Formal compliant against MPI

To: [email protected],

Hello all,

Please accept this correspondence as a formal complaint regarding the conduct of the Ministry for Primary Industries (MPI) in relation to several investigations and associated proceedings involving persons connected to matters we have been assisting with.

This complaint is not presently directed at the ultimate determination of any prosecution itself, but rather at the apparent administrative conduct, proportionality, evidential handling, and use of personal information by MPI investigators and associated agencies.

The concerns raised are serious and ongoing.

1. Apparent Overreach in Access to Personal Information

There appears to have been extensive access to personal communications, telephone-related material, banking information, and associated third-party data despite repeated requests for clarification as to:

• the lawful authority relied upon;
• the necessity and proportionality of that access;
• the evidential relevance of the material obtained;
• the safeguards applied to prevent excessive or irrelevant collection; and
• whether all material gathered was directly connected to identifiable offending.

The degree of access appears disproportionate when compared with the nature of the allegations involved.

1. Lack of Transparency Regarding Evidential Basis

Repeated requests have been made seeking clarification of:

• the actual evidential foundation relied upon;
• whether assumptions or associative inferences were used;
• the source and chain-of-custody of information;
• the basis upon which warrants or information requests were authorised;
• whether exculpatory or neutral material was preserved and disclosed; and
• what oversight existed regarding the scope of the investigations.

The responses received have frequently been incomplete, redirected, delayed, or non-responsive.

1. Concerns Regarding Investigative Proportionality

The investigations increasingly appear excessive relative to the alleged offending.

In several matters, ordinary activities, communications, and associations appear to have been interpreted in a manner that creates concern about speculative or assumption-based investigation rather than evidence-led investigation.

The cumulative effect creates the appearance of intrusive scrutiny without clear demonstration of necessity, proportionality, or evidential threshold.

1. Administrative Fairness and Accountability Concerns

There is concern that MPI has adopted an overly broad interpretation of investigative authority while avoiding meaningful scrutiny regarding:

• how information was obtained;
• whether all relevant approvals existed;
• what oversight mechanisms were applied;
• whether procedural fairness obligations were met; and
• whether affected parties were properly informed of the basis for investigative actions.

Where clarification has been sought, the response has frequently been to redirect matters elsewhere rather than address the substance of the concerns raised.

1. Public Interest Considerations

This complaint raises broader public-interest concerns regarding:

• the handling of personal information by regulatory agencies;
• proportionality in investigative practices;
• transparency surrounding evidence gathering;
• inter-agency information sharing; and
• whether adequate safeguards exist to prevent unnecessary intrusion into private affairs.

Request for Ombudsman Review

Accordingly, I respectfully request that the Ombudsman consider reviewing:

• the administrative conduct of MPI in these matters;
• the adequacy of responses provided to requests for clarification and disclosure;
• whether investigative powers have been exercised proportionately;
• whether procedural fairness obligations have been met; and
• whether the handling of personal information and associated evidential material meets appropriate standards of accountability and lawful administration.

Please also note that separate concerns regarding information collection, use, retention, and disclosure may additionally be referred to the Privacy Commissioner.

I am willing to provide supporting correspondence, requests for clarification, disclosure requests, and related material if required.

Kind regards,

Tracy Lynch
InLandsAirWater Counsel
PO Box 265
Queenstown