7 August 2020
1. Overview and Scope
In order for DFA Australia Limited ("Dimensional", "we", "us" or "our") to provide our products and services to you, it is necessary for us (or our appointed agent/s) to collect and often store your personal information. In doing so, we are committed to managing your personal information in a manner that reasonably seeks to ensure its confidentiality, integrity, and ongoing security.
For the purposes of this Policy we describe "Personal Information" and "Sensitive Information" as:
Information or an opinion, whether true or not, and whether recorded in a material form or not, about you as an individual, whereby your identity is apparent, or can reasonably be ascertained, from the information or opinion.
Information or an opinion about an individual’s: racial or ethnic origin; political opinions; membership of a political association; religious beliefs; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual preference or practices; criminal record; or personal health.
2. The Kind of Personal Information We Typically Collect
1) Direct investments (hard copy/Investment Portal): If you are directly investing into the Dimensional Wholesale Trusts (“Trusts”), you will typically be asked to provide Personal Information when completing an account application form or requesting a transaction. This may include your name; address; email address; tax file number; assets; Trust account balance; investment activity; information voluntarily provided by you on Dimensional’s website; date of birth; telephone number; bank account details; residency for tax reporting purposes; relevant authorised signatory lists, which include the relevant names and signatures and where relevant titles of those individuals authorised to act on your account; and identification information collected as part of the anti-money laundering and counter-terrorism financing regulations.
The Investment Portal is an online portal that allows investors in a Trust to apply and make redemption requests for units in the Trust and change certain investor details (such as bank account and address).
Hard copy applications are where you complete an application form and submit it via fax to our registry provider.
Please refer to the relevant Trust’s Product Disclosure Statement for more information on how to make investments.
2) Find an Advisor: If you are using Dimensional’s web-based ‘Find an Advisor’ service, you may provide Personal Information when requesting the service (this is a service Dimensional provides to prospective investors who wish to engage a financial adviser for advice on investing in the Trusts, either directly or indirectly through a wrap service or master fund account). This may include your name; email address; location (country and postcode); and proposed investment amount.
3) Conferences, Events & Webcasts: If you are registering for a Dimensional conference, event or webcast through our website, you may provide Personal Information for registration purposes. This may include your name; address; email address; telephone number; company details and any dietary requirements. Where relevant, your name may be shared with your financial adviser to confirm conference, event or webcast attendance.
4) Meetings with prospects/clients: Personal Information may be taken during meetings with prospects and clients. This may include any Personal Information voluntarily provided by you, for example your name; email address and telephone number.
5) Recruitment: If you are applying for a role through our recruitment process, you may provide Personal Information. This may include your name; address; email address; telephone number; information contained on your resume; covering letter; academic transcripts and certificates; personal identification documents, such as a copy of your passport; birth certificate; drivers licence; salary information or information otherwise provided by you.
6) Rights to work: During the recruitment process, we may provide your name; date of birth; passport details; and/or identity card number to the Department of Immigration to confirm your work rights. The results of these checks will be provided directly to Dimensional.
3. Sensitive Information
There may be instances where you provide Sensitive Information to Dimensional, or consent to it being collected. For example:
- Conferences & Events: You may provide health or dietary requirements relating to your attendance at Dimensional events.
- Police/Background Checks: During the recruitment process your name; phone number; and email address may be provided to Dimensional’s external police/background checking providers so they can contact you regarding the commencement of the checks. The types of checks that Dimensional may conduct through external providers includes but is not limited to: employment; education; police; criminal; credit; bankruptcy; global sanctions and anti-money laundering checks; World-Check searches; and any other appropriate checks as required. The results of these checks will be provided directly to Dimensional.
4. How We Collect and Store Your Personal Information
Typically, it is our practice to collect Personal Information directly from you or via your financial adviser if applicable. If it is necessary to store your Personal Information, Dimensional (or its agent) will store it in an appropriately secure physical or electronic facility, including paper-based files and/or computer databases.
Dimensional utilises "cloud" based services for several ancillary business services. Examples include Customer Relationship Management, Human Resource Management, Compliance Reporting, and Public Website Hosting. Dimensional has deployed an internal private "cloud" computing platform. Also, certain external service providers and applications used by Dimensional may utilise "cloud" capabilities.
We will take all reasonable steps to protect the Personal Information we hold relating to you from misuse, interference and loss, unauthorised modification or disclosure. Access to your Personal Information will be restricted to our employees and agents who need that information for the primary purpose of providing our products and services to you.
Dimensional will undertake reasonable steps to destroy or permanently de-identify your Personal Information if it is no longer needed for any of the purposes set out in this Policy.
5. Why We Collect Your Personal Information
If you invest directly into our Trusts, we will collect Personal Information for the primary purposes of setting up your account(s), processing your transactions, and managing your account(s) generally, including sending you related correspondence such as transaction confirmations and year-end tax statements. We are unable to undertake these activities without this information.
Some Personal Information is collected for the purpose of compliance with relevant laws (laws, regulations, rules, directions or requests from regulatory or government agencies), including the Financial Transaction Reports Act, the Anti-Money Laundering & Counter-Terrorism Financing Act and global information reporting regimes such as the United States Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standards (CRS). We may also be required to provide certain information in relation to your investments to regulatory authorities, or use it in order to resolve disputes.
In addition, we may collect Personal Information to consider the suitability of prospective employees.
6. Who Else May Access Your Personal Information
In order to provide our products and services to you, there may be occasions when we need to provide some of your Personal Information (including, in certain limited circumstances, your Sensitive Information) to our related entities, agents, or external service providers. In such circumstances, Dimensional will impose the necessary restrictions and standards within our contractual arrangements with such entities in order to reasonably seek to ensure that your Personal and/or Sensitive Information is kept secure, used only in accordance with our instructions and for the primary purpose it was entrusted to them.
As mentioned, Dimensional has appointed Citi as its agent to perform registry services. As our agent, Citi will be primarily responsible for collecting and storing your Personal Information if you directly invest into the Trusts.
There may be occasions where Dimensional or our agent needs to provide Personal and/or Sensitive Information to our parent company, another affiliated company, or third party located outside of Australia (including, but not limited to, the United States, the United Kingdom, Tokyo, Singapore, Hong Kong and Malaysia). Where Personal and/or Sensitive Information is required to be sent offshore, Dimensional and its agents will take such steps as are reasonable in the circumstances to seek to ensure that the overseas recipient does not breach Australian privacy laws or their local equivalent laws where applicable.
Where relevant, your name may be shared with your financial adviser to confirm conference, event or webcast attendance.
7. You May Request Access to Your Personal Information at Any Time
Subject to the exceptions set out in the Privacy Act, you may contact us to request access to your Personal Information that we or our agents hold, or if you have any questions or concerns about your Personal Information held by us. We will endeavour to meet your requests within a reasonable period and, where applicable, provide you with timely access to your Personal Information in the manner requested. We ask that you promptly notify us if you become aware that any of your Personal Information we hold is inaccurate.
8. Notifiable Data Breaches
Dimensional will assess any suspected data breaches to determine whether it is likely to result in serious harm to any of the individuals to whom the information relates. In which case, Dimensional will notify the individual(s) at risk of serious harm and the Office of the Australian Information Commissioner as soon as practicable.
9. If You Have a Complaint
Dimensional is a member of the Australian Financial Complaints Authority (“AFCA”), an external and independent dispute resolution service. In the unlikely event that you are not satisfied with our response to your complaint, you can contact AFCA directly on 1800 931 678.
The Office of the Australian Information Commissioner ("OAIC") can investigate privacy complaints from individuals. Complaints to the OAIC must be made in writing, typically using their online Privacy Complaint Form. You can contact OAIC directly on 1300 363 992.
Dimensional's Contact Details:
Telephone Number: +61 2 8336 7100
Fax: +61 2 8336 7197
The Compliance Manager
DFA Australia Limited
PO Box R1830
Royal Exchange NSW 1225, Australia
If you would like to know more about your rights to privacy or the Australian Privacy Principles, we recommend that you click on this link to the Office of the Australian Information Commissioner.
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