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Information we collect
Communications undertaken through IFM Group Systems
How we use your information
Grounds for processing
Disclosure of your information
Other organisations
Cookies
International transfers of personal information
Retention of your information
Security
Your rights
Status of this privacy notice

IFM Investors Pty Ltd (“IFM Investors”) and its subsidiaries (hereafter “IFM Group”, “we”, “our” or “us”) are committed to ensuring the confidentiality and security of your personal information and acting in accordance with your rights under data protection law.

Information we collect

When you register with IFM Investors, we will collect personal information from you which includes:

  • name, address, date of birth, gender, organisation, email address and any other information contained in the evidence of identity provided by you; and
  • contact numbers (including home number, mobile number, fax number and work number);

You will be unable to register and access the ‘members area’ of this website unless you provide this information. We also collect general information such as the pages you access, the date and time of your visit, your IP address, cookie identifiers, and the domain name and country from which you access this website.

In addition, we may collect personal information about you from related bodies corporate (including our ultimate parent, Industry Super Holdings Pty Ltd and its subsidiaries), service providers, business partners, government agencies and educational institutions. We may also collect information about you in the course of providing services to clients and investors in any IFM Funds, such as information about individuals authorised to act on behalf of the client or investor.

Communications undertaken through IFM Group Systems

All communications undertaken through IFM Investors and IFM Group systems (including, without limitation, email, text messages and instant messages) and all internet sites accessed are treated by IFM Investors and the IFM Group as business/work-related. IFM Investors and the IFM Group may monitor and, where relevant, intercept, your communications (whether sent or received and including the content of such communications) where it is appropriate and necessary to do so. For the avoidance of doubt, such interception shall be deemed necessary where it is for the purpose of fact finding during the course of an investigation or actual or threatened litigation proceedings. IFM Investors and the IFM Group may carry out such monitoring and interception without providing further notice to you. You acknowledge and agree that monitored and intercepted communications may be used as evidence in disciplinary or legal proceedings.

How we use your information

We use your information for the following purposes:

  • managing your registration and providing you with information you request;
  • providing investment management and related products and services to you (and/or your employer) (including carrying out diligence and administrative tasks prior to the provision of the services such as undertaking know your client checks and requirements);
  • receiving products and services from our suppliers in order to carry out our business mentioned in the preceding items;
  • to comply, or for our affiliates to comply, with applicable legal requirements under business, financial and employment legislation, e.g. (i) client or counterparty identification for the purposes of meeting anti-money laundering obligations, or (ii) authorised signatory verification to meet our obligations on preventing financial crime; 
  • administrative, financial accounting, risk analysis, fraud/crime prevention and client relationship purposes;
  • to correspond with you by email, such as to inform you about products or services you may be interested in, to manage our relationship with you, and to provide you with thought leadership, economic updates and similar publications; and
  • to manage conflicts of interest.

Grounds for processing

Our use of your information as described above is permitted by applicable data protection law because it is:

  • necessary for our or others’ legitimate interests in pursuing the purposes set out in (a) to (g) above, such interests in each case not being overridden by your privacy interests. For more information on how this balancing test has been carried out, please contact [email protected]
  • necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; and
  • necessary to comply with a legal obligation to which IFM is subject.

Disclosure of your information

We may disclose personal information to the following third parties: 

The IFM Group – we will share personal information in certain circumstances with the other companies across the IFM Group so that we can provide you with a high quality service across the IFM Group. We will also share personal information with the other companies across the IFM Group in connection with any transfer of IFM Group’s business or assets;

Our service providers – we will share personal information with our service providers who assist us in performing our functions and services. These service providers may include organisations that provide insurance and insurance broking, personnel, superannuation, payroll, archival, mail and delivery, auditing, professional advisory (financial, legal, tax and management consulting), banking, security or technology services. When disclosing personal information to third party service providers, we shall ensure that such third parties comply with the relevant laws and regulations concerning the protection of personal information.

Other organisations

  • If we're discussing selling or transferring part or all of an IFM Group, we may share information about you to prospective purchasers and their advisers - but only so they can evaluate the relevant business; 
  • If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide services to you;
  • If we are required to by law, under any code of practice by which we are bound or where we are asked to do so by a public or regulatory authority or governmental entity.

Cookies

We also use ‘cookies’, which are small amounts of information stored on your computer’s hard drive that allow us to recognise your computer when you visit the site. Most browsers can be configured so as not to accept cookies, however this may affect the functionality of the website.

International transfers of personal information

Entities in the IFM Group may share personal information with each other (including sending information to its international offices) for the purposes outlined in this notice. IFM may also share personal information with a third party carrying out services abroad for the IFM Group. This may result in your information being transferred from the European Economic Area (the “EEA”) to countries that the EU Commission has not declared to have an adequate level of data protection (e.g. Australia and the United Stated). IFM will not send your information to a party in another country, unless we have taken steps to ensure that the information will be protected to the standard required under the applicable privacy laws. To ensure an appropriate level of protection for personal information from the EEA, we typically use a data transfer agreement in the appropriate standard form approved for this purpose by the European Commission or (where applicable) relevant authority in the United Kingdom. Further details of these transfers and copies of these agreements are available from us on request. 

Retention of your information

We will keep your personal information for the longer of the period required in order to meet our legal or regulatory responsibilities, and the period envisaged within our retentions policy. We will never retain your personal information for longer than is necessary. In most cases, our retention period will come to an end 10 years after the end of your relationship with us. 

Security

IFM Investors uses appropriate security procedures and technology to keep your information secure.  However, users should be aware that the transmission of information to or from the website may not be totally secure. We utilise the United States NIST Cybersecurity Framework to help frame our policy and to manage and assess our controls to prevent, detect and respond to security risks.

Your rights

You have a number of rights under European Union data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal information we process about you.

These include:

  • the right to access a copy of the personal information we hold about you;
  • the right to correction of inaccurate personal information we hold about you;
  • the right to restrict our use of your personal information;
  • the right to be forgotten;
  • the right of data portability; 
  • the right to object to direct marketing; and
  • the right to object to our use of your personal information.

These rights are not absolute. If we do not comply with your request, we will explain why.

Where we rely on consent as the legal basis on which we process your personal information, you may also withdraw that consent at any time.

If you have any questions or wish to exercise any of the above rights, you may send an email to [email protected]. You can also use this e-mail address if you wish to make a complaint about how we process your information.

You can also lodge a complaint about our processing of your personal information with the Information Commissioner’s Office (www.ico.org.uk) or, if you are no longer resident in the UK, the relevant data protection authority in your country of residence.

Status of this privacy notice

This privacy notice was last updated in 29 October 2018.

It may be subject to amendments. Any future changes or additions to the processing of personal data as described above in this privacy notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

Please download IFM Investors Group Privacy Policy for details of the IFM Group’s Privacy Policy.