How we handle your personal information
1. Your privacy is important to us
We know that how we collect, use, exchange and protect your personal information is important to you and we value the trust you put in us. We believe protecting your personal information and being clear about what we do with it is a vital part of our relationship with you.
This Privacy Policy relates to First Sentier Investors (First Sentier Investors) Australia.
Please be aware that if you are also an investor of one of our overseas entities then their privacy policy will reflect local conditions and legal requirements. Please refer to their privacy policies, for local requirements, which are available through the First Sentier Investors global website: www.firstsentierinvestors.com
Please note that during the course of our relationship with you, we may tell you more about how we handle your personal information. This could be when you complete an application form, or receive terms and conditions or a product disclosure document. When you receive this further information, please consider it carefully. Please also visit our website regularly as we update this policy from time to time.
2. About First Sentier Investors
First Sentier Investors is ultimately owned by Mitsubishi UFJ Financial Group (“MUFG”).
First Sentier Investors includes the following Australian entities, First Sentier Investors (Australia) IM Ltd, First Sentier Investors (Australia) RE Ltd and First Sentier Investors Realindex Pty Ltd.
For more information about First Sentier Investors, including its relationship with MUFG, please see the Who we are section.
3. Information we collect and how we collect it
Information we collect from you
We collect personal information about you when you invest in our financial products, visit our website, contact us or deal with us in some other way. For example,
- When you invest with us we will collect your information through the application form you complete which includes information such as your name and address, phone number, email address, tax file number, bank account details and citizenship. Where you invest in the name of a company or trust, we collect information about key individuals, for example directors, officers and key management personnel.
- When you use our website we may collect information using Cookies however the information we collect does not enable us to identify you.
- If you send us a query or subscribe to receive investment insights or other publications through our website, we will collect your name, email address and communication preferences.
Information we collect from others
We may also collect information about you from third parties, such as:
- Service providers we appoint to administer the business, for example, the unit registry services or custodians of a fund you invest in;
- Public sources, to enable us to verify your identity in accordance with the requirements of the Anti-Money Launder and Counter-Terrorism Financing Act 2006, Foreign Account Tax Compliance Act or the Common Reporting Standards; and
- Parties you appoint to act on your behalf, for example, an accountant, lawyer, financial adviser.
Sensitive information
We do not generally collect sensitive information about you. However if we do, we only do so where we have a clearly identified legal reason to obtain this type of information and we will ask for your consent, unless otherwise permitted by law.
4. How do we use your information?
We collect, use and store your information so that we can provide the financial products and services you have requested, including:
- setting up and administering your investment,
- communicating with you about your investment,
- keeping records as we are required to do by law
We also collect, use and store your information to comply with our legal obligations and assist government and law enforcement agencies or regulators.
We may also use your personal information to identify and tell you about other products or services that we think may be of interest to you. We will only do this with your consent. If you don’t want to receive direct marketing such as investment insights and event invites, you can tell us by using any of the methods set out in section 11.
Gathering and combining data to get insights
Improvements in technology enable organisations like ours to collect and use information to get a more integrated view of our investors and prospective investors, in order to provide better products and services.
First Sentier Investors may combine investor and prospective investor information it has with information available from a wide variety of external sources (for example investment industry databases).
Other First Sentier Investors entities located overseas are able to analyse the data in order to gain useful insights which can be used for any of the purposes mentioned earlier in this section 4.
In addition, other First Sentier Investors entities located overseas may provide data insights or related reports to others, for example to help them understand their investors better. These are based on aggregated information and do not contain any information that identifies you.
5. Who do we exchange your information with?
In the course of carrying out business we may provide your personal information to the following parties for the purposes mentioned in section 4:
other First Sentier Investors entities located overseas
third parties such as:
- Service providers we appoint to administer the business, for example, the unit registry services or custodians of a fund you invest in;
- Parties to whom we outsource certain functions, for example, direct marketing, event companies or media agencies;
- Parties you appoint to act on your behalf, for example, an accountant, lawyer, financial adviser;
- Auditors;
- Government and law enforcement agencies or regulators; and
- Entities established to help identify illegal activities and prevent fraud.
6. When we send your information overseas
Generally, we use systems and service teams located in Australia, however some of our services are located in our global offices.
From time to time we may send your information to recipients overseas, including our offices, to service providers or other third parties who operate or hold data outside Australia. We may also send information overseas to complete a particular transaction, or where this is required by laws and regulations.
Where we do this, we make sure that appropriate data handling and security arrangements are in place. Please note that while Australian law may not apply to some of these entities we include terms in contracts that require the other party to meet the requirements of other regulators around the globe.
Where your information is sent overseas, it may be sent to one of the following countries:
Canada
Cayman Islands
France
Germany
Hong Kong
Ireland (Republic of)
Japan
Luxembourg
Netherlands
New Zealand
Singapore
United Kingdom
United States
7. Keeping your information secure
We keep your records on our premises and systems or offsite using trusted third parties. Our security safeguards include:
- Staff education
We train and remind our staff of their obligations with regard to your information.
- Taking precautions with overseas third parties
When we send information overseas or use third parties that handle or store data, we validate that appropriate data handling and security arrangements are in place.
- System security
We have security controls in place such as firewalls, intrusion detection and virus scanning tools to protect against unauthorised persons and viruses accessing our systems.
When we send your electronic data outside of First Sentier Investors we use dedicated secure networks or encryption.
We follow sound user and access management practices to restrict unauthorised access to our systems and data.
- Building security
We have protection in our buildings against unauthorised access such as alarms, cameras and security passes.
- Data retention
We keep information only for as long as required to provide services to you, and in accordance with legal and regulatory requirements
8. Accessing, updating and correcting your information
You can ask for access to your information by calling us, going online or contacting your relationship manager.
Is there a fee?
We do not charge you a fee to request access to your personal information. However, in some cases we may charge you a fee to access your personal information. We will advise you beforehand, so that you can decided whether to proceed. Any fee charged would be to cover the cost of obtaining your information. For example, search, retrieving and despatching to you.
How long does it take to gain access to my information?
We try to make your information available within 30 days of your request. Before we give you the information, we will need to confirm you are appropriately authorised to access the information, which may include an identity verification process.
Can you deny or limit my request for access?
In certain circumstances we’re allowed to deny your request, or limit the access we provide. For example we might not provide you access to commercially sensitive information. Whatever the outcome, we’ll be in touch to explain our decision.
Updating your basic information
It’s important that we have your correct contact details, such as your current postal address, email address and telephone number. You can check or update your information by contacting your relationship manager.
Can I correct my information?
You can ask us to correct any inaccurate information we hold or have provided to others by contacting us. If the information that is corrected is information we have provided to others, you can ask us to notify them of the correction. We don’t charge a fee for these requests.
We’ll inform you when the process is complete or if we have been unsuccessful at correcting your details with third parties.
What if we disagree that the information should be corrected?
If we disagree with you that information should be corrected, we’ll let you know in writing our reasons. You can ask us to include a statement with the relevant information, indicating your view that the information is inaccurate, misleading, incomplete, irrelevant or out-of-date.
We will take reasonable steps to comply with such a request.
9. Notifiable Data Breaches
Whilst we have measures in place to secure your personal information, in the unlikely event that your personal information is accessed or disclosed without authorisation or is lost we will assess whether the breach is likely to result in serious harm to you. If we assess is it likely to cause serious harm we will notify both you and the Office of the Australian Information Commissioner (OAIC).
10. Making a privacy complaint
We accept that sometimes we can get things wrong.
If you have a concern about your privacy, you have a right to make a complaint and we’ll do everything we can to put matters right.
How do I make a complaint?
To lodge a complaint, please get in touch with us through your relationship manager or at the following email address: [email protected].
How do we handle a complaint?
We will let you know that we have received your complaint and every effort will be made to resolve the complaint within 5 business days of receipt. However, more complex matters may take longer. For complex matters we expect to make our final response to you within 30 days. We will keep you informed if it’s going to take any longer than that.
External review
If you’re not satisfied with our handling of a privacy matter or you think it’s taking too long you can refer your complaint to the OAIC at the details below. Please keep in mind OAIC requires you to submit your complaint to us first and generally expects you to allow us 30 days to resolve it.
Telephone: 1300 363 992
Online: www.oaic.gov.au
Mail: GPO Box 5218 Sydney NSW 2001
11. How to contact us
For any other privacy related queries, access or correction requests, please contact your relationship manager or should you not have a relationship manager please contact us on any of the following:
Phone on: +61 2 9010 5200
In writing to: Level 5, 300 Barangaroo Avenue, Barangaroo NSW 2000
Or email at: [email protected]
12. To find out more about Privacy
For more information about the Australian Privacy Principles and the Privacy Act.
Issue date: October 2020
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