A woman complained to the Office of the Privacy Commissioner after three health agencies refused to disclose her late mother's health information to her. The woman was appointed as an executor of her mother's estate, but another executor had refused authority for the information to be disclosed. The Commissioner considered both section 22F of the Health Act and Rule 11(4) in the Health Information Code and affirmed that as an executor, the woman was her mother's "representative" for the purposes of disclosure. The Commissioner then stated that "[a]n agency does not need the authority of all executors… to release information to one of them. Any agency that receives a request from one executor or administrator should therefore respond as if the request was made on behalf of the deceased individual". The Commissioner also commented that the same was true for guardians of children under 16, noting that an agency could release information to either guardian on their individual request. After receiving the Commissioner's view, the health agencies disclosed the information. Case Note 231747 [2011] NZ PrivCmr 8