MUFG Pension & Market
Services Privacy Policy
MAY 2023
Document Name:
MUFG Pension & Market Services
Privacy Policy
Policy Category:
Public
Approver:
Board
Executive Sponsor:
General Counsel
Policy Owner (Author):
General Counsel
Approval Date:
28 July 2020
Review Frequency:
Generally, every two years unless required more
frequently
Last Review Date:
May 2023
Next Review Date
May 2025
Contact for questions:
Group Risk and Compliance
Document Classification: Public
MUFG Pension & Market Services
Who is MUFG Pension & Market Services
MUFG Pension & Market Services is a market-leading financial administrator that connects
people with their assets. We provide technology-enabled administration solutions and related
services across multiple product classes including superannuation, managed investments,
equities, debt and property.
Since inception, MUFG Pension & Market Services has been entrusted by clients to handle
commercial and personal data in a secure and confidential manner. A full listing of our business
unit websites by Division is shown in Schedule A.
This document serves as a Privacy Policy and Privacy Notice that covers all MUFG Pension &
Market Services subsidiaries. In this Policy, references to we, us or our are references to MUFG
Pension & Market Services.
1. What is this policy?
1.1. We may collect Personal Information (defined below) about you and we are committed to
protecting this Personal Information and your privacy. Set out in this Policy is an
explanation of how we collect, use and safeguard your Personal Information. In most
jurisdictions where we operate, the protections set out in this Policy also apply to the
Personal Information of our employees provided by those employees to us.
1.2. The purpose of the Policy is to provide individuals and organisations with transparency
about our collection, usage, maintenance, storage and destruction of Personal Information
(which terms are often described as “processing”).
1.3. The key principles of integrity, openness, transparency, and respect for the rights of
individuals are all elements of this Policy which apply to all of our business units globally.
2. Why do we need this policy?
2.1. This Policy sets out the minimum requirements for all our businesses and their employees
for the confidentiality, security, integrity, and protection of Personal Information.
2.2. Where a jurisdiction in which we operate has regulatory or governance obligations over
and above these Policy minimums, for that jurisdiction these additional requirements are
included in Schedule B. Additionally, European Union (“EU”) and United Kingdom (“UK”)
residents are entitled to additional rights under the respective EU and UK General Data
Protection Regulation (“EU and UK GDPR''). Both the EU and UK GDPR apply even
where the Data Controller (i.e. the entity that determines the purpose and means for
processing Personal Information) is based outside of the EU or UK, and is offering goods
or services to residents within the EU or UK. These rights are also outlined in Schedule B
of this Policy.
3. What personal information do we collect?
3.1. Personal Information is information that relates to an identified or identifiable individual.
Personal Information should only be collected and processed as is necessary for the
purpose for which it was collected or obtained. MUFG Pension & Market Services will only
collect and process Personal Information about you that is necessary to provide you with
the products and services that you have requested.
3.2. The information we collect depends on the nature of our relationship with you. Personal
Information we may collect includes:
Document Classification: Public
MUFG Pension & Market Services
● Contact information – this includes your name, address, contact information and
relationships to other people;
● Financial and transactional information – this includes payments, trades, payment
card details, bank account information, tax residency information details of income and
assets, mortgages, investments and superannuation and pensions contributions and
values;
● Product information – information about the products and services we provide to you
including unique reference numbers;
● Socio-demographic information – this includes your gender identity, job and
education;
● Communications – personal information contained in letters, emails, phone calls or
any other communications between us;
● Technical and usage – details on the devices and technology you use including
internet protocol (IP) address, cookies, pixels and other tracking technology;
● Behavioural – details about how you use our products and services;
● Documentary/identity information – this includes information stored in documents
such as a passport, driving licence or birth certificate, in addition to national identifiers
and tax numbers;
● Marketing and communication preferences;
● Authentication data – this includes usernames, passwords and any information
required to access our products and services;
● Open data and public records – this can include information from the Electoral
Register, and information that is publicly available on the internet;
● Information about criminal convictions and offences – information obtained when
carrying out anti-fraud or anti money laundering checks, or other background screening
checks (in some cases, this will be “Sensitive Personal Information”, or information
which otherwise attracts special rights and protections); and
● Sensitive Personal Information – in certain limited circumstances, we may request
or receive Personal Information which is sensitive in nature. We will only collect and
process this Sensitive Personal Information if the law allows. Sensitive Personal
Information can include information relating to your health, genetic or biometric data,
sexual orientation, racial or ethnic origin, political opinions, religious or philosophical
beliefs and trade union membership.
4. Where do we collect your Personal Information from?
4.1. We may collect Personal Information directly from you:
• via application and various event registration forms;
• through feedback forms and other forums;
• when you purchase any of our products and services or our clients’ products and
services;
Document Classification: Public
MUFG Pension & Market Services
• when you fill out a survey, or vote in a poll on our websites;
• via our telephone calls with you, which may be recorded;
• when you provide your details to us either online or offline;
• when you communicate with us via email; or
• via cookies (see section 10 of this Policy for further information).
4.2. We may also collect Personal Information about you internally, between MUFG
Pension & Market Services entities, and from external organisations and third parties,
including:
• Government agencies, authorities, regulators and official bodies (for example, when
accessing government probate records);
• Law enforcement and fraud prevention agencies;
• People linked with you, such as joint account holders, trustees or another person you
have authorised to act on your behalf;
• Your legal representative or financial advisor, authorised to act on your behalf;
• Identity verification and credit reference agencies;
• Other financial services companies (for example, banks and card providers);
• Public information and open sources such the Electoral Register, Companies House,
internet searches, and information that is publicly available;
• Companies we work with such as sub-contractors, suppliers and consultants;
• Organisations that introduce you to us, for example brokers;
• Your employer (past and current);
• Third parties in connection with any merger or acquisition of a business by us;
• Other companies, either because you ask us to or because of features of the product or
service you have with us; and
• from third party registers maintained by regulators such as those listed in Schedule D.
5. Why do we collect and process your Personal Information?
5.1. We are only allowed to process your Personal Information if we have a reason under data
protection law.
5.2. The basis for processing your Personal Information will vary according to the nature of the
relationship we have with you, the MUFG Pension & Market Services product that you hold
or the MUFG Pension & Market Services service for which you have subscribed. For
example:
• If you are an investor with whom we have a contract, we may be required to process
your Personal Information to verify your identity, to administer your investment product,
or to investigate fraud; or
Document Classification: Public
MUFG Pension & Market Services
• If you are an employee of a firm with whom we have a business relationship, we may
be required to process your Personal Information as part of our contractual obligations
and in the normal course of doing business with your firm; or
• If you are a user of our website, we may process your Personal Information which is
contained in cookies, to track the use of our website.
5.3. The following are further illustrative examples of the circumstances in which we might
collect or process your Personal Information, and the lawful basis/bases for processing in
these circumstances.
Type of
processing
Purpose of
processing
Lawful basis/bases
(EU/UK)
Our legitimate interests
(EU/UK)
The
administration
and provision
of services
To provide our
products and services;
To communicate with
you, including
marketing activity;
To resolve and
respond to
complaints;
To provide services
set out in a contract
with you;
Your consent;
To comply with our
legal obligation(s);
and
Keeping our records up to date;
Identifying support needs and
communication preferences;
Managing how we provide our
products and services;
Seeking your consent when we
need it to contact you;
To manage our
relationship with you
or your business;
Our legitimate
interests.
To help meet contractual and
legal obligations;
To understand how
you use our products
and services; and
To manage our
brands, products and
services.
To comply with regulations,
guidance and rules;
Understanding how our
products and services are used
and accessed;
Identifying opportunities to
improve; and
To manage our commercial
interests.
Improving the
services we
offer to you
To develop marketing
opportunities and
activities;
To provide services
set out in a contract
with you;
Developing and improving
products and services;
To identify and
develop new brands,
products, services;
To comply with our
legal obligation(s);
and
Identifying opportunities to grow
and improve our businesses;
To help meet contractual and
legal obligations;
To test new products;
and
Our legitimate
interests.
To comply with regulations,
guidance and rules; and
To manage
companies that we
work with.
To manage our commercial
interests.
Managing our
business
To understand and
monitor how our
business is
performing, changing
and adapting;
To ensure the ongoing
provision of products
To provide services
set out in a contract
with you;
To comply with our
legal obligation(s);
and
Managing how we provide our
products and services;
To help meet contractual and
legal obligations;
To comply with regulations,
guidance and rules; and
Document Classification: Public
MUFG Pension & Market Services
and services;
To maintain our
websites and apps;
Our legitimate
interests. To manage our commercial
interests.
To manage fees,
charges, interest or to
collect money that is
owed to us;
For our own internal
and external
management
information purposes;
and
Maintaining
accounting records,
analysis of financial
results, internal audit
requirements, and
receiving professional
advice.
Managing risk
To comply with
regulations, guidance,
laws, rules and
standards;
To provide services
set out in a contract
with you;
To protect (us and you) from
loss, harm or damage;
To improve business efficiency;
To prevent and detect
crime;
To comply with our
legal obligation(s);
and
To help meet contractual and
legal obligations;
To manage risk for us
and our customers;
and
Our legitimate
interests.
To comply with regulations,
guidance, laws, rules and
standards; and
To establish, enforce
or defend our legal
rights.
To manage our commercial
interests.
5.4. In certain limited circumstances we may process Sensitive Personal Information (defined
in Section 3.2 of this Policy). We will ask for your explicit consent to process this type of
Personal Information, unless the processing is allowed under law.
6. With whom do we share Personal Information?
6.1. We will only disclose your Personal Information in accordance with applicable laws and
regulations. In some instances, this will include sharing your Personal Information with
third parties such as:
• Any member of MUFG Pension & Market Services, which includes our ultimate holding
company and its subsidiaries (from time to time), as necessary to provide services to
you;
• Government agencies, authorities, regulators and official bodies (for example, a
privacy or data protection regulator or other relevant government department where
reasonably necessary for financial crime and sanction compliance purposes);
• Law enforcement and fraud prevention agencies (for example, the police or another
related authority that may require disclosure on legal grounds);
Document Classification: Public
MUFG Pension & Market Services
• People linked with you, such as joint account holders, trustees or another person you
have authorised to act on your behalf;
• Your legal representative or financial advisor, authorised to act on your behalf;
• Identity verification and credit reference agencies (for example, Equifax and Experian);
• Other financial services companies (for example, banks and card providers);
• Companies we work with such as sub-contractors, suppliers and consultants, engaged
by us to assist us in providing services to you (for example, cloud storage providers,
mail-houses, IT system suppliers, auditors, lawyers, marketing agencies, document
management providers, tax advisers and investment product and service
administrators);
• Third parties in connection with any merger or acquisition of a business by us; and
• Other companies, either because you ask us to or because of features of the product
or service you have with us.
7. How do we keep your Personal Information secure?
7.1. We store Personal Information in secure databases and in secure cloud environments. We
take appropriate security measures to protect such Personal Information from misuse,
interference and loss, as well as unauthorised access, modification or disclosure.
7.2. We take protection of your Personal Information and our system security very seriously.
Any Personal Information that is collected, processed or stored will have appropriate
safeguards applied in line with our data protection obligations. We have also designed and
implemented controls to minimise loss of, or damage to, your Personal Information by
human error, negligence or malicious intent and engage internal and external auditors to
conduct regular, independent assurance exercises across our business to ascertain the
effectiveness of our security control environment and our security strategy.
7.3. Our employees also protect your Personal Information whenever they are processing it
and must undergo regular training on privacy and data protection requirements.
7.4. Our security controls are aligned to industry standards and good practice; providing a
control environment that effectively manages risks to the confidentiality, integrity and
availability of your Personal Information.
7.5. All exchanges of Personal Information between you and our websites go through
encrypted channels in order to prevent interception of your Personal Information. Public
access to your Personal Information via our websites or any web-hosted platform is
protected by a login using a personalised user ID and password. You should ensure that
your user ID and password are kept secret and not divulged to other people. As our
websites are grouped to the internet which is inherently insecure, we cannot guarantee the
Personal Information you supply will not be intercepted while being transmitted over the
internet. Therefore, your use of our websites is entirely at your own risk. Accordingly, we
accept no responsibility or liability for the security of Personal Information transmitted by
you through our websites.
8. For how long will we store your Personal Information?
8.1. We generally hold your Personal Information on our systems for as long as is necessary
Document Classification: Public
MUFG Pension & Market Services
to provide our services to you. The length of time for which we keep your Personal
Information will depend on the services we provide to you and their relevant regulatory
requirements in your jurisdiction. Our websites use Google Analytics where a record of
some of your Personal Information (e.g. IP address) may be retained for up to 38 months
depending on your jurisdiction.
8.2. We typically keep Personal Information for up to a maximum retention period of 10 years
from the date you cease to use the Services, depending on the jurisdiction where your
Personal Information is held. In some cases, where there may be a dispute or a legal
action, we may be required to keep Personal Information for a longer period.
8.3. When it is no longer required, we will take steps to delete, destroy, or de-identify your
Personal Information. Where we are able to de-identify your Personal Information so that
it can no longer be associated with you, we may retain that information indefinitely without
notice to you.
9. Your rights
9.1. Each jurisdiction grants individuals certain legal rights in respect of their Personal
Information. No matter where you are resident, you have the following rights in relation to
how MUFG Pension & Market Services processes your Personal Information.
• Right to lodge a complaint – You have a right to lodge a complaint to us at any time
if you object to the way in which we have processed or managed your Personal
Information.Where you are dissatisfied with our response, you also have the right to
escalate yourcomplaint to the relevant regulator in your jurisdiction. Further information
can be located on the applicable regulator’s website (see Schedule D).
• Right of access – All individuals have a right to access their Personal Information held
by an organisation. There will not usually be a charge to you for us to respond tothese
requests. However, where the request is deemed by us to be excessive, you may be
charged a fee for our providing you a record of your Personal Information thatis held
by us. Your Personal Information will usually be provided to you in hard copy, unless
otherwise requested. Where you have made the request to receive a record ofyour
Personal Information held by us by electronic means, we will endeavour to provide the
data in the requested format where we are able to do so.
• Right of rectification – We take reasonable steps to ensure that the Personal
Information we collect and hold about you is accurate and complete. However, if you
do not believe this is the case, you have the right to request we rectify the inaccuracy
or to complete any incomplete Personal Information.
• Right to opt out from receiving any direct marketing – You can ask us to stop
sending you marketing messages at any time. Please see below for instructions on
how you can do this.
9.2. Additional rights are available to individuals resident in the EU, UK and Australia, which are
outlined in Schedule B of this Policy.
9.3. If you would like to exercise any of the above rights, please refer to Schedule C for the
contact details for your jurisdiction.
9.4. In some circumstances, exercising some of these rights may result in us being unable to
continue providing you with a prescribed service and/or our business relationship with you.
Please note that in some cases, we may not be able to uphold your request for reasons
such as our own obligations to comply with other legal or regulatory requirements. We will
always respond to any request you make and if we can't comply with your request, we will
Document Classification: Public
MUFG Pension & Market Services
tell you why.
Marketing
9.5. We may contact you to tell you about products, services and offers that we think you may
be interested in. When we send you this type of marketing message we will do so because
we have a lawful basis to do so.
9.6. You have the right to opt out from receiving any direct marketing messages. You can ask
us not to send you marketing messages by following the unsubscribe instructions that
appear in our email communications. Alternatively, please refer to Schedule C for details
of relevant local contact(s) in your jurisdiction.
9.7. You may continue to receive important information and service-related communications,
regardless of your marketing preferences.
10. Cookies, pixels and tracking technology
10.1. We use cookies, pixels, online identifiers and similar tracking technologies on our websites,
apps, and in our emails. This technology is used to improve our own products and services,
your user experience, optimise what you may see on our websites and provide information
when you are online. We comply with the cookie regulations as stated in the jurisdictions
within which we operate.
10.2. Cookies -
There are two types of cookies that can be stored on your device:
• "session cookies", which only last for the duration of your visit to our websites and are
automatically deleted from your device when you close your browser; and
• "persistent cookies", which remain on your device after you have visited our websites
and are not deleted when you close your browser. Persistent cookies are sent back to
our server every time you visit our websites.
Users will be able to adjust their internet settings to accept all cookies, to notify them when
a cookie is issued, or not to receive cookies at any time. If you use your browser settings
to block all cookies (including essential cookies), you may not be able to access all or parts
of our website.
10.3. Pixels – We use small images called “pixels” in our emails to help us improve our
communications and to understand how you interact with them. The use of pixels allows
us to understand whether and how many times you have opened an email, the device
you used and the IP address. We may also set a cookie to find out if you clicked on any
links in the email.
10.4. For further information about cookies, pixels and tracking technology used by MUFG
Pension & Market Services, please see our Cookie Policy, where a full list of the cookies
used by MUFG Pension & Market Services web pages, and information on how to
manage or delete cookies, is available.
10.5. Our websites may contain links to other websites that may make use of their own cookies
technology and will have their own privacy policies. You should carefully review the
privacy policies and practices of other websites that we do not control as we do not accept
any liability for the privacy practices of such third-party websites.
11. Social media
Document Classification: Public
MUFG Pension & Market Services
11.1. We use a third-party provider, LinkedIn, to manage our social media interactions. If you
send us a private or direct message via social media, it will be stored by LinkedIn for the
period of time your account is in existence.
11.2. We see all this information and decide how we manage it. For example, if you send a
message via social media that needs a response from us, we may process it in our contact
management system as an enquiry or a complaint.
11.3. When contacting MUFG Pension & Market Services through a social media platform, we
suggest you also familiarise yourself with the privacy information on that platform.
12. Who can you speak to about this policy?
12.1. If you have any questions, or want more details about how we use your Personal
Information, please refer to Schedule C of this Policy for details of relevant local contact(s)
in your jurisdiction.
12.2. If you are unhappy with how we have handled your Personal Information and wish to make
a complaint, please refer to Schedule C of this Policy for details of relevant local contact(s)
in your jurisdiction. You also have the right to complain to the relevant regulator in your
jurisdiction, and to lodge an appeal if you are not happy with the outcome of a complaint.
Please refer to Schedule D of this Policy for details.
13. Changes to this policy
13.1. Please note that this Policy will be reviewed periodically and may be changed from time
to time. We provide details on this page to inform you of when this Policy was last updated.
Document Classification: Public
MUFG Pension & Market Services
14. Schedule A: MUFG Pension & Market Services business unit websites by division
MUFG Corporate Markets
MUFG Retirement Solution
MUFG Corporate Markets –
Australia
https://www.linkmarketservices.com.au/corporate/home.html
New Zealand (including Pacific Custodians (New Zealand)
https://
www.linkmarketservices.co.nz/
Germany
https://www.linkmarketservices.de/
South Africa
https://www.linkmarketservices.co.za/Home/
Hong Kong
https://
www.linkmarketservices.hk/corporate/
United Kingdom
https://www.linkassetservices.com/what-we-do/market-
services
AAS – Australia
https://www.aas.com.au/
Link Advice – Australia
http://linkadvice.com.au/
Super Clearing House Online – Australia
http://www.sch-online.com.au/Home/
Link Intime – India
https://linkintime.co.in/
Orient Capital – Australia, Hong Kong and United Kingdom
https://www.orientcap.com/
D.F. King – France, Germany, Hong Kong, and United
Kingdom
http://www.dfkingltd.com/
Link Market Services including Treasury Services –
United Kingdom, Jersey, Guernsey and the Isle of Man
https://
www.linkassetservices.com/what-we-do/market-
services
Company Matters
Australia
https://www.companymatters.com.au/
United Kingdom
https://www.linkassetservices.com/what-we-do/company-
secretarial
Pacific Custodians
Australia
https://www.linkmarketservices.com.au/corporate/services/tru
/trustee-services.html
Technology & Operations
Link Digital Solutions – Australia
https://www.linkdigitalsolutions.com/
SyncSoft – Australia
Empirics – Australia
https://www.empirics.com.au/home/
Document Classification: Public
MUFG Pension & Market Services
Schedule B: Additional Privacy Requirements
For EU and UK residents, in addition to those obligations outlined in Section 5 of this Policy,
the following additional rights apply globally:
Under UK and European law, there must be one of the following lawful bases for us to process your
Personal Information:
• Contract – The processing of Personal Information is necessary for the performance of a
contract to which you are party;
• Legitimate interest – The processing of Personal Information is necessary for our
legitimate interest (and when the processing of your Personal Information is based on our
legitimate interest(s), we ensure that our interests do not unfairly override your rights and
freedoms);
• Consent – Where you have given us clear consent to process your Personal Information
for a specific purpose;
• Legal obligation – The processing of Personal Information is necessary for us to meet
our legal and regulatory obligation(s); or
• Public interest – The processing of Personal Information is necessary for reasons of
public interest.
For EU and UK residents, the following outlines how we approach transferring and
processing your Personal Information internationally:
We have adopted the EU and UK GDPR to inform our global privacy and data protection standards.
EU and UK residents are advised that sometimes MUFG Pension & Market Services entities or third
parties who we share your Personal Information with (see Section 6 of this Policy), will process your
Personal Information outside of the EU and UK.
If you are an EU or UK resident, when your Personal Information is processed outside of the EU or
UK, we will ensure that appropriate safeguards are in place. We will also require that any such MUFG
Pension & Market Services entity or third party outside of the EU or UK has put in place adequate
safeguards to ensure that your Personal Information is held securely and in accordance with this
Policy.
If we are to undertake a transfer of your Personal Information to a non-adequate third country
(i.e., a country outside of the EU / EEA or UK that has not already been granted data “adequacy”
status from the EU Commission or UK government), we will, in line with our legal obligations: (a)
choose and implement an appropriate tool for the transfer; (b) complete a transfer impact
assessment; and (c) if necessary, choose and implement Supplementary Measures, aimed at
providing essentially equivalent protection to the GDPR.
If you would like further information on the safeguards, we use to share Personal Information
internationally, please contact your local Privacy/Data Protection Officer. Contact details can be
found in Schedule C of this Policy.
For EU and UK residents, in addition to those rights outlined in Section 9 of this Policy, the
following additional rights apply globally:
Right to erasure – you have the right to ask us to delete your Personal Information if our continued
use is not justified. This request will be balanced against other factors, depending upon the type of
Document Classification: Public
MUFG Pension & Market Services
Personal Information we hold about you and why we have collected it. There may be some legal and
regulatory obligations which mean we cannot comply with your request.
Right to restrict processing – you have the right to ask us to restrict our use of your Personal
Information if one of the following applies:
● If your Personal Information is not accurate;
● If the processing of your Personal Information is unlawful and you do not want us to
delete it;
● If we no longer need your Personal Information, but you want us to retain it for the
establishment, exercise or defence of legal claims; or
● Whilst we verify if we can uphold your objection to us processing your Personal
Information.
Right of data portability – you have the right to ask us to provide you with a copy of the Personal
Information that you have supplied to us in a commonly used machine-readable format or to transfer
your information directly to another data controller (e.g. a third party offering services competing with
ours). Once transferred, the other party will be responsible for looking after your personal information.
Right to object – You can object to us keeping or using your Personal Information in some
situations, this includes when our lawful basis for processing is in the public interest or in our
legitimate interest, or when your Personal Information is processed for direct marketing purposes
(see Sections 5, 10 and 11 of this Policy).
Right to withdraw consent – for certain limited uses of your Personal Information, we may ask for
your consent. Where we do this, you have the right to withdraw your consent at any time. If you
withdraw your consent, we may not be able to provide certain products and services to you. If this is
the case, we’ll tell you.
Right not to be subjected to automated-decision making (that is, using technologysolutions rather
than human judgement to automatically determine outcome – e.g. assessment of credit worthiness).
You have the right not to be subject to a decision based solely on automated processing, including
profiling, which produces a legal or similarly significant effect on you, unless it is:
● Necessary for a contract between us and you;
● Authorised by law; or
● Based on your explicit consent.
You can object to an automated decision we have made and ask that a person reviews it. Currently,
we do not make decisions about you solely based on automated processing.
In some circumstances exercising some of these rights will mean we are unable to continue providing
you with your investment or maintaining a business relationship with you.
For Australian residents, the following additional rights apply globally:
Personal Information includes Sensitive Personal Information, which includes the following
information for individuals in Australia:
• Trade union and/or political party affiliation; and
• Criminal records.
Document Classification: Public
MUFG Pension & Market Services
Anonymity and pseudonymity – Individuals dealing with us have the option of being anonymous
or using a pseudonym unless we:
• are required or authorised by law or a court or a tribunal order to deal with identified
individuals; or
• it is impracticable for us to deal with you if you have not identified yourself.
If we are unable to collect your personal information – In addition to not being able to provide
certain products or services to you, the following may also occur:
• we may not be able to provide you with information that you requested;
• we may not be able to offer you employment with us; and / or
• you may be subject to additional taxation or your assets or entitlements could be transferred
to ASIC, the ATO or to State revenue offices.
Dealing with unsolicited personal information – Generally, most information received by us is
immediately and automatically recorded (I.e. most telephone calls are electronically recorded and
most documents received are scanned into an electronic image.) This is necessary because we are
a trusted third-party record keeper, providing technical, administrative, support and/or financial
services involving day-to-day money and security asset movements, where imprecise record keeping
may have significant adverse consequences.
Where it becomes apparent that a communication contains unsolicited personal information that
could not otherwise lawfully be requested or used, we will make reasonable efforts to delete, destroy
or de-identify the record. Where it is impracticable to do this (for example, the unsolicited information
is combined with necessary information), the record will be retained, subject to the safeguards
detailed in this privacy policy.
Disclosing your personal information outside of Australia
– As part of providing services to you
and in our capacity as a service provider, occasionally personal information may be stored or
processed at locations outside of Australia.
We may disclose personal information to corporate and third party suppliers and service providers
located overseas for some of the purposes listed in Section 4 of this policy. They include: data hosting
organisations, IT service providers, and other third party vendor/suppliers located overseas.
Those countries that we may disclose your personal information to that are located outside of
Australia, include: China (Hong Kong), France, Germany, India, Luxembourg, New Zealand, Papua
New Guinea, the Philippines, and the United Kingdom, the United States of America, and United
Arab Emirates as at the date of this policy.
Enquiries and Complaints – Individuals may lodge an enquiry with us directly at any time.
Complaints should be lodged with us in the first instance and will be dealt with efficiently in
accordance with our established internal dispute resolution processes. If you are not satisfied with
how your complaint has been managed or if we have not responded to your complaint within 30 days,
you may escalate your complaint to the regulator – refer to Schedule D of this policy.
We encourage individuals wishing to make enquiries or lodge a complaint about how we handle
personal information to do so using any of the following means:
Telephone: + 61 1800 502 355 (free call within Australia)
9am–5pm (Sydney time), Monday to Friday (excluding public holidays),
Email: privacy.officer@linkgroup.com;
Post: Attn: Privacy Officer
MUFG Pension &
Market Services
Locked Bag A14
Sydney South NSW 1235
Document Classification: Public
MUFG Pension & Market Services
Schedule C: MUFG Pension & Market Services Privacy / Data Officer contact details
John Deane
E: John.Deane@linkgroup.co.uk
Data Protection Officer for:
MUFG Corporate Markets
● Link Market Services Ltd;
● Link Market Services Trustees Ltd;
● Link Registrars Ltd;
● Link CTI Ltd;
● Link Market Services (Isle of Man) Ltd;
● Link Market Services (Jersey) Ltd;
● Link Market Services (Guernsey) Ltd;
● Link Treasury Services Ltd;
● Company Matters;
● Orient Capital Ltd;
● Orient Capital GmbH; and
● D F King Ltd.
Privacy queries relating to:
MUFG Corporate Markets (Australia)
Grainne Mannion
E: Grainne.Manni[email protected]
Data Protection Officer for:
Banking and Credit Management
Document Classification: Public
MUFG Pension & Market Services
privacy.officer@linkgroup.com
Privacy que
ries relating to:
● Empirics Marketing Pty Ltd;
● Australian Administration Services Pty Ltd;
● Government Employee Superannuation Board (GESB);
● Link Super Pty Ltd (i.e. Russell); and
● The Superannuation Clearing House Pty Ltd.
Other Enquiries
Australia EU India Hong Kong New Zealand
Privacy.officer@
linkgroup.com
Data.protectionofficer
@linkgroup.co.uk
Privacy.officer@
linkgroup.com
Privacy.officer@
linkgroup.com
Privacyofficer@
linkmarketservices
.co.nz
Document Classification: Public
MUFG Pension & Market Services
Schedule D: Regulatory authority per jurisdiction
Country Authority Name Website Contact Details
Australia
Office of the Australian
Information Commissioner
(OAIC)
www.oaic.gov.au GPO Box 5218, Sydney NSW 2001
T 1300 363 992
United
Kingdom
Information
Commissioner’s Office
www.ico.org.uk
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
T +0303 123 1113 (or +44 1625 545745 if calling from
overseas) F 01625 524510
Germany Germany has a Data
Protection Authority for
each of the 16 German
states (Länder).
France
The « Commission
Nationale de
l’Informatique et des
Libertés » or « CNIL »
https://www.cnil.fr/en/home
3 place de Fontenoy
TSA 80175 75334 Paris Cedex 07
1. 01 53 73 22 22
53 73 22 00
Netherlands The Dutch Data Protection
Authority (Autoriteit
Persoonsgegevens)
Autoriteit Persoonsgegevens, Postbus 93374, 2509 AJ
DEN HAAG Telephone number: (+31) - (0)70 - 888 85 00
Document Classification: Public
MUFG Pension & Market Services
Country Authority Name Website Contact Details
Ireland
An Coimisinéir Cosanta
Sonraí (or the Data
Protection Commission)
www.dataprotection.ie
Dublin: 21 Fitzwilliam Square, Dublin 2, D02 RD28,
Ireland Regional Office: Canal House, Station Road,
Portarlington, R32 AP23 Co. Laois Telephone: +353 57
868 4800
Luxembourg
Commission Nationale
pour la Protection des
Données (CNPD)
Avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette,
T: +352 26 10 60 1 F: +352 26 10 60 29
Jersey
Jersey Office of the
Information Commissioner
https://jerseyoic.org
2
nd
Floor, 5 Castle Street, St Helier, Jersey, JE2 3BT.
T +44 (0) 1534 716530
Guernsey
The Office of the Data
Protection Authority
https://odpa.gg
St Martin’s House, Le Bordage, St. Peter’s Port,
Guernsey, GY1 1BR
Isle of Man
Isle of Man Information
Commissioner,
https://www.inforights.im
PO Box 69, Douglas, Isle of Man, IM99 1EQ
T +44 1624 693260
Hong Kong
The Office of the Privacy
Commissioner for
Personal Data
http://www.pcpd.org.hk/
12/F, Sunlight Tower, 248 Queen’s Road East
Wanchai, Hong Kong T +852 2827 2827 F +852 2877
7026
India No authority currently exists
