(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: (i) racial or ethnic origin; (ii) political opinions; (iii) membership of a political association; (iv) religious beliefs; (v) philosophical beliefs; (vi) membership of a professional or trade association; (vii) membership of a trade union; (viii) sexual preference or practices; (ix) criminal record; or (x) personal health.
(2) The Kind of Personal Information We Typically Collect
- (1) Direct investments:
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; fund account balance; investment activity; information voluntarily provided by you on Dimensional’s website; date of birth; telephone number; bank account details; residency for tax purposes; and identification information collected as part of the anti-money laundering and counter-terrorism financing regulations.
Dimensional has appointed Citi as its agent to perform transfer agency services which includes the setting-up of all new customer accounts and the processing of associated transactions within the Trusts. As our agent, Citi will be responsible for collecting and storing your Personal Information if you directly invest into the Trusts.
- (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 advisor 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 (state and country); and proposed investment amount.
- (3) Conferences:
If you are registering for a Dimensional conference through our website, you may provide Personal Information for registration purposes. This may include your name; email address; and location (state and country).
- (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 or information otherwise provided by you; salary information; police and/or background checks.
(2.1) Sensitive Information
Dimensional will not typically collect Sensitive Information from you. However you may provide Sensitive Information to Dimensional which may be used (e.g. heath or dietary requirements related to your attendance at Dimensional conferences).
(3) How We Collect and Store Your Personal Information
Typically it is our practice to collect Personal Information directly from you or via your accredited financial advisor 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.
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.
(4) 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 (FACTA) 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.
(5) 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 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 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 key transfer agency 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 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 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.
(6) You May Access Your Personal Information at Any Time
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.
(7) If You Have a Complaint
Dimensional is a member of the Financial Ombudsman Service (FOS), an external and independent industry dispute resolution service. In the unlikely event that you are not satisfied with our response to your complaint, you can contact FOS directly on 1800 367 287.
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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