BNP PARIBAS ASSET MANAGEMENT - Legal MIFID 1440x300

Privacy Notice

BNP PARIBAS ASSET MANAGEMENT Australia Limited Privacy Policy

This is the Privacy Policy of BNP PARIBAS ASSET MANAGEMENT Australia Limited (“BNPP AMAU”).

This Privacy Policy relates to personal information. Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

BNPP AMAU is bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth) (“Privacy Act”). The employee records exemption under the Privacy Act applies to employee records held by BNPP AMAU.

Information Collected From You

We obtain most information from you directly, or in some cases from your employer, where your employer is an existing or prospective client or service provider of ours. The type of information that we collect from you will depend on what products and services you as an individual use, and in some instances, the products and services we provide to your employer. Such information may include your name and address, telephone number, email address, sample signature and government identifiers such as your ABN, Tax File Number and passport number. If you provide incomplete information we may not be able to provide you with the services you are seeking.

If you invest in a registered managed investment scheme for which BNPP AMAU is the investment manager, we will have access to all the information collected and held by the responsible entity of the scheme (and its delegates and agents, including the custodian and administrator of the scheme) that relates to you and your investment. In some cases, we may collect personal information from you (or your financial adviser or agent authorised to provide information in relation to your investment) in our capacity as an agent of the scheme’s responsible entity, and may disclose that information to other service providers to the scheme, so that they can provide services to you as an investor, and store your information in their systems.

How We Use Information Collected From You

We collect, hold, use and disclose your personal information as reasonably necessary and as permitted by law.

We generally collect, use and disclose your personal information for the following purposes:

  • to provide you (or your employer) with a particular product or service;
  • servicing and managing our relationship with you and/or your employer;
  • information systems and infrastructure management, maintenance, development and support services, and business continuity and disaster recovery processes and testing;
  • internal accounting, audit, record keeping, risk management, reporting and administrative functions;
  • complying with our legislative, audit, regulatory and compliance requirements;
  • complying with BNP Paribas Group policies and procedures;
  • protecting you, BNPP AMAU and the BNP Paribas Group from error, fraud, and any other legal, compliance, financial or regulatory risks, including verifying an investor’s or prospective investor’s identity;
  • inviting you to events that may interest you; and
  • dealing with complaints.

In the event that we contract out some functions and activities, your personal information may be disclosed to a third party, and we would prohibit such a party from using personal information except for the specific purpose for which we supply it.

We may also disclose your personal information to third parties such as regulatory, government, taxation and other authorities, and your nominated financial adviser.

Except where it is required by law or where permitted by the privacy law, we only use or disclose your personal information with your express or implied consent. We obtain your consent in various ways. For instance, we may obtain your consent to use or disclose your information on an application form that you complete for one of our products or services. We may obtain your consent to use or disclose your personal information from your employer, for example where your employer provides your personal information for the purposes of us verifying your, and/or your employer’s identity, in relation to services provided to your employer.

If we send you publications or invitations to events which we consider may be of interest to you, your employer or colleagues, you will always have the ability to opt out from the receipt of further materials or invitations.

On occasion we may assist our local and offshore investment managers should they need to verify a client’s or prospect’s identity for the purposes of regulatory requirements applicable to them. If such a client or prospect is your employer, this may involve collection of your personal information directly from your employer, and disclosure of it to the relevant offshore investment manager. The countries our offshore investment managers are located in currently include Denmark, France, Hong Kong, Singapore, the United Kingdom and the United States.

If you do not provide us with your personal information when we ask for it, we may not be able to provide you (or your employer) with our products and services. Further, in the case of registered managed investment schemes for which we are the investment manager, we may not be able to fulfill our investor communications responsibilities to you as an investor, if we do not have access to your personal information.

We do not disclose names and addresses to third parties for the purpose of enabling such third parties to directly market their products and services to you. Due to BNP Paribas Group internal reporting requirements, some of your personal information may be shared with other members of the BNP Paribas Group, and in particular, entities located in France and Hong Kong.

Some members of the BNP Paribas Group provide us with services such as information systems and infrastructure maintenance, development and support, marketing support and event management services, internal audit and anti-money laundering and fraud related compliance, screening and reporting services. In some cases this may result in your personal information being accessible to those entities, in particular, those located in Australia, Belgium, France, Hong Kong, India and Singapore.

How Your Personal Information is Kept Up-to-date

We take reasonable steps to ensure that your personal information is accurate whenever we collect it or use it.

If you find that personal information we hold about you is inaccurate, please contact us immediately and we will correct it. In the case of our registered managed investment schemes, we will arrange for the administrator of the scheme to correct the information.

How You Can Access Your Personal Information

You are entitled to request access to information about you which is held by BNPP AMAU. If possible, BNPP AMAU will provide you with the information you request. However, BNPP AMAU may deny access to information in certain circumstances, in accordance with the Australian Privacy Principles.

We will provide you with such information within a reasonable time frame. We may charge you a reasonable amount to provide a copy of your personal information. If there is an access charge, we will give you an estimate of the fee and confirm with you whether you would like us to proceed.

Contact: BNP PARIBAS ASSET MANAGEMENT Client Services
Phone: +61 (2) 9619 6041
  1800 267 726 (Australia)
Mail: BNP PARIBAS ASSET MANAGEMENT Australia Limited
60 Castlereagh Street
Sydney NSW 2000

 Storage and Security of Your Personal Information

We protect any personal information that we hold from misuse and loss and we also protect it from unauthorised access, modification and disclosure. Your personal information may be stored as hard copy documents in our offices, as electronic data or in our information technology software and/or systems, or on our behalf, including by other members of the BNP Paribas Group.

Complaints Procedures

If you have a complaint that relates to the privacy of your personal information or you believe that we have breached the Australian Privacy Principles, then please contact BNPP AMAU. We will respond to your complaint as soon as possible, but in any event within five working days, to let you know who is dealing with your complaint. We will endeavour to ensure that the complaint is properly considered and dealt with within 45 days, and, in the case of an investment in a registered managed investment scheme, within the time limits specified by the responsible entity of the scheme.

Contact: Complaints Handling Officer

Phone: +61 (2) 9619 6238
  1800 267 726 (Australia)
Fax: +61 (2) 9006 9051
Mail: BNP PARIBAS ASSET MANAGEMENT Australia Limited
Complaints Handling Officer
60 Castlereagh Street
Sydney NSW 2000

If you are not satisfied with our response, you may wish to refer the matter to the Office of the Australian Information Commissioner (OAIC). For more information regarding the OAIC generally, and how to contact them, please see www.oaic.gov.au

 

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BNP PARIBAS ASSET MANAGEMENT Australia Limited ABN 78 008 576 449

Date: 18 December 2018