For Australian Investors
In this document, “we”, “us”, “our” means the individual APP entity. We may make any changes to this Privacy Statement from time to time and for any reason. Any changes will be reflected in brochures and our website.
Respecting and protecting your privacy
At State Street we respect your right to privacy and are committed to ensuring your personal information is collected, used, disclosed, and maintained in accordance with the Australian Privacy Principles (APP) under the Act, our global and local policies.
We protect your personal information with the same integrity that we would use to handle our own individual personal information. This enables us to conduct business and exchange information in a secure environment, meeting employee, customer and regulator expectations for privacy, security and confidentiality.
Personal information we may collect
The type of personal information that we may collect and hold will vary depending on: (i) the service we provide, which includes custody, fund administration, funds management and other financial services; and (ii) the circumstances in which we are dealing with you.
Also, where you have applied for a position with us, we will only collect and hold personal information relevant to that relationship with you. The personal information we collect may include:
Where we collect certain information, for example, tax file number, and you choose not to provide the information, it may mean that we will not be able to provide the services that you require.
The Act restricts the collection of sensitive personal information. Sensitive information includes information about an individual’s racial or ethnic origin, health, criminal record, religious beliefs, or membership of political, professional or trade association.
We may be required to collect and use sensitive information about you in order to provide the products and services you have requested but we will only do this with your consent unless we are permitted by law to do so without your consent.
Your personal information may be collected by others on our behalf such as service providers, agents, advisers and brokers.
Information about you may also be collected from publicly available sources such as public registers or information made available by third parties.
Why do we have to collect, hold, use and disclose personal information?
We collect, hold, use and disclose your personal information as is reasonably necessary to administer our products and services and manage our relationship with you, as well as to comply with our legal obligations and assist government and law enforcement agencies or regulators. For example, we may be required to disclose your personal information to Australian Government regulators such as the Australian Securities and Investments Commission (ASIC), Australian Tax Office (ATO), Australian Transaction Reports and Analysis Centre (AUSTRAC) and to other regulatory or government entities.
We may also collect, hold, use and disclose your personal information for the following purposes:
How we collect personal information
If you do not provide the information requested, or it is incomplete or inaccurate, we may not be able to provide our services to you.
Do we disclose your personal information to others?
We may disclose or share your personal information for the purposes listed above or as otherwise permitted by the Act to third parties that include the following:
State Street operates as a global organisation and certain functions operate from dedicated centres which also provide shared services around the globe. As referred to above, some related bodies corporate and other recipients to whom we disclose your personal information may be based overseas. We require overseas service providers to take reasonable steps to protect personal information from unauthorised use or disclosure in accordance with the relevant APPs or ensure they operate in countries with laws to protect your information substantially similar to the protection provided by the APPs.
Anonymity and adoption of a pseudonym
Although the Act allows for you to deal with us anonymously or by using a pseudonym, we can only allow this in limited circumstances, such as in relation to enquiries of a general nature. We are unable to allow anonymous dealings or the adoption of a pseudonym in relation to more specific enquiries about your account with us.
Keeping your personal information secure
We have security systems, policies, processes and procedures that meet current industry standards, to protect your personal information from misuse, loss and unauthorised access, modification or disclosure and we regularly review their effectiveness. The only people who are allowed to handle or have access to your personal information are those employees of State Street Australia and the State Street Group and those who perform services for us who need your personal information to do their jobs.
Keeping your personal information accurate and up-to-date
We maintain the quality of your personal information by taking reasonable steps to make sure that the information collected, used and disclosed is accurate, complete and up-to-date and we encourage you to contact us about the changes to your personal details.
Accessing and correcting your personal information
You can request access to the personal information we hold about you by contacting us with your request, using the contact details set out below. We will need to verify your identity before completing your request.
We may not always be able to give you access to all the personal information we have about you. For instance, we may not be able to give you access to information that:
You can also request correction to the personal information we hold about you by contacting us with your request, using the contact details set out below.
How to contact us (includes making a complaint)
You can contact us about this Policy, to request access or correction to your personal information, or if you have a complaint about the way we handled your personal information, by:
for SSAL, SSBT and SSGMIL:
for SSGA AL and SSGA ASL:
We aim to complete/resolve your request/complaint within 30 days of receiving it, or longer for a more complex request or complaint. Please note that our process also includes notifying our Corporate Privacy Office in the U.S. If you are unhappy with the handling of your complaint you may also contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, visiting www. oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.