Legal Disclosure

Whistleblower Policy

For Australian Investors

IMPORTANT: You should read this Privacy Statement if you are an individual whose ‘personal information’ we collect. This Privacy Statement is our Privacy Policy for the purposes of the Privacy Act 1988 (Cth) (the Act) and provides information on how we manage your ‘personal information’, which is any information or an opinion about an identified or reasonably identifiable individual. It also provides information on certain matters relevant to individuals whose personal information we may collect, hold, use and disclose from time to time.


This Privacy Statement (the “Privacy Statement”), is the Privacy Policy of the following State Street entities, for the purposes of the Act and provides information on how your “personal information” is managed, including how it is collected, held, used and disclosed from time to time by these APP entities, which are all part of the “State Street Group”, including other branches, subsidiaries and related entities.

  • State Street Bank and Trust Company, Sydney Branch (ARBN  062 819 630)
  • State Street Global Advisors Trust Company (ARBN 619 273 817)
  • State Street Global Markets, LLC (ARBN 620 947 613)
  • State Street Global Markets International Limited (ARBN 120 116 065)
  • State Street GlobalLink Asia Pacific (ARBN 626 835 283)
  • State Street Australia Limited (ABN 21 002 965 200)
  • State Street Capital Pty Limited (ABN 87 083 100 832 )
  • SS Borrowdale Pty Limited (ABN 48 151 402 292 )
  • State Street Services Australia Pty Limited (ABN 38 151 402 247)
  • State Street Global Advisors, Australia, Limited (ABN 42 003 914 225)
  • State Street Global Advisors, Australia Services Limited (ABN 16 108 671 441)

In this document, “we”, “us”, “our” means the relevant individual APP entity.

We may make any changes to this Privacy Statement from time to time and for any reason. Any changes will be reflected in brochures and our website.


  • Respecting and protecting your privacy
  • Personal information we may collect
  • Why do we collect, hold, use and disclose personal information?
  • How we collect personal information
  • Do we disclose your personal information to others?
  • Anonymity and adoption of a pseudonym
  • Keeping your personal information secure
  • Keeping your personal information accurate and up-to-date
  • Accessing and correcting your personal information
  • Using our website
  • Cookies
  • How to contact us and handling of complaints

Respecting and protecting your privacy

At State Street we respect your right to privacy and are committed to ensuring your personal information is collected, used, disclosed, and maintained in accordance with the Australian Privacy Principles (APP) under the Act, our global and local policies.

We protect your personal information with the same integrity that we would use to handle our own individual personal information. This enables us to conduct business and exchange information in a secure environment, meeting employee, customer and regulator expectations for privacy, security and confidentiality.

Personal information we may collect

The type of personal information that we may collect and hold will vary depending on: (i) the service we provide, which includes custody, fund administration, funds management and other financial services or both; and (ii) the circumstances in which we are dealing with you. For example, in the case of SSAL, where you are engaged by, or connected with, our Client as its representative, such as officer, employee, agent or any similar capacity, or where you are a client of our Client, we will only collect and hold personal information relevant to the services we provide to our Client.

Also, where you have applied for a position with us, we will only collect and hold personal information relevant to that relationship with you.

The personal information we collect may include:

  • your full name, date of birth, gender and occupation;
  • contact details, such as your address, email address and telephone numbers;
  • tax file number and bank account details;
  • identification documentation (for example, a driver's licence or passport) ;
  • tax residency and taxpayer identification number used outside Australia;
  • information and documentary evidence about place of birth, residency and citizenship.

Where we collect certain information, for example, tax file number, and you choose not to provide the information, it may mean that we will not be able to provide the services that you require.

The Act restricts the collection of sensitive personal information. Sensitive information includes information about an individual’s racial or ethnic origin, health, criminal record, religious beliefs, or membership of a political, professional or trade association.  We may be required to collect and use sensitive information about you in order to provide the products and services you have requested but we will only do this with your consent unless we are permitted by law to do so without your consent

Why do we have to collect, hold, use and disclose personal information?

We collect, hold, use and disclose your personal information as is reasonably necessary to administer our products and services and manage our relationship with you, as well as to comply with our legal obligations and assist government and law enforcement agencies or regulators. For example, we may be required to disclose your personal information to Australian Government regulators such as the Australian Securities and Investments Commission (ASIC), Australian Tax Office (ATO), Australian Transaction Reports and Analysis Centre (AUSTRAC) and to other regulatory or government entities.

We may also collect, hold, use and disclose your personal information for the following purposes:

  • establish your identity and assess applications for products and services;
  • recruitment and employment purposes – for example, to assess your suitability to the position you are applying for;
  • engaging service providers, contractors or suppliers;
  • to maintain your details so we are able to respond to any of your inquiries or contact you;
  • dealing with complaints;
  • meeting legal and regulatory requirements. Various Australian laws may expressly require the APP entities to collect your personal information or the APP entities may need to do so in order to be able to comply with other obligations under those laws. Such laws include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (for example, to comply with obligations to combat money laundering and financing of terrorism), the U.S Foreign Account Tax Compliance Act, the Taxation Administration Act 1953, the Income Tax Assessment Act 1936 and other taxation laws (for example, to comply with obligations relating to employment or with information requests issued by the Commissioner of Taxation); enforcing our rights, including undertaking legal proceedings; promoting our products and services – for example, for direct marketing purposes where the law permits. In the event that you do not want to receive direct marketing materials please notify us using the contact details  on the last page or you may use the unsubscribe functionality available on our marketing documents to opt out from receiving direct marketing;
  • in other ways where permitted by law.

How we collect personal information

If it is reasonable and practical to do so, we will collect personal information directly from you. For example, if we are dealing with you as a representative of a Client (such as a director or other officer of a Client) or as a client of a Client, you may provide personal information as a result of your dealings with us. We may collect your personal information through application forms, over the telephone, via email, the internet, or in person when you visit our office. We may also collect your personal information when you call us. We may monitor and/or record telephone calls for the purposes of staff training and to verify statements made during the telephone call.

We may also need to collect personal information from third parties, including:

  • Client’s clients, for example, where SSAL provides unit registry services;
  • your representative (such as a legal adviser, financial adviser, accountant), for example where we need to verify information you have provided;
  • and government agencies, such as the Federal Police, for example where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation for reporting of the matter.

If you do not provide the information requested, or it is incomplete or inaccurate, we may not be able to provide the services to our Client or provide you with other opportunities (for example, a role with us) that you have applied for.

Do we disclose your personal information to others?

We may disclose or share your personal information for the purposes listed above or as otherwise permitted by the Act to third parties that include the following:

  • entities within State Street, locally or overseas, including without limitation the U.S., China, India and the Philippines;
  • entities outside State Street situated in Australia, the U.S., and the Asia-Pacific region (including without limitation, India, and the Philippines) – for example:

·  service providers to whom services may be outsourced such as mailing functions, statement production, information technology support and direct marketing services;

· insurers;

· superannuation funds;

· our accountants, auditors or lawyers;

· third parties that act on your behalf or that are otherwise connected with you (such as your legal adviser or financial adviser);

· courts, tribunals, government and regulatory agencies or bodies, police;

· other persons and entities as permitted under the Act.

State Street operates as a global organisation and certain functions operate from dedicated centres which also provide shared services around the globe. As referred to above, some related bodies corporate and other recipients to whom we disclose your personal information may be based overseas. We require overseas service providers to take reasonable steps to protect personal information from unauthorised use or disclosure in compliance with the APPs or ensure they operate in countries with laws to protect your information substantially similar to the protection provided by the APPs.

Anonymity and adoption of a pseudonym

Although the Act allows for you to deal with us anonymously or by using a pseudonym, we can only allow this in limited circumstances, such as in relation to enquiries of a general nature. We are unable to allow anonymous dealings or the adoption of a pseudonym in relation to more specific enquiries about your account with us.

Keeping your personal information secure

We have security systems, policies, processes and procedures that meet current industry standards, to protect your personal information from misuse, loss and unauthorised access, modification or disclosure and we regularly review their effectiveness. The only people who are allowed to handle or have access to your personal information are those employees of State Street Australia and the State Street Group and those who perform services for us who need your personal information to do their jobs.

Keeping your personal information accurate and up-to-date

We maintain the quality of your personal information by taking reasonable steps to make sure that the information collected, used and disclosed is accurate, complete and up-to-date and we encourage you to contact us about the changes to your personal details.

Accessing and correcting your personal information

You can request access to the personal information we hold about you by contacting us with your request, using the contact details set out below. We will need to verify your identity before completing your request.

We may not always be able to give you access to all the personal information we have about you. For instance, we may not be able to give you access to information that:

  • would reveal personal information about another person;
  • would reveal a commercially sensitive decision-making process;
  • we are prevented by law from providing to you; or
  • relates to existing or anticipated legal proceedings.

You can also request correction to the personal information we hold about you by contacting us with your request, using the contact details set out below.

Using our website

We do not use your browsing information to identify you personally.  We may record certain information about your use of our website, including which pages you have visited, the time and date of your visit and the IP address designated to your device.

We may also collect information such as the webpages that visitors to our site access, items downloaded, links from other sites they visit to reach our site, and the type of browser they use. Any such information does not constitute personal data and is only used for statistical and website development purposes.


State Street may periodically collect information from you through automated means. When you browse the Site, use the Services, or read our emails or newsletters, we may use "cookies" or other online tracking mechanisms in order to provide better service, facilitate your use of the Site or Services, store online preferences, track usage of the Site or Services, tailor the marketing of business services to our institutional customers, or enhance security.

How to contact us and handling of complaints

You can contact us about this Policy, to request access or correction to your personal information, or if you have a complaint about the way we handle your personal information, by;

  • sending a letter to the Head of Privacy APAC, Level 14, 420 George Street, Sydney NSW 2000, Australia.
  • calling us on: +612 9323 6000 or +612 8249 1100, and asking to be connected to the Head of Privacy APAC.

We aim to complete/resolve your request/complaint within 30 days of receiving it, or longer for a more complex request or complaint. Please note that our process also includes notifying our Global Privacy Office who will contact you to handle any privacy matter under the Privacy Act 1988 (Cth) or any other relevant privacy instruments in other jurisdictions including the General Data Protection Regulation 2016/679 (GDPR) in the EU (where applicable).

If you are unhappy with the handling of your complaint you may also contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, visiting or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.