In this Policy:
Australian Privacy Principles refers to the set of harmonised, legally binding, privacy principles that regulate the handling, holding, accessing and correcting of Personal Information by businesses as set out in the Privacy Act.
DBS Group means DBS Australia, and its head office, branches, parent company, subsidiaries, representative offices, agencies and affiliates (including branches or representative offices of any subsidiary or affiliate).
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
Primary Purpose means the purpose for which Personal Information is collected. For example, for the purposes of staff recruitment, staff employment, providing products and services to our customers and anti-money laundering (AML), counter-terrorism financing (CTF), creditworthiness checks, other due diligence conducted by DBS Australia, business planning, enhancing our products and services or informing customers of DBS Australia’s services and benefits.
Secondary Purpose means a purpose other than the Primary Purpose of collection.
Sensitive Information means:
- Personal Information which comprises information or an opinion about an individual's:
- racial or ethnic origin;
- political opinions;
- membership of a political association;
- religious beliefs or affiliations;
- philosophical beliefs;
- membership of a professional or trade association;
- membership of a trade union;
- sexual orientation or practices;
- criminal record; or
- health information about an individual; or
- genetic information about an individual that is not otherwise health information; or
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- biometric templates.
3.Collection of Personal Information
Generally, DBS Australia collects and uses Personal Information about individuals, including our customers, persons associated with or employed by our customers, or our business contacts, to provide our professional services and to effectively manage our business relationships. We collect Personal Information through personal contact, records of communications and from third parties including public sources, credit reporting bodies, institutions or entities that employ or are associated with individuals, advisers, brokers, referrers or service providers.
The types of Personal Information we collect may be business contact details or may involve detailed knowledge of an individual's financial or personal circumstances, depending on the particular service we are required to provide. This information may include an individual’s name, mailing or residential address, email address, telephone number, facsimile number, age, date of birth, gender, nationality, residency status, passport number, driver’s licence number, profession, occupation, job title, credit eligibility information and financial details.
DBS Australia does not collect Sensitive Information unless we are authorised or required by law to do so or you have consented to us collecting that information from you for a particular purpose, in which case we will only use such information for that purpose. We may collect information about an individual’s affiliation with certain organisations, such as professional associations or bodies for purposes set out in this Policy.
If at any time you provide DBS Australia with Personal Information about another person, you will ensure that the person has been notified of all relevant matters required under the Privacy Act relating to our collection, use and disclosure of such information and has consented to the collection, use and disclosure of their Personal Information by us as set out in this Policy and any other additional privacy disclosures or materials we provide in connection with particular products or services we offer.
DBS Australia keeps Personal Information in physical and electronic records, at our premises and the premises of our service providers. Personal Information may be stored on sound recordings of your telephone discussions with us or computer and data storage systems which may include emails, servers, hard drives, applications and on the cloud. Where this occurs, we take steps to protect Personal Information.
4.Use of Personal Information
DBS Australia uses the Personal Information it collects and holds for either:
- the Primary Purpose;
- a Secondary Purpose where express consent has been obtained for such use, or it is related to the Primary Purpose of collection and would be reasonably expected; or
- where we are required or authorised to do so by law.
In general, DBS Australia collects, holds, uses and discloses your Personal Information to:
- provide our products and services to customers;
- understand you and meet your needs;
- process payments and refunds;
- verify your identity and Personal Information;
- maintain and update our records and carry out other administrative tasks;
- perform control and risk management functions (including monitoring credit exposure, conducting credit checks and audits generally and regulatory screening, monitoring and reporting);
- communicate and manage our relationship with you and your organisation (including conducting marketing and social functions);
- help manage and enhance our products and services, including by conducting market or customer satisfaction surveys and other research;
- carry out or deal with your applications or instructions (including AML, CTF, creditworthiness and other due diligence checks), enquiries and concerns;
- prevent, detect, investigate and deal with unlawful activity and misconduct (whether actual or suspected);
- comply with the requirements of any relevant law or regulation, any judicial, regulatory, supervisory, tax, fiscal, governmental or quasi-governmental body including a securities exchange and protect our lawful interests;
- process and respond to any request, query or complaint made by you.
We may not be able to do these things without your Personal Information. For example, we may not be able to provide our services, communicate with you or deal with your enquiries. We may also use, and disclose your Personal Information to anyone whom our assets or business (or any part of it) is transferred or offered to be transferred, in connection with acquisitions or potential acquisitions of our business.
We also use your Personal Information to promote and market products and services to you, including through telephone and electronic methods such as email, SMS, websites and mobile apps (or any other methods which become relevant from time to time). This is to keep you informed of products, services and special offers and may continue after you cease to acquire services from us.
If you do not wish us to contact you to promote and market products, services and special offers (whether it be through electronic methods or otherwise), or if you have subscribed to any of our newsletters or subscriptions and no longer wish to receive such communications, you may do so by contacting our Privacy Officer using the contact information below or by using opt out facilities provided in the marketing communications.
5.Disclosing Personal Information
We may disclose Personal Information to:
- other members of the DBS Group;
- service providers and professional advisers or consultants who have been contracted to provide administrative, financial, research, archival, auditing, accounting, insurance, valuation, customer contact, legal, business consulting, banking, payment, debt collection, delivery, data processing, data analysis, storage, information broking, research, marketing, investigation, website, technology, security or other services or business processes;
- insurers, other banks, auditors, valuers, lawyers, industry bodies, rating agencies, courts, tribunals, judicial, law enforcement, regulatory, supervisory and government authorities or bodies (including the Australian Tax Office and a securities exchange) as required or authorised by law or in accordance with their reasonable information requests; or
- your representatives and anyone else authorised by you, as specified or required by you or a contract or a transaction; or
- any financial institution or intermediary with which our customer has or proposes to have dealings or otherwise is in connection with provision of products or services;
- payment systems, clearing houses, trade repositories, exchanges, depositories or similar facilities or institutions whether pursuant to legislation, regulation or in connection with provision of services or products or otherwise in connection with the operation of DBS Australia business;
- anyone who takes over or may take over all or any of our rights or obligations;
- for the purposes of protecting or enforcing our rights and interests;
- as otherwise authorised or required by law.
DBS Australia does not disclose credit information or credit eligibility information in our possession to any credit reporting bodies.
6.Overseas disclosure of your personal information
DBS Australia operates and provides services and products to customers through, and with the support from, other members of the DBS Group and third parties located in multiple jurisdictions. There are situations where we may need to disclose Personal Information to other DBS Group members and third parties that may be located in Australia, Singapore and other countries (overseas recipients) where DBS Group operates. DBS Australia will only disclose or make available Personal Information to overseas recipients in accordance with the Privacy Act.
The countries in which overseas recipients are located may change from time to time. As such, for an up-to-date list of these countries please see the DBS Group website at https://dbswebprv-grp-p01.corp.dbs.com/gsmc-grp/about-us/our-global-offices/default.page.
While such overseas recipients will often be subject to privacy and confidentiality obligations, where you agree to this Policy you acknowledge and agree that APP8.1 will not apply to the disclosure of your personal information and you consent to such disclosures to overseas recipients:
- they may not always comply with those obligations or those obligations may differ from Australian privacy laws;
- we will not be accountable for any breaches by the overseas recipient of the Privacy Act or equivalent laws;
- you may not be able to seek redress under the Privacy Act; and
- the overseas recipient may be subject to foreign laws which might compel further disclosures of Personal Information (e.g. to government authorities).
7.Cookies and related technologies
A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our websites but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behavior of users visiting the website.
You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites.
8.Protecting Personal Information
Protecting Personal Information is a priority at DBS Australia. We take into account security and confidentiality when handling Personal Information in both the physical and electronic environment.
We have taken and will continue to take reasonable steps to protect your Personal Information from misuse, interference, loss and from any unauthorised access, modification or disclosure. We remind you, however, that the internet is not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.
Our websites may contain links to other websites not maintained by us. DBS Australia is not responsible for the privacy practices or the content of such other websites. If you provide any information to parties who operate websites that are linked to or from our websites, different rules may apply to their collection, use or disclosure of your Personal Information. We encourage you to review these websites’ policies before revealing any Personal Information. To the fullest extent permitted by law, DBS Australia will not be liable for any use of such websites.
Your Personal Information is kept for as long as it is required for the purpose for which it was obtained or as otherwise required by law. We take appropriate measures to destroy or permanently de-identify this information when its retention is no longer required. The types of measures we take vary with the type of information, and how it is collected and stored.
9.Access to and correction of Personal Information
We take all reasonable steps to ensure that the Personal Information we hold and use is accurate, complete and up-to-date.
You have a right to, and we will provide you with access to the Personal Information that we hold about you. When you request access to your Personal Information, we may need to take measures to verify your identity. In some circumstances it may not be possible to provide you with all of your Personal Information. When this is the case, we will tell you why unless we are unable to do so due to any law or regulation or otherwise.
You have a right to seek correction of the Personal Information we hold about you. If at any time your personal details change or you think that any Personal Information we hold about you is inaccurate, incomplete or out of date, you may request correction by contacting our Privacy Officer on the details below and we will use reasonable steps to update our records or ensure that it is corrected.
Please allow at least 30 days for us to respond to a request for access or updates to your Personal Information.
If you apply for a position at DBS Australia, we may also collect information about your qualifications, experience, employment history, character, screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability, drugs/alcohol and criminal record checks).
We collect, use and disclose your Personal Information to assess your application, conduct screening checks and consider and contact you regarding other positions. We may disclose your Personal Information to other third parties such as academic institutions, recruiters, screening check providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers.
Without your Personal Information we may not be able to progress your application for employment with us. When no longer required we will destroy or de-identify your Personal Information in accordance with our Document Retention Policy and the Australian Privacy Principles.
An individual who believes their privacy may have been interfered with by DBS Australia has the right to make a complaint about the matter by contacting our Privacy Officer at the contact details below. DBS Australia will investigate the complaint, respond to you promptly and attempt to resolve it.
If DBS Australia receives a request in writing from an individual seeking resolution of a dispute concerning one of its acts or practices in relation to credit reporting it must respond to the complainant, in writing, within 30 days of receipt of the request.
An individual who is dissatisfied with DBS Australia's handling of the complaint, or the outcome, may take his/her complaint to the Office of the Australian Information Commissioner.
Further information is available by phoning: 1300 363 992 or at: http://www.oaic.gov.au/about-us/contact-us-page.
12.Please contact us
- you would like to find out more about how DBS Australia manages the Personal Information it holds;
- you would like to express any concerns, or to make a formal complaint, about how we are handling your Personal Information;
- you would like to make a request for access to your Personal Information held by us; or
- you no longer wish to receive information about our range of services.
please contact our Privacy Officer at:
Post: Suite 1901
Level 19, Chifley Tower
2 Chifley Square
Sydney NSW 2000
Phone: +61 2 8823 9300
DBS Australia may update or modify its Policy at any time by publishing it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Policy.