Privacy and the Information Handling Practices of the Commonwealth Bank Group.
First State Investments (UK) Limited and the companies within the First State Investments (UK) group are members of the Commonwealth Bank of Australia Group. The companies for whom First State Investments (UK) is a business name are listed below :
First State Investments (UK) Limited
First State Investment Management (UK) Limited
First State Investment Services (UK) Limited
First State Investments (UK Holdings) Limited
First State Investments International Limited
How we handle your personal information
Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, contact details as well as your health and financial information. We are part of the Commonwealth Bank of Australia Group. We will act to protect your personal information in accordance with local law and this policy statement.
The Commonwealth Bank of Australia Group is a collection of related organisations that provide banking, insurance, fund management, financial planning and advice, superannuation, stockbroking and finance services.
We value your trust, and aim to help you manage and build wealth over a long period. The protection of your personal information is a vital part of this relationship. It is supported by our long experience of keeping personal information confidential.
We collect personal data to provide you with the financial products and services you request as well as information on other products and services offered by us. The law may also require us to collect personal information in certain circumstances. We will tell you who collects the personal information, advise you of their contact details, your right of access to that information, and what will happen if you choose not to provide this information.
Personal information may be used and disclosed within the Commonwealth Bank of Australia Group to administer our products and services, as well as for prudential and risk management purposes and, depending on your choice, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We co-operate with police and other enforcement bodies as required or allowed by law.
We disclose relevant personal information to external organisations that help us provide services. These organisations are bound by confidentiality arrangements. They may include overseas organisations.
You can seek access to the personal information we hold about you. If the information we hold is inaccurate, incomplete or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why.
If you have any questions or would like further information on our privacy and information handling practices, please contact us.
At First State Investments (UK) Limited and its group companies the privacy of your personal data is important to us. We collect personal data to make and maintain investments on your behalf or on behalf of your clients in funds managed by us as well as to provide you with information about other products and services we offer. In some circumstances the law may also require us to collect personal data. The Data Protection Act 1998 ("the Act") defines personal data as data "which relate to a living individual who can be identified:
(a) from those data; or
(b) from those data and other information which is in the possession of, or is likely to come into the possession of the data controller
and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual".
First State Investments (UK) is bound to protect your personal data in accordance with the Act and the principles contained therein.
The following statement outlines our general information handling practices.
How is your personal data dealt with?
In the course of doing business we outsource certain tasks to third party administrators or agents. These third parties are bound by confidentiality arrangements when handling your personal data. Your personal data may also be used by us to administer, monitor and evaluate products and services, inform you about promotional activities, gather, aggregate and report statistical information, assist you with any queries and take measures to detect and prevent fraud and other illegal activity. We may also be allowed or obliged to disclose information by law or by the rules of any applicable regulatory body or otherwise where you have given your consent.
If you used a financial advisor who recommended that you invest with us (as indicated on your application form) then details of your investments may also be provided to such financial advisor (or any replacement or additional advisor which you inform us of).
We aim to ensure that the personal information we retain about you is accurate, complete and up to date. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking or the best of our products for your individual circumstances.
What personal data do we collect?
First State Investments (UK) collects personal data on investors, clients, intermediaries and business contacts via application forms, other First State Investments (UK) forms, investment management agreements, correspondence, business cards, phone, fax, e-mail and on-line. Personal data collected may include:
Date of birth
National Insurance Number/other tax details
Bank account information
Login and activity details for First State's secure websites
Information to respond to any technical difficulties on First State's secure websites
Responses to surveys, competitions and prizedraws
The main purpose for First State Investments (UK) collecting your data is to make and maintain investments on your or your client's behalf in funds managed by us. If you would like to receive further information from us about other products or services offered by First State Investments (UK) please ensure you tick the relevant box on the appropriate application form or contact us by e-mailing us at email@example.com
Personal Data Quality
We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date. Please contact us by e-mailing us at firstname.lastname@example.org writing to the Data Protection Manager at 23 St Andrew Square, Edinburgh, EH2 1BB if any of the details you have provided change. Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.
Personal information security
We are committed to keeping secure the personal data you provide to us. We take all reasonable precautions to protect the personal data we hold about you from misuse and loss and from unauthorised access, modification or disclosure. We have a range of physical and technological policies and procedures in place to provide a robust security environment. We seek to ensure the on-going adequacy of these measures by regularly reviewing them. Our security measures include, but are not limited to: restricting access to our computer systems and physical records to authorised persons and preventing users from accessing information they have no need to access; and requiring employees to use unique passwords and finger print recognition to gain access to systems. These passwords are changed regularly and their use is independently monitored; encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks; employing firewalls, intrusion detection systems and virus scanning tools to prevent unauthorised persons and viruses from entering our systems; using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; providing secure storage for physical records; and detecting and preventing unauthorised access to buildings by employing physical and electronic means such as alarms and cameras. Where information we hold is identified as no longer needed for any purpose we take reasonable steps to effectively and securely destroy it.
For statistical purposes we collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site) through the use of 'cookies'. This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. We only collect your personal data via your use of our website if you complete a Form or otherwise make an enquiry via the website and submit your details.
A 'cookie' is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer. When you use our website, we send you a temporary cookie (known as a session cookie) that gives you a unique identification number. A different identification number is sent each time you use our website. Session cookies do not identify individual users, although they do identify a user's browser type and your Internet Service Provider (ISP). At the end of your interaction with our public website, the session cookie "crumbles". This means it no longer exists on your computer and therefore it cannot be used for further identification or access to your computer.
We also use persistent cookies in certain parts of our sites. A persistent 'cookie' is a small file which is placed on the storage device of your computer by your browser. The information stored in this cookie does not identify you and does not track or store any browsing habits, urls or user inputs. As First State and its associated companies are based in various jurisdictions and operate different websites for each regional business, the persistent cookie stores general information such as the language the site is being viewed in (for example English, Chinese) and currency settings. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences.
Links to other web sites
Our web site may contain links to non First State Investments (UK) web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
We monitor and record telephone calls for training and security purposes.
Access to your Personal Data
If you wish, you may also have a copy of the personal data held on you by First State Investments (UK). First State Investments (UK) are allowed, by law, to charge you a fee for this. If you would like to exercise this right, please put your request in writing to:
First State Investments (UK)
23 St Andrew Square
First State Investments (UK) will respond promptly, and in any event within 4 days, to a request by you for a copy of personal data held. If we deny access to your personal information, we will let you know why.