. ... 

Clearview AI argued that the information it handled was not personal information and that, as a company based in the US, it was not within the Privacy Act’s jurisdiction. Clearview also claimed it stopped offering its services to Australian law enforcement shortly after the OAIC’s investigation began. 

However, Commissioner Falk said she was satisfied Clearview AI was required to comply with Australian privacy law and that the information it handled was personal information covered by the Privacy Act.

SOCI 2 - Cyber Security Obligations

The exposure draft of the Security Legislation Amendment (Critical Infrastructure Protection) Bill - aka SOCI 2 - features a specific part 2C on 'Cyber Security Obligations', described thus in the explanatory statement for the draft Bill -  

86. Critical infrastructure assets and the systems they rely on are increasingly interconnected and interdependent. While Parts 2, 2A, and 2B, discussed above, impose obligations to manage risks to the operation of these assets, a small subset of critical infrastructure assets are of the highest criticality due to their interdependences with other critical assets. A closer partnership is required in relation to these systems of national significance, and the computer infrastructure that underpins them, to build enhanced cyber resilience and preparedness. 

87. The Australian Government has introduced the enhanced cyber security obligations to strengthen the cyber preparedness and resilience of entities that operate critical infrastructure assets of the highest criticality (system of national significance). Consultation on the Cyber Security Strategy 2020 supported initiatives to enhance cyber information sharing to build a stronger collective understanding of threats to Australian systems. These obligations enable the Government to establish a bespoke partnership, tailored to individual assets, to not only prepare entities to better manage cyber risks but also improve Australia’s situational awareness, particularly as the threat environment worsens. 

88. Under Part 6A, the Minister for Home Affairs may declare a critical infrastructure asset to be a system of national significance. Part 2C would provide for a series of enhanced cyber security obligations which may be imposed on the responsible entity for a system of national significance. Responsible entities for Systems of National Significance would not be obligated to comply with each of these enhanced obligations following the Minister’s declaration, but rather may be required to do so, from time to time, following a written notice from the Secretary of Home Affairs. This approach reflects the different nature of the obligations provided under this Part, which are aimed at addressing or identifying vulnerabilities and building resilient practices. 

89. The Australian Government would continue to build on the strong voluntary engagement and cooperation with critical infrastructure entities that has underpinned the success of the relationship to date. This includes providing voluntary support and guidance. However, there may be instances where entities are unwilling or unable to voluntarily cooperate and the Enhanced Cyber Security Obligations are necessary. 

Division 2 of Part 2C – Statutory incident response planning obligations 

90. The first of the enhanced cyber security obligations which the Secretary may require the responsible entity for a system of national significance to comply with is the statutory incident response planning obligation. Incident response plans are designed to ensure an entity has established processes and tools to prepare for and respond to cyber security incidents. Incident response plans would provide assurance to Government that entities are sufficiently prepared for cyber security incidents and would assist entities by clearly articulating ‘what to do’ and ‘who to call’ in the event of a cyber  security incident. Clear escalation pathways and processes can be crucial to mitigating and minimising the consequences of fast moving cyber incidents. 

91. Section 30CB would enable the Secretary of the Department of Home Affairs to determine that the statutory incident response planning obligations apply to the entity, meaning that it would need to adopt and maintain an incident response plan (section 30CD), comply with the plan (section 30CE), and regularly review (section 30CF) and take all reasonable steps to ensure the plan is up to date (section 30CG). 

92. Section 30CJ would provide that an incident response plan is a written plan that relates to the system of national significance, for the purposes of planning for responding to cyber security incidents that could have a relevant impact on the system. The plan would need to comply with any requirements specified in the rules, which may include details on procedures to be included in the plan for responding to a particular cyber security incident. 

93. Incident response plans would vary from entity to entity. However, common elements of an incident response plan include definitions of the types of systems being used, details of staff member roles and responsibilities, outlines of common cyber incidents and incident response processes to mitigate and remediate a cyber security incident. 

94. A copy of the incident response plan would need to provided to the Secretary of Home Affairs, as soon as practicable after it is adopted or varied. This would ensure Government and entities have the necessary information to activate cyber security incident response arrangements at any point in time, particularly in the event of an emergency. 

95. A civil penalty of up to 200 penalty units applies for failure to comply with the obligations in this Division (the value of a penalty unit is currently $222 for offences committed on or after 1 July 2020). 

Division 3 of Part 2C – Cyber security exercises 

96. The second of the enhanced cyber security obligations which the Secretary may require the responsible entity for a system of national significance to comply with is the requirement to undertake a cyber security exercise. 

97. Cyber security exercises are an integral part of an entity’s cyber security procedures, as they are used to test response preparedness, mitigation and response capabilities. Such exercises enable an entity to develop an understanding of how to address a cyber incident through a scenario that requires the entity to draw upon resources, such as incident response plans, relevant legislation, policies and processes to identify the most appropriate response to a cyber security incident. Cyber security exercises can identify gaps in existing approaches and help streamline processes to ensure more effective and efficient responses to threats as they emerge. 

98. During consultation on the Cyber Security Strategy 2020, submissions highlighted the importance of joint cyber security exercises involving industry and government to improve entities’ cyber resilience. Noting the interdependencies between critical infrastructure assets, these exercises can be used to develop interoperable response capabilities to prevent a cascading of impacts across sectors. 

99. Section 30CM would provide that the Secretary of Home Affairs may, by written notice, require the entity to undertake a cyber security exercise in relation to all types of cyber security incidents, or one or more specified types of cyber security incidents (for example, a denial of service or ransomware attack). 

100. The scope of the exercise would be determined based on analysis of threats and incident trends, as well as consideration of the consequential or cascading effects that may occur should the system be impacted by a cyber security incident. 

101. A cyber security exercise would be defined in section 30CN to an exercise, the purpose of which is to test the entity’s: ability to respond appropriately to the cyber security incident/s; preparedness to respond appropriately to the cyber security incident/s; and   ability to mitigate the relevant impacts the cyber security incident/s could have on the system. 

102. Cyber security exercises are generally conducted through one of two formats: discussion-based or tabletop exercises, and operational or functional exercises. 

103. The Secretary of Home Affairs may also require that the entity allow specified designated officers to observe the cyber security exercise, provide those officers with access to the premises or other assistance and facilities to allow the observation of the exercise, allow them to make reasonably necessary records and give them notice of when the exercise would commence. A designated officer is defined in section 30DQ to be an employee of the Department of Home Affairs or a staff member of the Australian Signals Directorate. 

104. Section 30CQ would provide that, on completion of the exercise, the entity is required to prepare an evaluation report relating to the exercise and give a copy of the report to the Secretary. An evaluation report is a written report the purpose of which is to evaluate the entity’s:  ability to respond appropriately to the cyber security incident/s;  preparedness to respond appropriately to the cyber security incident/s, and  ability to mitigate the relevant impacts the cyber security incident/s could have on the system. 

105. However, if the entity has prepared, or purported to prepare an evaluation report, provided it to the Secretary for Home Affairs and the Secretary has reasonable grounds to believe that the report was not prepared appropriately, the Secretary may require the entity to appoint an external auditor to prepare an evaluation report for the entity. Alternatively, if the entity fails to comply with section 30CQ the Secretary for Home Affairs may require an external evaluation report to be prepared by an external auditor. An external auditor is a specified individual authorised by the Secretary as such for the purposes of the Act. 

106. A civil penalty of up to 200 penalty units applies for failure to comply with the obligations in this Division (the value of a penalty unit is currently $222 for offences committed on or after 1 July 2020). 

Division 4 of Part 2C – Vulnerability assessments 

107. The third element of the enhanced cyber security obligations which the Secretary may require the responsible entity for a system of national significance to comply with is the requirement to undertake a vulnerability assessment. 

108. Vulnerability assessments are a routine cyber security practice undertaken to identify vulnerabilities or ‘gaps’ in systems which expose them to particular types of cyber incidents. These preparatory activities also enable the entity to evaluate the risk of particular vulnerabilities. This  would enable entities that operate Australia’s Systems of National Significance to remediate vulnerabilities before they can be exploited by malicious actors. The identification of vulnerabilities in one system may also enable the remediation of similar vulnerabilities across other critical systems. 

109. A vulnerability assessment can consist of a documentation-based review of a system’s design, a hands-on assessment or automated scanning with software tools. In each case, the goal is to identify security vulnerabilities. 

110. Section 30CU would provide that the Secretary of Home Affairs may require the entity to undertake, or cause to be undertaken, a vulnerability assessment in relation to the system and a particular type of cyber security incident, or cyber security incidents generally. The entity can undertake this assessment or may choose to engage the services of a third party to undertake the assessment. Prior to making such a request, the Secretary is required to consult with the entity. This consultation requirement would assist the Secretary to determine the entity’s capacity to undertake, or cause to be undertaken, the required vulnerability assessment. 

111. If the Secretary of Home Affairs has reasonable grounds to believe that the entity would not be capable of complying with a notice or has not complied with an earlier notice, the Secretary may give a designated officer a written request to undertake the vulnerability assessment and require the entity to provide reasonable access, assistance and facilities to the officer to allow the assessment to be undertaken. 

112. If the entity, or a designated officer, undertakes a vulnerability assessment they would need to prepare, or cause to be prepared, a vulnerability assessment report and provide a copy of the report to the Secretary. 

113. A civil penalty of up to 200 penalty units applies for failure to comply with the obligations in this Division (the value of a penalty unit is currently $222 for offences committed on or after 1 July 2020). 

Division 5 of Part 2C – Access to system information 

114. The final of the enhanced cyber security obligations which the Secretary may require the responsible entity for a system of national significance to comply with is the requirement to provide system information. 

115. During consultation on the Cyber Security Strategy 2020, stakeholders strongly supported initiatives to improve information sharing to make critical infrastructure more resilient and secure. The provision of system telemetry from Systems of National Significance would support the Government’s ability to build a near-real time threat picture through the CESAR capability and share actionable, anonymised information back out to industry. Aggregated system information, overlaid with intelligence and reporting, would also enable the Government to target its limited capabilities to the threats and vulnerabilities of greatest consequence to the nation. 

116. System information is information that relates to the operation of the computer needed to operate a system of national significance. This information may assist with determining whether a power under this Act should be exercised in relation to the system of national significance. However, system information cannot include personal information within the meaning of the Privacy Act 1988. For example, system information may be network logs or alerts that provide visibility of the operation and functioning of a broader computer network. The monitoring of this information can be crucial to identifying a compromise of a system and deploying a rapid response to mitigating its potential impacts. 

117. Section 30DB would provide that, if the Secretary of Home Affairs believes on reasonable grounds that the responsible entity for the system of national significance is technically capable of doing so, the Secretary may require the entity to provide the Australian Signals Directorate with periodic reports consisting of specified system information (‘a system information periodic reporting notice’). The Secretary may specify the intervals, manner and form in which the information is to be provided, as well as any other information technology requirements relating to the provision of the information. Depending on the information required and the ability for automated provision (such as automated machine-to-machine cyber threat intelligence sharing), these reports may be required to be made at rapid intervals, for example, every minute. 

118. Section 30DC would provide that, if the Secretary of Home Affairs believes, on reasonable grounds, that the responsible entity for the system of national significance is technically capable of doing so, the Secretary may require the entity to provide the Australian Signals Directorate with reports consisting of specified system information as soon as practicable after each incidence of a specified event occurring (‘a system information event-based reporting notice’). For example, a report may be required every time a particular computer program raises a specified class of alert or error message. 

119. In deciding whether to give a system information periodic reporting notice or a system information event-based reporting notice, the Secretary of Home Affairs would have to have regard to the costs that are likely to be incurred by the entity in complying with the notice. To support this consideration as well as the determination of whether the entity is technically capable of providing the report, section 30DD mandates that the Secretary of Home Affairs would need to consult with the entity prior to issuing the notice. 

120. If the Secretary of Home Affairs does not believe on reasonable grounds that the entity would be technically capable of preparing reports under sections 30DB or 30DC, section 30DJ would provide that the Secretary may require the entity to install and maintain a specified computer program (‘system information software notice’). The computer program may only be specified in the notice if its purpose is to collect and record the required system information and cause the information to be transmitted electronically to the Australian Signals Directorate. The computer program would be provided by the Government and would, for example, operate as a host-based sensor reporting back to the Australian Signals Directorate telemetry information used to monitor the system for malicious behaviour. 

121. In deciding whether to give a system information software notice, the Secretary of Home Affairs would need to have regard to the costs that are likely to be incurred by the entity in complying with the notice. To support this consideration, section 30DK mandates that the Secretary of Home Affairs would need to consult with the entity prior to issuing the notice. 

122. A civil penalty of up to 200 penalty units applies for failure to comply with the obligations in this Division (the value of a penalty unit is currently $222 for offences committed on or after 1 July 2020).

SOCI 2 - Risk Management and Vetting

The exposure draft of the Security Legislation Amendment (Critical Infrastructure Protection) Bill - SOCI 2 - includes a requirement to 'Establish, maintain, and comply with a Risk Management Program' - 

 11. The Risk Management Program would require owners and operators of critical infrastructure assets to manage the material risk of any hazards occurring, which pose a risk of impacting on the availability, integrity or confidentiality of the critical infrastructure asset. Where possible, the requirements under the Risk Management Program recognise or build on existing regulatory frameworks to minimise the regulatory burden on industry. Indeed, the Government has kept the public interest criteria in the proposed Bill to ensure that cost and the need to switch on the obligation through a rule following formal consultation is maintained. This ensure that if an existing regulation already exceeds the Risk Management Program requirement, there is not a duplicative set of obligations in place. 

12. The Exposure Draft sets out the overarching obligations for the Risk Management Program with the more detailed requirements to be contained in rules that have been developed with industry during an extensive consultation process. 

Enhanced Cyber Security Obligations for Systems of National Significance 

13. The Enhanced Cyber Security Obligations would, if implemented, support a bespoke, outcomes- focused partnership between Government and Australia’s most critical assets – declared as systems of national significance’. These obligations would enhance the already mature Government-industry information sharing arrangements to build an aggregated threat picture and provide Government with a comprehensive understanding of the ability of entities responsible for Systems of National Significance to respond appropriately to, or mitigate the impact of, a cyber security incident. Importantly all obligations are exclusively outlined in the proposed bill. 

14. Systems of National Significance are proposed to be a significantly smaller subset of critical infrastructure assets that, by virtue of their interdependencies across sectors and cascading consequences of disruption to other critical infrastructure assets and critical infrastructure sectors, are crucial to the nation. 

15. Should the Minister for Home Affairs declare a critical infrastructure asset to be a System of National Significance, the Secretary of the Department of Home Affairs may require the responsible entity for a System of National Significance to undertake one or more prescribed cyber security activities. This does not mean that all obligations would apply. They would be considered on a case by case basis following consultation with the System of National Significance. The exclusive and exhaustive list of possible obligations include the development of cyber security incident response plans, cyber security exercises to build cyber preparedness, vulnerability assessments to identify vulnerabilities for remediation, and provision of system information to build Australia’s situational awareness. The Exposure Draft explicitly requires the Secretary of the Department of Home Affairs to request the prescribed activity in order to ensure activities have a clear, stated security objective. 

16. Through consultation on these reforms, stakeholders have consistently supported greater threat information sharing and partnerships with Government. The Enhanced Cyber Security Obligations would support the bi directional sharing of threat information to provide industry with a more mature understanding of emerging cyber security threats, and the capability to reduce the risks of a significant cyber attack against Australia’s most critical assets. 

Create a mechanism to declare critical infrastructure assets of the highest criticality as systems of national significance 

17. The Exposure Draft sets out a new proposed Part 6A outlining the mechanisms for making a declaration to define critical infrastructure assets that are the most interconnected and interdependent assets, and critical to the security, economy and sovereignty of Australia, as Systems of National Significance, and enabling the requirement for enhanced cyber security obligations. 

18. The Minister for Home Affairs would have ability to privately declare a critical infrastructure asset to be a system of national significance, once they have considered the asset’s interdependencies with other critical infrastructure assets, and the consequences to Australia’s national interest if the asset is significantly impacted. 

Other measures 

19. The Exposure Draft proposes information sharing provisions to make it easier for regulated entities to share information with their relevant regulator(s).

The statement indicates 

Combined, the SOCI Act and the proposed rules would ultimately require responsible entities of critical infrastructure assets to manage security risks by meeting the following principles-based outcomes:

a. Identify material risks – Entities would have a responsibility to take an all-hazards approach when identifying risks that may affect the availability, integrity, reliability and confidentiality of their asset. This would require considering both natural and human induced hazards, which pose a material risk, with the detail outlined in rules that have been designed with industry. This may include understanding how these risks might accumulate throughout the supply chain, understanding the way systems are interacting, and outlining which of these risks may have a significant consequence to core service provision. 

b. Mitigate risks to prevent incidents – Entities would be required to understand the identified risks and have appropriate risk mitigations in place to manage those risks so far as is reasonably practicable. Risk mitigation should consider both proactive risk management as well as having processes in place to detect and respond to threats as they are being realised to prevent the risk from eventuating. 

c. Minimise the impact of realised incidents – Entities would be required to have robust procedures in place to mitigate, so far as is reasonably practicable, the impacts in the event a threat has been realised and recover as quickly as possible. This may include ensuring plans are in place for a variety of incidents, such as having back-ups of key systems, adequate stock on hand, redundancies for key inputs, out-of-hours processes and procedures, and the ability to communicate with affected customers. 

d. Effective governance – Through rules, entities would be required to have appropriate risk management oversight arrangements in place, including evaluation and testing. This would involve strong governance with clear lines of accountability, demonstrated comprehensive planning, and a robust assurance and review process. Compliance would be assessed by the relevant regulator, noting that what is appropriate would be unique to each entity. Regulators would focus on security and resilience outcomes and seek to avoid compliance action wherever possible.\

71. Subsection 30AH(1)(c) specifically requires the critical infrastructure Risk Management Program to comply with any requirements specified in the rules. At a minimum, it is proposed that rules, to be developed with industry, would require responsible entities to consider and address risks in the following four domains:

a. Physical security and natural hazards: This includes risk of harm to people and damage to physical assets. For example, mechanical failures, natural hazards such as floods and cyclones, as well as human induced hazards such as terrorism. 

b. Cyber and information security hazards: Malicious cyber activity is one of the most significant threats facing Australian critical infrastructure assets and can range from denial of service attacks, to ransomware and targeted cyber intrusions. 

c. Personnel security hazards: This refers to the ‘insider threat’ or the risk of employees exploiting their legitimate access to an organisations’ assets for unauthorised purposes including corporate espionage and sabotage. 

d. Supply chain hazards: The reliance on supply chains inherently involves dependencies on other assets, or providing other entities with some level of access to, or control of, your asset or business’ deliverables. As is the case for personnel risk, supply chain risks relate to entities exploiting their legitimate access to, or control of, an organisations’ assets for unauthorised purposes or otherwise creating a cascading impact to dependent assets.

As forecast, the Bill encompasses vetting, with the statement indicating 

Background checking 

77. Trusted insiders are potential, current or former employees or contractors who have legitimate access to information, techniques, technology, assets or premises. Trusted insiders can intentionally or unknowingly assist external parties in conducting activities against the organisation or can commit malicious acts of self-interest. Such action by a trusted insider can undermine or severely impact the availability, integrity, reliability or confidentiality of those assets captured as critical infrastructure assets. 

78. Recognising the importance of personnel security, the Exposure Draft would make two key amendments to support industry’s ability to understand and manage personnel security risks through background checking. 

79. The Exposure Draft would insert new paragraph 8(1)(ba) into the AusCheck Act 2007 to provide the ability for the AusCheck scheme prescribed in the AusCheck Regulations 2017 to be amended to enable industry to utilise background checking of an individual if that entity considers that individual to be a critical employee or a member of critical personnel. Please note that this is not a mandatory background check for critical infrastructure. Nor is it to be used as a justification for excessive and unwarranted background checking of staff. The provisions to enable entities to conduct background checking of critical employees or personnel under the critical infrastructure Risk Management Program would be made by rules under new subsection 30AH(4). 

80. Currently, the AusCheck Scheme has been established to provide background checking services for the Aviation Security Identification Card (ASIC), Maritime Security Identification Card (MSIC), National Health Security (NHS) check schemes, and in relation to Major National Events (MNE), amongst others.

IPND

ACMA has announced that Telstra has yet again disregarded obligations regarding the Integrated Public Number Database (IPND). 

the announcement states that  Telstra has paid an infringement notice of $2.53 million after ACMA found 'large-scale breaches of rules intended to protect the privacy and safety of customers', with almost 50,000 instances where Telstra failed to correctly upload a customer’s choice of an unlisted - or silent - number to the IPND. That failure - regrettably not a one-off, given that ACMA found in 2019 that Telstra had breached the same obligations.

The failure meant 'silent' numbers could be published in public phone directories or be available through online directory services. 

ACMA also found that Telstra failed to provide data to, or failed to update, the IPND for its Belong customers on over 65,000 occasions.

ACMA's Chair said Telstra potentially put people’s safety at risk. 

 When people request a silent number it is often for very important privacy and safety reasons, and we know that the publication of their details can have serious consequences. The IPND is also used by Triple Zero to help locate people in an emergency, for the Emergency Alert Service to warn of emergencies like flood or bushfire, and to assist law enforcement activities. 

The provision of these critical services can be hampered and lives put in danger if data is missing, wrong or out of date. It is alarming that Telstra could get this so wrong on such a large scale.

ACMA notes that 

All telcos are required to upload customer information into the IPND for each service they provide. This includes the telephone number, the customer’s name and address and whether the customer wants their number of be listed or unlisted. Flagging a number as listed or unlisted determines whether a customer’s details are available in public phone directories and directory assistance services. ... In 2018 and 2020 the ACMA took action against a total of 26 telcos for non-compliance with upload rules, including giving remedial directions. Earlier this year the ACMA gave Lycamobile a $600,000 penalty for breaching the rules.

15 December 2021

Tobacco

'New Zealand Is Banning Tobacco. Will Anyone Follow?' by David Fickling on Bloomberg News on 13 December 2021 comments 

New Zealand last week announced plans to become the first nation in the world to ban tobacco. Prohibition won’t happen overnight. Instead, the country will raise the legal smoking age each year, so that people born after 2008 will never be allowed to puff. That will eventually mean that tobacco smoking — a practice that’s been prevalent in the Americas for thousands of years, and spread around the world after Christopher Columbus introduced it to Europe — may finally start disappearing from one corner of the planet. This may be a taste of things to come. The Netherlands will ban supermarket sales of tobacco starting in 2024, and the Medical Journal of Australia last month called for a New Zealand-style phaseout policy in that country. One in four Americans supported a total smoking ban in a 2018 survey by Gallup. … 

Smoking kills more than 8 million people every year, making it a scourge at least on the scale of Covid-19, which has caused about 5.3 million recorded deaths over the past two years (alcohol, far more widespread, contributes to about 3 million annual deaths). That alone is reason enough to restrict the practice. … 

[W]e’re now at the point where the thick end of [polict] wedges is hoving into view. If you’d suggested 14 years ago that banning smoking in pubs might ultimately lead to states prohibiting adults from undertaking activities that only harm themselves, it would have been dismissed as alarmist. But that’s what we’re looking at now. Restrictions on indoor smoking and packaging protect bystanders from passive fumes and reduce the marketing power of cigarette businesses — outcomes that serve to enhance the welfare of all individuals. Further restrictions to limit the exposures of children and fellow householders to second-hand smoking in the home and private vehicles might be justified on the same grounds, even if they would be challenging to enforce. Outright bans, however, limit the scope of choice that the generation of New Zealanders who grow into this new law will be allowed to make. … 

What’s clear is that the current breed of tobacco control policies aren’t succeeding in bringing down voluntary smoking fast enough without harmful side-effects of their own. The very high taxes imposed in New Zealand and Australia — a 25-stick pack of Marlboro Gold at my local supermarket costs A$48.95 ($35) — don’t seem to be enough to break the power of addiction. Ultimately, they mean the underprivileged communities who still smoke at the highest rates have to pay regressive taxes on top of their other problems. … 

That suggests a change of direction toward a limited and gradual, but ultimately more absolute measure like that being introduced in New Zealand is worthwhile, even just so the rest of the world can see whether it’s a success or a failure. Smokers themselves, few of whom feel great loyalty to their self-destructive habit, are often supportive of tobacco control policies. A 2019 survey in Sweden found former users were only slightly less in favor of such laws than the general population, while one recent study of 6,014 smokers in Pakistan found that 82% supported a complete ban. 

Liberal societies will rightly seek to enhance individuals’ sovereignty over their bodies, and tread carefully when they take those freedoms away. Addictive drugs already violate that sovereignty, though, by making it physically or psychologically painful to give them up. Tobacco prohibition in New Zealand will certainly infringe on people’s freedoms. Tobacco addiction, however, has been doing that for centuries.

Genome Editing

The interim report of the Australian Citizens’ Jury on Genome Editing states 

The Australian Citizens’ Jury on Genome Editing (AusCJ) assembled 23 (extra)ordinary Australians to learn, reflect and discuss the conditions under which they might accept the application of various forms of human genome editing. They deliberated over four days at the Museum of Australian Democracy in Canberra on 17-20 June 2021. Their considerable efforts resulted in a series of twelve recommendations pertaining to heritable human genome editing (HHGE), non-heritable human genome editing (NHHGE), research on human genome editing using human embryos and the use of mitochondrial donation. 

Although there were important differences among participants’ views that are raised in this report, there was a generally strong level of interest and engagement with the possibilities afforded by the application of human genome editing in terms of reducing the burden of disease. Most participants agreed with a strong degree of conditionality, to ensure that development and application is directed toward community benefit, not for non-clinical enhancement, and that there is a high level of ongoing community engagement and oversight. The potential use of HHGE was much more controversial for participants than NHHGE, but there was a strong level of support for continued research into its application, as long as doing so does not result in implementation via incremental creep. This research would serve to inform a thorough understanding of the associated ethical implications and potential benefits to inform future choices. 

A strength of the AusCJ was the diversity of participants’ views. The process resulted in substantive transformation of positions, tending toward greater interest and acceptance of the technology. However, a good deal of this diversity remained after deliberation. Part of that diversity involved substantial concern regarding the more profound implications associated with the technology. These concerns overlapped with feedback from participants that more time was needed to reflect on such a complex issue, as well as a need to hear more critical views of the value of genome editing from the witnesses who presented information. Provisional analysis of the deliberation process suggests that other areas remained incompletely deliberated, including the role of the private sector, considering the strong focus on public benefit and equity of access, and specific ethical issues regarding use of embryos for research on genome editing. 

The findings of participants and provisional analysis included in this report demonstrate the need for wider public engagement regarding human genome editing. The alternative is to risk polarisation and distrust, affecting the application of all forms of the technology. Follow up research involving interviews, population survey, and engagement with the community of experts will further assess the issues raised and the results communicated in the final report.

The recommendations produced by the AusCJ are summarised in the report as follows, with the AusCJ commenting that in many cases the view expressed involves a majority rather than complete consensus. 

Recommendations regarding heritable human genome editing (HHGE) 

R 1 Potential future clinical applications of HHGE should be supported by encouraging more research. If approved, HHGE should only be used to assist people to have healthy, genetically related children, under strict guidelines and regulation. 

R 2 Clinical applications of HHGE should be prioritised and non-clinical applications, including enhancement, should be prohibited. 

R 3 Any process for approving applications of HHGE must ensure meaningful participation by members of the public. 

R 4 People should be informed about and have access to reproductive technologies that do not involve human genome editing, where such exist. 

Recommendations regarding non-heritable human genome editing (NHHGE) 

R 5 Clinical applications of NHHGE should be supported to alleviate human suffering if meaningful consent can be ensured. Non-clinical applications should be prohibited for now. 

R 6 All parts of the NHHGE process should be subject to intersectoral regulation and oversight to ensure that risks and benefits are adequately assessed. 

R 7 NHHGE should be made accessible to those who need it. Decisions about equitable access be motivated by concern for the public good. 

Recommendations regarding human genome editing research using human embryos 

R 8 Genome editing research using human embryos, including human embryos created for research through fertilisation, should proceed subject to stringent regulation and oversight. 

R 9 Strict monitoring and regulation should be used to prevent mass production and commercialisation of human embryos for research through fertilisation. 

Recommendations regarding mitochondrial donation 

R 10 Mitochondrial donation should be permitted for the purpose of preventing mitochondrial disease, but only with appropriate regulation. 

R 11 Mitochondrial donation should not be offered for profit and no financial transactions should take place between donor and recipient. 

R 12 Mitochondrial donation should be made accessible to those who need it, and consideration should be given to how best to ensure equitable access.

NZ Succession Law Reform

The New Zealand Law Commission report on Succession states 

 1. This Review of Succession Law examines the body of rules that governs how a person’s property is distributed when they die. The review requires consideration of the Property (Relationships) Act 1976 (PRA), the Family Protection Act 1955 (FPA) and the Law Reform (Testamentary Promises) Act 1949 (TPA). It also includes the rules governing the distribution of intestate estates under the Administration Act 1969. The succession to whenua Māori under Te Ture Whenua Maori Act 1993 (TTWMA) does not form part of this review. 

2. This Report begins with consideration of what it means to develop good succession law. We conclude that the current law governing entitlements to and claims against estates is old, out of date and inaccessible. Reform is required to achieve simple and clear law. Reform is also required to reflect te ao Māori perspectives in succession. 

3. Our view of te Tiriti o Waitangi | Treaty of Waitangi requires us to focus on how kāwanatanga might be exercised in a responsible manner, including how the exercise of tino rangatiratanga might be facilitated in specific circumstances. In the context of succession, we conclude that responsible kāwanatanga requires us to facilitate tino rangatiratanga through recognising tikanga Māori where that is necessary to enable Māori to live according to tikanga, to weave new law that reflects tikanga Māori and other values shared by New Zealanders and finally to recognise the limits of kāwanatanga. 

4. This approach requires tikanga Māori to be considered in both defining and responding to a policy “problem”. In some areas, this has been difficult to implement, given the pervasive nature of aspects of state law. We conclude that it is the tikanga of the relevant whānau that will be most important. 

5. We also conclude that the exercise of responsible kāwanatanga requires that tikanga Māori be able to continue to govern succession to taonga and the appropriate role of state law in relation to taonga should be limited to facilitating the resolution of disputes in accordance with tikanga Māori. We discuss these matters further in Chapters 3, 12 and 13. 

6. We identify several criteria that good succession law should satisfy. Good succession law should: (a) be simple, accessible and reflect New Zealanders’ reasonable expectations; (b) be consistent with fundamental human rights and international obligations; (c) balance mana and property rights (including testamentary freedom) with obligations to family and whānau in order to promote whanaungatanga and other positive outcomes for families, whānau and wider society; and (d) facilitate efficient estate administration and dispute resolution. 

7. We recommend that a new statute should be enacted as the principal source of law in place of Part 8 of the PRA, the FPA and the TPA. It should be titled the Inheritance (Claims Against Estates) Act (the new Act). The intestacy regime should be revised in line with our recommendations in Chapter 7 but remain in the Administration Act. There is merit in considering whether the new Act and other statutes relevant to testate and intestate succession could be consolidated into one statute. 

SUCCESSION AND TAONGA 

8. Taonga are knowledge and identity markers for Māori. They may be described in various ways including that they are highly prized and valuable objects, resources, techniques, phenomena or ideas. Taonga remind the living of their obligations to the living and future generations. Taonga have associated intangible attributes such as mana, tapu, kōrero mauri and utu. Where a taonga strongly reflects these attributes, it may have its own mauri which must be respected. For these sorts of taonga, the holder of the taonga exercises a kaitiaki role on behalf of the group. Where a taonga has fewer of the attributes, individuals may exert more influence over the taonga. 

9. We conclude that taonga should be treated in a way that respects the tikanga relating to taonga grounded in mātauranga Māori. State law should not determine the substantive question of succession to taonga. The Wills Act 2007, the Administration Act and the new Act should ensure that succession to taonga is determined by the tikanga of the relevant whānau or hapū. In our view, this approach actively protects “te tino rangatiratanga o … o ratou taonga katoa” and is the best way for the Crown to responsibly exercise its kāwanatanga to that effect. 

10. To exclude taonga from succession under state law, taonga must be defined. We prefer a definition that references the tikanga of the relevant whānau or hapū. This reflects our view that what constitutes a taonga should be determined by the tikanga of the relevant whānau or hapū. It is a factual inquiry that must be undertaken considering both the relevant tikanga and the circumstances of the case. 

RELATIONSHIP PROPERTY ENTITLEMENTS 

11. Part 8 of the PRA provides that, when a partner to a qualifying relationship dies, the surviving partner is entitled to a division of the couple’s relationship property instead of whatever provision is available for them under the deceased’s will or in an intestacy. The rules that apply to the division of relationship property when couples separate apply, with some modifications, to the division of relationship property on death. The policy basis for Part 8 of the PRA is that a surviving partner should be no worse off on the death of their partner than if the couple had separated. 

12. In tikanga Māori, marriage was traditionally a relationship equally as important for the whānau and hapū as the spouses because it provided links between different whakapapa lines and gave each new members. However, while marriage was highly valued, it was not given absolute precedence over other relationships because of the importance of whakapapa. The operation of whanaungatanga, aroha and manaakitanga mean whānau take care of their members, including undoubtedly a bereaved partner. This is likely to manifest itself in care not only for the partner but for any children of the relationship and likely involve whānau of both partners. 

13. We conclude that the new Act should continue a surviving partner’s entitlement to a division of relationship property. We are satisfied with the policy basis for this approach and consider it aligns with the reasonable expectations of New Zealanders. 

14. A relationship property division under the new Act should occur differently to division under the current rules of Part 8 of the PRA: 

(a) The option A/option B process through which a partner formally elects a division of relationship property should not be continued in the new Act. Instead, a partner should have a right to apply to the court for a relationship property division within 12 months of the grant of administration. 

(b) Whereas the PRA revokes any gift to a surviving partner under the deceased’s will when they elect a relationship property division, we recommend the partner should generally still receive the gifts. Whatever property is then needed to “top-up” the surviving partner’s entitlement to the full extent of their relationship property interest should be awarded from the estate. We consider this approach is likely to be more consistent with the deceased’s testamentary intentions and easier for the personal representatives to administer. 

(c) Key changes we recommended in the PRA review should be brought into the new Act including changes concerned with the classification of relationship property and the relationships that should qualify for relationship property division. 

FAMILY PROVISION CLAIMS 

15. Under the FPA, a family member of the deceased can challenge the provision left to them under the deceased’s will or in an intestacy on the grounds it is inadequate for their “proper maintenance and support”. The courts have applied the statute by asking whether the deceased has breached the “moral duty” they owed to make proper provision. The courts have held that adequate support, as a standalone concept, can require financial provision from an estate as recognition of belonging to the family, even if the claimant has no financial need. 

16. In tikanga, whānau occupies a central place. Rights and obligations are sourced from whakapapa, whanaungatanga, manaakitanga and aroha. These obligations can include financial and moral support as well as an obligation to take responsibility for each other’s actions. The whānau is also crucial for discussing and settling familial issues relating to child rearing and succession. One of the primary obligations of the whānau as a whole is to the welfare of tamariki and mokopuna. 

17. The practice of whāngai, where a child is raised by someone other than their birth parents, usually another relative, is firmly rooted in whanaungatanga. The rights of whāngai to succeed according to tikanga varies amongst whānau, hapū and iwi. 

18. We conclude the FPA requires reform. The objectives of the statute are not sufficiently clear to satisfy modern legislative drafting standards. Instead, the law relies heavily on judicial discretion to assess whether there has been a breach of “moral duty”. It is unsatisfactory to have a legal test expressed in these terms. In many cases, reasonable minds will differ on the “moral” way of distributing an estate among family. Feedback from submitters showed strongly divergent views on when it should be appropriate to disrupt a deceased’s testamentary intentions to grant further provision to family members. Aotearoa New Zealand’s increasing cultural diversity and the need to enable te ao Māori perspectives no doubt add to the differences of opinion. In addition, the courts have been reluctant to accept arguments that tikanga Māori should determine the scope of a deceased’s moral duty. 

19. We recommend the repeal of the FPA. In its place, the new Act should allow certain family members of the deceased to apply to the court for a family provision award. 

Family provision awards for partners 

20. A deceased’s surviving partner from a qualifying relationship should be eligible to claim family provision. The court should make an award where the partner has insufficient resources to maintain a reasonable, independent standard of living. The court should take into account the provision available from the deceased on the deceased’s death. The court should have regard to the economic disadvantages arising from the relationship for the surviving partner. The court should have discretion to determine the amount of a family provision award to a surviving partner, having regard to a list of factors expressed in the new Act, including the tikanga of the relevant whānau. 

Family provision awards for children 

21. In respect of the rights of the deceased’s children and grandchildren to claim family provision, we are unable to present a single recommendation for reform. Through our research and consultation, it is evident that opinions in Aotearoa New Zealand are divided on the question of whether adult children should be eligible to seek further provision from a parent’s estate. Instead, we put forward two options for reform for the Government to consider. 

22. Under Option One, the deceased’s children and grandchildren of all ages should be eligible to claim family provision. A court should grant an award when the deceased has unjustly failed to: (a) provide for the child and grandchild who is in financial need; or (b) recognise the child or grandchild. 

23. Under Option Two, only the deceased’s children under 25 years of age or those who are disabled would be eligible to claim. For a child under 25, a court should make an award when, taking into account whatever provision is available to the child from the deceased on the deceased’s death, the child does not have sufficient resources to enable them to be maintained to a reasonable standard and, so far as is practical, educated and assisted towards attainment of economic independence. For children who are disabled, the disability must have reduced the person’s independent function to the extent that they are seriously limited in the extent to which they can earn a livelihood. A court should make an award when, taking into account whatever provision is available to the child from the deceased on the deceased’s death, the child does not have sufficient resources to enable them to maintain a reasonable standard of living. 

24. For both options, the court should have discretion to determine the amount of a family provision award, having regard to a list of factors expressed in the new Act, including the tikanga of the relevant whānau. 

25. For both options, we recommend a child of the deceased should be defined to include an “accepted child” and whāngai. An accepted child would be a child for whom the deceased had assumed, in an enduring way, the responsibilities of a parent. The extent to which a whāngai should be entitled to family provision should be informed by the tikanga of the relevant whānau. 

CONTRIBUTION CLAIMS 

26. Under the current law, a person who provides benefits to someone who later dies may have claims they can bring against the deceased’s estate in respect of their contributions. For example, they may claim an award under the TPA, breach of contract, a constructive trust over the estate, estoppel, unjust enrichment or quantum meruit. 

27. In tikanga, utu, take-utu-ea, whanaungatanga and whakapapa and mana may be relevant to contributions to a deceased. Utu involves the idea of reciprocity, which provides for the ongoing maintenance of relationships. Utu sits within the take-utu-ea framework, which is a framework for assessing breaches of tikanga and what the appropriate utu is to reach a state of ea, or resolution. Whanaungatanga and whakapapa concern the nature of the relationship between the contributor and the deceased. From an ao Māori perspective the appropriate response to contributions is relative to the increase in mana caused by the contributions and not the contributions themselves. 

28. The main problem with the current law is its complexity and uncertainty. The multiple claims arising from similar factual situations can lengthen litigation and increase costs. Predicting outcomes and awards can be difficult, which can discourage parties from settling claims out of court. 

29. For these reasons, we proposed in the Issues Paper to codify the current law through a single statutory cause of action that would apply in respect of contributions to a deceased or their estate. We have not, however, carried through the proposal as a recommendation. Feedback from consultation, while broadly supportive of the intention behind the proposal, questioned the extent to which the law could be codified and also raised the risk of unintended consequences. 

30. We therefore conclude the new Act should restate a revised testamentary promise cause of action. The cause of action should respond in much the same way as the TPA to hold a deceased to their promise to make testamentary provision to someone from whom they have received substantial work or services. Other causes of action in common law and equity would continue to operate outside the new Act. 

INTESTACY ENTITLEMENTS 

31. Intestacy occurs when the whole or part of the deceased’s estate is not of disposed of by will. Dying intestate is relatively common in Aotearoa New Zealand. It is estimated that around half of those aged 18 or over do not have a will. Rates of will-making are lower in Māori, Pacific peoples and Asian communities. 

32. Section 77 of the Administration Act sets out the rules for distributing intestate estates consisting of all property other than whenua Māori. Broadly, the rules prioritise the intestate deceased’s partner and children, followed by parents, siblings, grandparents, aunts and uncles (by blood) and cousins. When none of the specified family members are alive to succeed, the Crown will take the estate as bona vacantia (ownerless goods). Intestate succession to whenua Māori is governed by TTWMA. 

33. The intestacy provisions in the Administration Act are old and have not been recently updated. We are concerned the distribution of intestate estates provided for under section 77 does not: (a) reflect contemporary public attitudes and expectations; (b) respond to the growing number of blended families; (c) align with a surviving partner’s relationship property entitlements; and (d) conform to modern legislative drafting standards. 

34. Additionally, the intestacy regime does not reflect tikanga Māori. For example, certain relationships like whāngai are not recognised. 

35. We conclude that the intestacy regime should be reformed. Revised provisions governing the distribution of intestate estates should be continued in the Administration Act (new intestacy provisions). The objective of the new intestacy provisions should be to reflect what most people who die intestate would do with their estate had they made a will. The Crown should facilitate tino rangatiratanga in relation to the intestacy regime, principally through excluding taonga from the state law rules of intestate succession, making provision for tikanga to determine when people in whāngai relationships should succeed in an intestacy, and facilitating tikanga-based resolution processes for whānau wishing to agree to a different distribution of the estate than that provided in state law. 

36. Where the deceased intestate (the intestate) is survived by a partner from a qualifying relationship, we recommend that the partner should continue to succeed. We recommend, however, that the prescribed amount to which the partner is entitled when there are descendants or parents of the intestate should be repealed. Instead, a surviving partner’s entitlement should be based in all cases as a proportion of the estate regardless of the size of the estate. In addition, the surviving partner should take the intestate’s “family chattels”, which should have the same definition as “family chattels” under the new Relationship Property Act we recommended in the PRA review. 

37. Where the intestate is survived by their partner but no children or descendants, the partner should continue to take the entire estate. Where, however, the intestate is survived by their partner and children, we recommend the introduction of new rules to respond to the growing numbers of blended families. The rules should provide that, where the intestate’s children are from the relationship with their surviving partner, the partner should take the entire estate. Where the intestate has one or more children from another relationship, the partner should take the family chattels and 50 per cent of the remaining estate. The intestate’s children should share evenly in the remaining 50 per cent. The rationale for this approach is that, where the partner is also the parent of the children, it is reasonable to expect they will pass the intestate’s wealth to the children by providing for them during their life and/or on their death. It also avoids fragmenting the estate in a way that may negatively affect the surviving partner. If the surviving partner is not the parent of the intestate’s children, it is less likely that the partner would act as a conduit for the intestate’s children. There is more reason to ensure that the children receive entitlements from the estate at the time of the intestate’s death.

38. Where the deceased is survived by their children but no surviving partner, we recommend the rule continue that the children share evenly in the whole estate. Where a child died before the intestate, we recommend that that child’s share is distributed evenly between their own children (the deceased’s grandchildren). This is known as per stirpes/by family distribution and is the current law. We consider this should continue to apply to all situations where a descendant’s parent has predeceased the intestate.

39. The children who are eligible to succeed in an intestacy should include the individuals considered by law to be the intestate’s children. Stepchildren and other classes of children for whom the intestate may have accepted parental responsibilities should not be included. Although the intestate may have wished to provide for these accepted children, extending the definition of child or descendant would overcomplicate the law, create practical uncertainties and establish an unreasonable responsibility for administrators.

40. People in whāngai relationships should be eligible to succeed in an intestacy when this accords with the tikanga of the relevant whānau. The share of the estate that the individual will receive should be determined according to the default intestacy rules. 41. Where the intestate leaves no partner nor descendants, we recommend that the estate is distributed to the intestate’s parents. If there are no surviving parents, the siblings of the intestate should share the estate, passing to the siblings’ descendants according to per stirpes/by family distribution. If there are no surviving siblings or their descendants, the intestate’s grandparents or their descendants should share the estate. 

42. Where no relative eligible to succeed in an intestacy survives the intestate, the Crown should continue to take the estate as bona vacantia. It is rare for estates to vest in the Crown as bona vacantia. The Crown should continue to have discretion to distribute the estate to certain parties upon application. We recommend that this includes other organisations, groups or people. This should enable hapū and iwi, charities or other community groups to apply to The Treasury to receive that money. 

AWARDS, PRIORITIES AND ANTI-AVOIDANCE 

Property claimable 

43. Under the current law, a surviving partner’s relationship property entitlements will be met from the relationship property of the estate. Awards the court makes under the FPA and TPA are sourced rateably across the estate. However, under the PRA, FPA and TPA, the court has discretion to exonerate any part of the estate from an award. 

44. We recommend that these rules should continue with some modification. As recommended in Chapter 4, a relationship property award to a surviving partner should “top-up” the gifts they receive under a will to the full extent of the surviving partner’s relationship property interest. This top-up amount should be sourced from the relationship property of the estate unless the court orders otherwise. 

Priorities 

45. Under the current law, awards under the PRA are made from the net estate after creditors’ claims are satisfied, subject to a partner’s protected interest in the family home, which takes priority over the deceased’s unsecured creditors. Similarly, awards under the FPA are made from the net estate. In contrast, awards under the TPA are made from the gross estate. Those with successful claims against an estate under other statutes, common law and equity will be regarded as unsecured creditors of the estate. As such, they will take priority over awards under the PRA and FPA. 

46. We recommend the general priority given to creditors should continue. In addition, we recommend that awards under the testamentary promise cause of action under the new Act should be met from the net estate. 

47. Awards under the PRA take priority over FPA claims and TPA awards. The FPA and TPA do not address which awards are to take priority over the other. The courts have taken the view, however, that neither Act takes priority, instead resolving the question on a case-by-case basis. We recommend this order of priority should continue under the new Act. 

Anti-avoidance 

48. The court’s power to make awards under the FPA and TPA only applies to the property of the estate. Under the PRA, the court has powers to make relationship property orders by accessing trust property in some circumstances and recovering property disposed of to defeat a partner’s rights. 

49. There are, however, several ways in which the property a person owned during their life will not form part of their estate when they die. For instance, the property the deceased co-owned as joint tenant will accrue to the remaining joint tenant(s) by survivorship on the deceased’s death. The deceased may have disposed of property before their death, such as transferring property on trust, which had they not, would have remained in their estate on their death. Because the court’s powers are generally limited to the property of the estate, awards to claimants under the PRA, FPA and TPA may be frustrated by property falling outside the estate. 

50. We conclude that having no or limited ability to recover property from outside the deceased’s estate undermines the rights that the new Act would purport to give claimants. Some form of anti-avoidance is therefore justified. We recommend the new Act contain provisions that would enable the court to recover property where the property:

(a) has been disposed of with intent to defeat an entitlement or claim under the new Act; or 

(b) was a property interest the deceased owned as joint tenant that has accrued to the remaining joint tenant(s) by survivorship with the effect of defeating an entitlement or claim. 

51. The first ground is based on long-standing provisions in other legislation, including the PRA, that allow for the recovery of property disposed of to defeat others’ rights. The second ground responds to the particular defeating effect caused by joint tenancies. Joint tenancies can be a mechanism for ensuring a designated person receives a benefit from the deceased in a similar way to if the deceased had made a gift in their will to that person. The caselaw shows that joint tenancies often defeat rights against a deceased’s estate. Joint tenancies were also raised as a particular issue in consultation. 

52. When either ground applies, the court should have power to order that the recipient of the property: (a) transfer the property or part of it to the estate; or (b) pay reasonable compensation to the estate. 

53. The court would only recover the property necessary to satisfy the award it wished to make under the new Act. The court should not order the recovery of property under the anti-avoidance provisions if a recipient of the property received it in good faith and provided valuable consideration. The court should also have discretion whether to order the recovery of property where the recipient received it in good faith, and it is unjust to order that the property be recovered. 

USE AND OCCUPATION ORDERS 

54. Individuals who relied on the deceased for housing or household items may suffer hardship when personal representatives are required to distribute the estate under the terms of the deceased’s will or the intestacy regime. 

55. Under the PRA, the court has powers to grant a surviving partner occupation of the family home or other premises forming part of the relationship property. It may also vest a tenancy in one partner. The court has additional powers to grant a partner temporary use of furniture, household appliances and household effects. 

56. We recommend that similar powers should exist under the new Act. A court should be able to grant an occupation order to a surviving partner or a principal caregiver of any minor or dependent child of the deceased. Where the deceased left any minor or dependent child, the new Act should contain a presumption in favour of granting a temporary occupation or tenancy order to the principal caregiver of the child for the benefit of that child. The order will allow the partner or children use of the home for a period as they transition to a life in which they are not dependent on the deceased’s estate for accommodation support. In exercising its powers, the court should consider the best interests of the deceased’s minor or dependent children as a primary consideration. This approach is consistent with the recommendations in the PRA review, the requirements of the United Nations Convention on the Rights of the Child and the tikanga relating to whanaungatanga, manaakitanga and aroha that requires the needs of tamariki are met. 

57. While the home over which an occupation order is sought will often be part of the deceased’s estate, it is possible that in some instances it will not be. To strengthen the court’s powers to address surviving partners’ and minor and dependent children’s accommodation needs following the deceased’s death, we include recommendations for the court’s powers to extend to homes held as joint tenancies and homes held on trust. 

58. We recommend the court should have the power to make furniture orders in favour of a surviving partner or a principal caregiver of any minor or dependent child of the deceased, either independently of or ancillary to any occupation or tenancy order. When making furniture orders, the court should consider the best interests of the child as a primary consideration. 

59. When the court makes a use or occupation order, it is appropriate for the court to have discretion to order that the recipient of the order pay occupation rent. Occupation rent compensates those beneficiaries or claimants who have had their entitlements under the will or intestacy deferred and is an effective means of achieving balance between the different parties’ interests. 

CONTRACTING OUT AND SETTLEMENT AGREEMENTS 

60. Part 6 of the PRA provides that partners and those contemplating entering a relationship may enter an agreement that governs the division of their relationship property rather than the following the provisions of the Act (contracting out agreements). Partners may also enter an agreement to settle any differences that have arisen between them concerning property (settlement agreements). To enter a valid contracting out or settlement agreement, the PRA requires partners to follow procedural safeguards, requiring the agreement to be in writing and each partner to obtain independent legal advice from a lawyer who then witnesses and certifies the agreement. The court retains residual power to set aside agreements that would cause serious injustice. 

61. In contrast, the courts have held that people cannot contract out of the FPA because it is paramount as a matter of state policy and potential claimants cannot surrender their rights through agreements. Nevertheless, we understand that parties routinely enter deeds of family arrangement to settle FPA claims. 

62. Allowing people to contract out of entitlements and claims regarding an estate recognises the mana of the parties to the agreement. It is also important that the state law relating to contracting out and settlement agreements does not impose undue barriers for parties wishing to resolve matters pursuant to tikanga. 

63. It is problematic, in our view, that the current law prevents parties from contracting out and settling matters under the FPA, but then allows it for matters under the PRA. This law undermines parties’ freedom to arrange their affairs in the manner they wish, promoting a certain outcome. The law can also create anomalies, such as allowing a partner to claim property through the FPA that is designated as the deceased partner’s separate property under a contracting out agreement. It is also unclear how the PRA’s provisions relating to contracting out apply when partners enter mutual wills arrangements. 

64. In general, we favour an approach that enables adults to contract out of the entitlements and claims they may have in respect of someone’s estate. We believe this approach is consistent with the principles underpinning contemporary state law in Aotearoa New Zealand that adult parties generally have autonomy to arrange their property matters with each other in the way they would like. 

65. Consequently, we recommend that partners or people contemplating entering a relationship should be able to enter contracting out agreements that deal with relationship property entitlements and family provision claims under the new Act. Recognising that these agreements will involve parties who do not approach one another as contracting parties at arm’s length, the parties should comply with the following procedural safeguards in order for the contracting out agreement to be valid:

(a) The agreement must be in writing. 

(b) Each party to the agreement must have independent legal advice before signing the agreement. 

(c) The signature of each party to the agreement must be witnessed by a lawyer. 

(d) The lawyer who witnesses the signature must certify that, before the party signed, the lawyer explained to that party the effect and implications of the agreement. 

66. We recommend the new Act should make no express provision for contracting out of adult children’s family provision claims. This will not preclude parties from entering agreements. Instead, parties will be able to enter agreements that do not otherwise comply with the procedural safeguards that we recommend should apply to contracting out agreements between partners. This approach will enable the court to consider the terms of any agreement between a parent and adult child when deciding whether to order family provision. There should, however, be no ability to contract out of family provision claims that may be brought by the deceased’s minor children. 

67. We recommend that mutual wills arrangements should be subject to same procedural safeguards as contracting out agreements regarding claims against estates. That is, if the parties agree not to revoke their wills or deal with property inconsistently with them, that agreement should be recorded in writing, their signatures should be witnessed, and the lawyers advising each partner should certify the agreement. The advantage of this approach is that it ensures consistency with the contracting out requirements that partners should observe when making agreements about their entitlements and rights to each other’s estates. It will also resolve many of the arguments that currently arise about whether the parties have in fact entered a mutual wills arrangement. 

68. When parties are in a dispute relating to entitlements or claims under the new Act or entitlements in an intestacy, we recommend that there should be the ability to settle the dispute by agreement without the need for court involvement. We do not recommend that the legislation should impose procedural safeguards in the same way as for contracting out agreements. Instead, it should be a matter of judgement for the parties, particularly the personal representatives, as to how the agreement should be entered, as it is under the current law. If, however, the dispute involves parties who are unascertained, minors or persons deemed by law to lack capacity, we recommend that the new Act should prescribe a process consistent with the alternative dispute resolution provisions of the Trusts Act 2019

69. For both contracting out and settlement agreements under the new Act, we recommend that the court retains power to vary or set aside agreements that would cause serious injustice. A court should also be able to recover property that is the subject of a contracting out agreement or settlement agreement if it would be captured by the anti-avoidance provisions we recommend in Chapter 8. 

JURISDICTION OF THE COURTS 

70. Every application under the PRA must be heard by te Kōti Whānau | Family Court (the Family Court). Under the FPA and TPA, however, the Family Court and te Kōti Matua | High Court (the High Court) have concurrent first instance jurisdiction. Claims under the FPA and TPA that relate only to Māori freehold land must be made in te Kooti Whenua Māori | Māori Land Court (the Māori Land Court). 

71. The High Court has jurisdiction to determine proceedings relating to testamentary matters and matters relating to the estate of deceased persons, including matters relating to intestate estates. The Māori Land Court has jurisdiction in relation to intestacy over Māori freehold land. 

72. There is a fundamental question about which court or courts are the most appropriate to hear and determine claims under the new Act. We recommend that the Family Court and High Court should have concurrent jurisdiction to hear and determine all claims under the new Act. We favour the Family Court having first instance jurisdiction because of the family nature of succession matters. However, there may be situations where it is appropriate for the High Court to hear matters at first instance, such as where the proceedings are complex or contain matters for which the High Court currently holds exclusive jurisdiction. If proceedings relating to the same matter are before both Courts, the High Court should hear the claim. Both Courts should have the power to transfer proceedings to the High Court and the new Act should contain directions on when proceedings should be transferred to the High Court. 

73. We recommend that the High Court and the Family Court have concurrent jurisdiction to hear and determine matters relating to eligibility in intestacies. The High Court should continue to hold exclusive jurisdiction for all other issues concerning the administration of an intestate estate and other related matters. 

74. We recommend that the new Act should permit appeals as of right against interlocutory decisions that can have a significant impact on the parties’ rights and obligations. For all other interlocutory decisions, claimants should obtain leave to appeal from the Family Court or High Court. This recognises that, in exceptional cases, an interlocutory decision of a procedural nature may also affect parties’ substantive rights and liabilities, while also minimising risks that parties unduly protract proceedings with appeals. 

75. For matters involving taonga, we recommend that the Family Court, High Court and Māori Land Court have concurrent jurisdiction. This recommendation is supported by our recommendations that, where needed, Family Court and High Court judges should continue to receive education on tikanga Māori and that the courts be able to appoint a person to inquire into and advise on matters of tikanga Māori. We also recommend that the Family Court and the High Court have power to transfer proceedings or a question in any proceedings to the Māori Land Court.  

76. We received feedback supporting an extended role for the Māori Land Court in relation to granting probate and letters of administration. The Government should consider whether the Māori Land Court should have greater jurisdiction to grant probate and letters of administration regarding matters already before the Māori Land Court where the applications to grant probate and letters of administration are uncontested. 

RESOLVING DISPUTES IN COURT 

Limitation periods 

77. Currently, parties generally have 12 months to commence proceedings under the PRA, FPA and TPA. We conclude that significant changes to the limitation periods for commencing proceedings are not required. We recommend that applications under the new Act should be made within 12 months of the grant of administration in Aotearoa New Zealand subject to the Court’s ability to extend that time provided that the application is made before final distribution of the estate. Final distribution should be deemed to have occurred where all estate assets are transferred to those beneficially entitled. 

78. Where an estate can be lawfully distributed without a grant of administration, slightly different rules should apply. Generally, the applications should be made within 12 months of the date of death. Personal representatives should continue to be protected against personal liability from claimants under the new Act where they distribute any part of the estate in the circumstances prescribed in section 47 of the Administration Act. This protects personal representatives when they make distributions six months after the grant of administration or when they are distributed with the consent of that person. 

Disclosure of information 

79. We recommend that the new Act should include an express duty on personal representatives to assist the court, including by requiring personal representatives in proceedings to place before the court all relevant information in their possession or knowledge. In proceedings for the division of relationship property, the surviving partner and the personal representative should have a duty to disclose each partner’s assets and liabilities. To assist parties to make available all appropriate information, we recommend that affidavit forms are created for applications under the new Act. 

Evidence 

80. Currently an anomaly exists about how evidence is given in TPA proceedings. In the High Court, evidence is presumed to be given orally unless the judge directs otherwise. In FPA and PRA proceedings and in TPA proceedings in the Family Court, evidence is usually given by affidavit. We recommend that affidavit evidence is preferred across all claims under the new Act unless a judge directs otherwise. 

Representation of minors, unascertained parties and persons deemed by law to lack capacity 

81. It is not always clear under the current law how the interests of minors, unascertained parties or parties deemed by law to lack capacity should be given effect. We think that it is important that these parties have their interests represented. The court should appoint representatives for such parties in proceedings under the new Act to facilitate this. 

Costs 

82. Costs in proceedings are at the discretion of the court. Historically, in FPA proceedings it was common for the court to order costs to be paid from the estate. That approach has been criticised for sometimes encouraging unmeritorious claims. We consider that the court’s current flexible approach to awarding costs is appropriate for the proceedings under the new Act. The new Act should confirm the court’s power to make cost orders as it thinks fit. 

83. The new Act should also confirm the court’s power to impose costs for non-compliance with procedural requirements. Parties to proceedings should be helped to understand what is required of them and should have it signalled to them the potential repercussions for failing to meet these requirements. 

84. In the PRA review, we recommended the establishment of a scale of costs for relationship property proceedings. We see merit in such a scale being established for claims under the new Act too. 

Tikanga Māori and dispute resolution in court 

85. We have received feedback that many Māori feel that the Māori Land Court is a more attractive forum for resolving disputes than the general courts. This can be attributed to a range of factors but the expertise of judges and staff in tikanga and te reo Māori in particular can make the Māori Land Court a supportive and positive place to go for dispute resolution. There is a drive to improve diversity amongst the judiciary and to educate judges to understand and appreciate te ao Māori through education programmes such as the ones offered by Te Kura Kaiwhakawā | Institute of Judicial Studies. Education on tikanga Māori, including on tikanga Māori specific to whānau, should be an important aspect of education for Family Court and High Court judges who are not already knowledgeable in these areas. Additionally, the courts should be able to appoint a person to inquire into such matters the court considers may assist it to deal effectively with the matters before it, including matters of tikanga Māori, and this power should be specified in the new Act. 

RESOLVING DISPUTES OUT OF COURT 

86. A significant proportion of claims against estates are resolved out of court. There are good reasons to promote the resolution of matters outside of court. It is generally quicker and less expensive. It can result in better outcomes for the families involved because resolution processes can focus on reaching agreement rather than adversarial court proceedings. The most common ways of resolving disputed claims against estates out of court are: (a) party or lawyer-led negotiation; (b) mediation; (c) arbitration; and (d) judicial settlement conferences. 

87. The Trusts Act provides that the trustees or the court may refer a matter to an “ADR process”, even if there is no provision in the terms of the trust that would allow for it. If a matter is one in which the only parties are the trustees or beneficiaries, it can be referred to ADR even if there are beneficiaries who are unascertained or are deemed by law to lack capacity. The court must appoint a representative who must act in the best interests of those beneficiaries. Except in relation to arbitral awards, the court must approve an ADR settlement in order for it to take effect. 

88. Part 3A of TTWMA provides for a statutory mediation process to assist parties to resolve any disputed issues quickly and effectively between themselves in accordance with the law, and as far as possible, in accordance with the relevant tikanga of the whānau or hapū, for both the process and the substance of the resolution. The mediator can follow any procedures the mediator thinks appropriate. 

89. Differences between the PRA, FPA and TPA regarding out-of-court resolution mean that it is unclear whether parties are able to comprehensively settle claims against an estate without going to court. There are also questions regarding the recognition of tikanga-based dispute resolution in the new Act and safeguards for parties who are unascertained, minors or persons who are deemed by law to lack capacity. 

90. In our view, out-of-court resolution may be particularly beneficial for the types of family disputes that would arise under the new Act. A process that allows the parties to arrive at an agreed settlement may be more helpful at diffusing family hostilities than an adversarial court process. Out-of-court resolution processes may also allow other family matters to be addressed that may not be strictly relevant to the legal issues before the court. We therefore recommend that the new Act should expressly endorse out-of-court dispute resolution and tikanga-based resolution. In addition, the new Act and the Administration Act should provide that parties can enter an agreement to settle any differences arising between them (see Chapter 10). 

91. We recommend the new Act prescribe a process that is consistent with the alternative dispute resolution provisions of the Trusts Act for parties who are unascertained, minors or persons deemed by law to lack capacity. The process will require the court to appoint representatives for those parties to look after their best interests. The representative would be able to agree on their behalf to participate in an out-of-court resolution process and agree to any settlement reached. Court approval of the settlement should be required (unless the settlement is an arbitral award) and the court should be able to vary or set aside any agreement that would cause serious injustice. 

92. Our recommendations about settlement agreements mean that parties could engage in an out-of-court or tikanga-based dispute resolution process of their own accord, without court involvement, and come to a resolution. It may also be beneficial for the Government to consider whether the mediation process under Part 3A of TTWMA could have broader application. 

ROLE OF PERSONAL REPRESENTATIVES 

93. “Personal representatives” is the term we use to refer to executors of a will or administrators of an intestate estate. Personal representatives have a duty to administer the estate and distribute it according to the deceased’s will or the intestacy regime. 

94. Personal representatives have a duty to be even-handed between beneficiaries. However, the extent of their duty to notify potential claimants is not clear under the current law. We recommend that this is clarified in the new Act. The new Act should require a personal representative to give notice in a prescribed form to a surviving partner or any person that the personal representative could reasonably apprehend was in an intimate relationship with the deceased at the time of death. The prescribed notice should contain information about relationship property entitlements and family provision claims, criteria for qualifying relationships, relevant time limits and obtaining independent legal advice. We think that a similar duty should apply in respect of children if the Government accepts Option Two of our family provision proposals limiting eligible children to those under 25 or who meet the definition of disabled within the new Act. 

95. Personal representatives will be the named defendants in proceedings against the estate but the role that they are expected to take may differ depending on the nature of the claim. For example, in FPA proceedings, the personal representative is generally expected to maintain a neutral role but, in PRA and TPA proceedings, they are often expected to actively defend claims. In our view the varied nature of claims makes it difficult to prescribe in statute the role that personal representatives should take in all proceedings. We instead recommend that the new Act includes a duty on personal representatives to place before the Court all relevant information in their possession or knowledge. 

96. At times, personal representatives may have a conflict of interest. It is not unusual, for example, for a personal representative to be a claimant against the estate or a beneficiary who intends to defend a claim as a beneficiary. In most cases, personal representatives and their legal counsel will know how to manage the conflict consistently with their legal duties and there is no need for the new Act to provide further guidance. In some cases, the court will need to intervene to remove or replace a personal representative. The current process for doing so is cumbersome because it requires a separate application to the High Court under the Administration Act. We recommend that this power be contained within the new Act so both the High Court and the Family Court are able to remove or replace personal representatives where necessary or expedient. 

CROSS-BORDER MATTERS 

97. Conflicts of laws may arise when the deceased has property in more than one country or is closely connected to more than one country. Currently, Aotearoa New Zealand’s choice of law rules for administration and succession are primarily governed by common law. Matters of administration (including claims under the TPA) are governed by the law of the country in which the assets are located and a grant of administration is made. Succession to movable property is determined by the law of the deceased’s domicile whereas succession to immovable property is determined by the law of the country where the property is situated. This includes claims under the FPA. Similar rules set out in the PRA apply to relationship property disputes, however, the PRA is silent on which country’s laws apply when the PRA does not apply. This creates uncertainty and risks leaving gaps in the law if no other country’s law applies. 

98. The distinction between movable and immovable property is heavily criticised. It prevents the succession of an estate being dealt with under a single legal regime. In FPA cases it can frustrate the court’s ability to award the level of provision the court thinks fit. In intestacy, it might result in a windfall to a partner because the partner is entitled to more than one statutory legacy. 

99. It can be difficult to identify the deceased’s domicile and may come as a surprise in some cases, particularly because acquiring a new domicile relies on the individual’s intention to reside permanently in that country. The different treatment between the TPA and the FPA also places artificial constraints on courts when making awards. 

100. We conclude that the law that should be applied to the succession of a deceased’s estate should be the law of the deceased’s last habitual residence, the country with which the deceased had the closest and most stable connection. This would be determined with reference to an overall assessment of the specific circumstances of the case, including the deceased’s social, professional and economic ties to the country. The inquiry should engage the most relevant law for that case to give effect to the interests of the deceased, of people close to the deceased and of creditors. Disputes over relationship property following the death of a partner should also be governed by the law of the deceased’s last habitual residence to avoid fragmenting the law governing a deceased’s estate. 

101. We recommend that habitual residence is used instead of domicile when determining the relevant law applying to the construction or interpretation of a will and the capacity to make a will or take under a will. We also recommend that the Government considers substituting “domicile” with “habitual residence” in section 22 of the Wills Act 2007. 

102. We think that it is important for courts to have some flexibility to interpret or adapt rules where the combination of choice of law rules or decisions taken in different jurisdictions produces an unacceptable outcome that would differ from the common outcome in a purely domestic case. We also recommend that courts retain the power to refuse to apply a foreign rule where doing so would be contrary to public policy. 

103. Consistent with our recommendations in the PRA review, we consider that partners should be entitled to agree that the law of a nominated country should apply to some or all of their property on death. Agreements should need to satisfy certain requirements, including that the agreement is valid under the law of the country that is chosen under the agreement, or under the law of the country with which the relationship had its closest connection. Courts would also retain discretion not to give effect to a valid agreement where doing so would be contrary to public policy. 

104. The choice of law rules should not apply to whenua Māori or taonga, meaning that the succession to these should always be determined according to the law of Aotearoa New Zealand. 

105. If property is situated outside Aotearoa New Zealand and is immovable (for example, land), a court should be able to make orders against a person rather than against the property directly. The court may order the person to transfer property or pay a sum of money to another party. We recommend that the new Act confirms that the Moçambique rule has no application in matters covered under that Act. We do not recommend bespoke jurisdictional rules be included within the new Act, nor do we recommend that the new Act or the Wills Act refer to the application of renvoi. 

OTHER REFORM MATTERS 

The need for education about the law relating to succession 

106. The low levels of awareness and understanding of the law relating to succession, both among the public and professional advisers, has been a key theme emerging from our research and consultation throughout this review. We think there is a need for greater awareness and education about the law related to succession and the importance of making wills. We recommend the Government consider ways to improve awareness and understanding of the law and the new Act. 

Power to validate wills 

107. Section 14 of the Wills Act provides the High Court with the power to validate a document that appears to be a will but does not comply with the validity requirements within the Wills Act. The reference to “document” in section 14 is criticised because it has generally prohibited the validation of audio or visual recordings of testamentary intentions. We recommend the Government consider reviewing the validation powers under section 14. 

Ōhākī 

108. Loosely understood as an oral will, the Māori practice of ōhākī has not been recognised in state law. This fails to recognise tikanga as an independent source of rights and obligations in Aotearoa New Zealand. We recommend the Government consider recognising ōhākī as an expression of testamentary wishes enforceable under state law. 

Sections 18 and 19 of the Wills Act 

109. Sections 18 of the Wills Act revokes a will in its entirety when a person marries or enters a civil union and has not made that will in contemplation of the marriage or civil union. Section 18 presumes that the will would no longer reflect the person’s testamentary intentions, failing to take into account that today many couples are in a de facto relationship before they get married. We recommend that section 18 is repealed. 

110. When a couple divorces, section 19 of the Wills Act revokes certain dispositions and powers given to the former spouse in the will on the assumption that the deceased would no longer want these to apply. We think this is a reasonable assumption to make. Section 19, however, does not apply to dispositions made to de facto partners. We recommend section 19 be amended to apply two years after the point when the partners in any qualifying relationship type ceased to live together in a relationship. This is because we have heard that it is not uncommon for couples to separate but not get around to formally divorcing or updating their wills. 

Multi-partner relationships 

111. The PRA is based on the notion of “coupledom”. Although the Act has special rules for when a partner maintains two separate relationships, it does not apply to multi-partner relationships. Multi-partner relationships may share many of the hallmarks of a qualifying relationship. However, we do not recommend any change at this time to recognise multi-partner relationships in the property sharing regime. We think that such changes would need to be considered within a broader context about how family law should recognise and provide for adult relationships that do not fit the mould of an intimate relationship between two people. We recommend further research and consultation be undertaken. 

Distributing an estate without probate or letters of administration 

112. Section 65 of the Administration Act provides that certain entities, such as superannuation funds, banks, or the employer of the deceased, can pay money to certain relatives of the deceased, such as a surviving partner, without the need for a grant of administration. The amount of money cannot exceed the prescribed amount, currently $15,000. Additionally, Public Trust and Trustee companies have powers to distribute estates without a grant of administration, where the total value of the estate does not exceed $120,000. We have heard that the administration process is complex and costly, and people would like to see these monetary thresholds increased. We recommend that the Government consider whether to increase the threshold for distributing estate money without a grant of administration. 

Social security and the Family Protection Act 

113. Section 203 of the Social Security Act 2018 enables Te Manatū Whakahiato Ora | Ministry of Social Development to refuse to grant a benefit, grant a benefit at a reduced rate or cancel a benefit already granted where a person has failed to take steps to advance a tenable FPA claim. It is an historic power that is now rarely used and we recommend it be repealed.