This policy applies to Russell Investment Group Limited, a member of the Russell Investments group of companies and referred to as "Russell Investments" or "We" throughout this policy.
This policy sets out what information we collect, how we use, disclose and store it, and what your rights are under the New Zealand Privacy Act of 1993, herein referred to as the "Privacy Act". The Privacy Act sets out how agencies should collect, use, disclose and provide access to personal information about their customers.
2. Russell Investments' Commitment
Russell Investments is committed to maintaining the privacy of individuals whose personal information we collect in accordance with the Privacy Act. This document sets out Russell Investments' policy on the management of personal information, together with what sort of information we hold, for what purposes, and how we collect, hold, use, disclose and provide access to that information.
3. Russell Investments' Activities
Russell Investments provides investment solutions and advisory services to institutional or habitual investors in New Zealand. Russell Investments also distributes funds managed by its affiliates to the NZ market, including through arrangements with other financial service intermediaries such as banks, platforms and investment advisers.
4. Why Russell Investments Collects Information
Russell Investments collects personal information where Russell Investments is:
- obligated by relevant legislation or regulation; and/or
- collection of the information enables or facilitates the efficient provision of the services provided by Russell Investments and/or its affiliates.
5. How Personal Information is collected
Personal information is primarily collected directly from you or your representative whom you have authorized to provide us with your information. Information is collected in a number of ways including:
- in written form (usually signed by the individual);
- electronically (via email or a website); or
When you visit a website hosted by Russell Investments we may set a 'cookie' on your machine (this is a small piece of system information stored on your hard drive) so when you next visit our site it links to your personal information that is stored on our system. If you do not wish us to use a cookie you can set your browser so it will not accept them.
Our website may contain links to other sites. We are not responsible for the privacy practices or the content of these websites.
We will take steps to ensure that personal information we hold is accurate, complete and up-to-date. If you think that we hold information about you that is incorrect in any way, please contact us.
6. What Personal Information is collected
Under this policy, "personal information" is any information about an individual (a living natural person) as long as that individual can be identified. We will only collect personal information that is necessary so that we can provide you with a financial service or product, information about a financial service or product or other information that you have requested from us.
If you provide incomplete or inaccurate information, we or our affiliates may not be able to provide the financial service or product or information to you.
7. How Personal Information is used
We or our affiliates use personal information to provide you with financial products and services. We may use personal information for related purposes. We may share personal information with our affiliates, where it will remain confidential. We may use personal information to notify you about products and services that we, or our affiliates, offer.
We or our affiliates use external service providers, for example, for administration, custody or management of our financial products and services. We may provide your personal information to these service providers. The information will only be used for the purpose of providing the service.
We or our affiliates will only disclose personal information to a third party with your consent or as permitted by law or the Privacy Act, this includes for the purposes of direct marketing. We will not sell your personal information to third parties.
If you do not want to receive communications from us and our partners, please contact us.
On websites hosted by Russell Investments the collected data is used to help us determine which pages are most popular, peak usage times and other information to help us make our sites more efficient and easier to use. We use your IP address to help diagnose problems with our server, to administer our websites and to gather broad demographic information.
8. Disclosure of Your Information
Personal information is only disclosed in the course of services provided to you by us or our affiliates. For example, personal information may be accessed by, or disclosed to the trustee or responsible entity of the funds, mailing houses, legal and tax advisers, service providers, insurers, regulators and courts.
Personal information that has been collected will not otherwise be disclosed unless:
- it is public information;
- express consent is given by the individual affected;
- disclosure is authorised or required by law;
- collection would not prejudice the individual; or
- the individual cannot be identified.
Like many businesses, Russell Investments, our affiliates and our outsource partners may use other providers to help maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of Russell Investments, our affiliates and our outsource partners, such as mail houses, will sometimes have access to personal information held by us and may use it on our behalf. These providers are required to adhere to strict privacy guidelines and not to keep this information or use it for any unauthorised purposes.
9. Access to and Correction of Information Collected
Individuals will have access to their personal information collected and are able to notify us of any corrections which need to be made so as to ensure their personal information is accurate.
We will only grant access by an individual to personal information where the individual has given appropriate identification verification, which may be required in writing. We reserve the right to impose charges for providing such access to information.
10. Security of Information
Personal information collected by Russell Investments may only be accessed by our affiliates, officers, employees, agents and delegates.
The key personal information collected will be in hard copy and/or electronic format. The Russell Investments computer system is password protected to prevent unauthorised access. Personal information in written form is held in appropriately secure locations to minimise unauthorised access.
Russell Investments also hosts websites. Records are kept of visits to various parts of the site to observe trends and improve the quality of that site. To the extent to which we have links to other websites, we are not responsible for the policies and practices of those sites.
We will take all reasonable measures to protect personal information that we hold from unauthorised access, use, modification or disclosure. We will, where practicable, destroy or permanently de-identify personal information that is no longer needed.
11. Russell Investments' Contact Details
The Privacy Officer
Russell Investment Group Ltd
188 Quay Street
P.O. Box 105-191
Auckland, New Zealand