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Policy Development Process

InternetNZ's Policy Development Process.

Note: The following information should be read in conjunction with the Policy Advisory Group Terms of Reference.

Identification of Policy areas and Scope

  • InternetNZ will only develop policy positions or generate submissions which are consistent with its constitutional objects and objectives, or its current strategic plan.
  • Any policy or position is to be broadly aimed at “protecting and promoting the Internet for New Zealand”, InternetNZ’s mission. It will in all cases be consistent with our vision: “The Internet, open and uncapturable”.
  • If an issue arises where InternetNZ input is sought but which appears to be outside the Society’s mission, vision, objects or objectives, it is possible to create a response but in all cases, such a response must be discussed with the InternetNZ Council before being lodged, whatever the specific requirements outlined below.

Consultation process

  • InternetNZ’s process will maintain and enhance the development of our reputation as being open and transparent.
  • Different processes apply for development of submissions on specific issues, and for the development of broader positions for the Society to advocate on over time. These are detailed separately below.
  • If there is any lack of clarity over which process applies to a given issue, the Executive Board will provide guidance. InternetNZ Council may ask the EB to reconsider its decision if it does not agree with it.


  • As soon as notice of a request for a submission is received, staff will create a “call for comment” to advise the following groups of it and welcome any input on the issue:
    • InternetNZ business units
    • InternetNZ Policy Advisory Group
    • InternetNZ Members
  • Such a “call for comment” will set out where appropriate the high-level principles that will drive the submission.
  • Input in response to a “call for comment” will be due with the office no later than one week after the call is issued.
  • A “Submission Framework” that sets out how the Submission will be drafted and the principles to be advanced will be finalised after this consultation, and sent to the Executive Board for signoff. Once signed off, this document will guide further work on preparing the submission. Reasonable time will be given for signoff, but silence will be considered to be assent: if no feedback is received the submission will proceed as outlined in the Framework.
  • If the submission is a large and complex one, the Executive Director may appoint a working group to work with staff to develop a submission. Such working group members will be drawn from the PAG, or from whatever other source the Executive Director feels is appropriate. At least one member of any such working group will be a member of the PAG.
  • In the case of the EB determining the issue for submission is large and complex, it may recommend holding a public workshop and it may hold a workshop for Council members to have input on the issue.
  • Staff drafting a submission may choose to circulate a draft submission to any individuals or organisations for comment. This should be regularly done in the case of large/significant submissions. At least the same entities which were consulted as for the initial call for comment will be sent any such draft.
  • Any feedback to such a draft will be required to be received generally no later than five working days before the intended approval date of the submission. Approval processes are dealt with below.

Broader policy statements

  • Where a broader piece of work is contemplated, there will be two broad calls for input:
    • The first will be the same as that set out for a submission.
    • The second will be a public workshop or seminar, to invite those stakeholders interested in the issue to attend in person or by remote means, to offer their input and ideas for consideration.
  • A draft of the proposed statement will be circulated at least one week before approval is intended, as a final chance for input, again to the same parties as those set out for a submission.

Other issues

  • InternetNZ staff and members of the Executive Board are not obliged to follow this PDP in preparing remarks to give to conferences, but should consider doing so for any papers to be presented at conferences.
  • Media/public comment and interviews do not go through the PDP.
  • Positions of advocacy at international and regional forums and events do not go through the PDP.
  • InternetNZ contractors are not on their own initiative required to follow this PDP: it is the responsibility of InternetNZ to ensure that the requirements of the PDP are adhered to.
  • Letters to decision-makers do not go through the PDP.
  • In all these cases, the positions represented as those being InternetNZ’s must be commonly held positions in the Society, and consistent with policy and earlier positions already developed and agreed.

Approvals Process

The purpose of the approvals process is to ensure that all submissions lodged or policy positions published on InternetNZ’s behalf have been reviewed and agreed by an appropriate authority within the organisation.


  • Submissions that remain consistent with the Submission Framework approved by the Board require no further Board approval.
  • A penultimate staff draft of the submission will be provided to the Policy Advisory Group no fewer than four working days before the submission is due, with any feedback due no later than 5pm the working day before the due date.
  • Staff will finalise the submission consistent with the Submission Framework and any final feedback on the day the submission is due.
  • Staff will lodge the submission one hour before submissions close, and at the same time provide a copy of the final document to the EB, the PAG and the Council.

Broader policy statements

  • As any such statement is on InternetNZ’s own timeline, the “publication date” referred to here is at InternetNZ’s discretion and may change.
  • A penultimate staff draft of the document will be provided to the Policy Advisory Group and the InternetNZ Council no fewer than ten working days before publication date, with any feedback due no fewer than six working days before the publication date.
  • A final staff draft will be provided to the Executive Board for review no fewer than four working days before publication day, with any feedback due no later than 5pm two working days before publication day.
  • The Executive Board members will be asked to indicate their assent that the statement is ready for publication over at least a 24 hour period, which finishes at 10am on the intended publication day.
  • Publication will be delayed if a majority of the EB does not indicate its assent.

External Review

  • Major submissions and policy statements will normally be reviewed by an external source which did not participate in the preparation of the submission, to ensure the quality of the document.
  • The staff should demonstrate to the Executive Board that such external review has been undertaken, when they submit work to the Executive Board for approval under this PDP.
  • The Executive Board acknowledges that project budgets will need to be adjusted to allow for such review, which will not always be possible on a non-commercial basis.


  • All InternetNZ submissions and policy documents will be published on the InternetNZ website.
  • In the first instance, submissions will be published the next working day after they are lodged.
  • If the submission is to a consultation where immediate publication is specifically against the rules of the consultation, InternetNZ will respect the rules of the consultation in terms of publication date.
  • InternetNZ is not able to lodge secret submissions, and cannot lodge submissions with any commercially sensitive information. Once a submission is finalised, there is only one version, and all of that version will be published.
  • If for any reason any part of any submission is deemed to be in confidence, and therefore cannot be published, the approval of the Executive Board and of the InternetNZ Council must be sought before any such submission is lodged.
  • When a final submission is published, the members will be advised of publication on the members-discuss list, if not otherwise notified.
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