Effective Date: April 22, 2026

Entity: Comrade Trustee Services Limited (CTSL)

1. Introduction

Comrade Trustee Services Limited (“CTSL”, “we”, “us”) is committed to protecting the privacy and “Protected Information” of our members. As the Trustee for the DFRBF, we handle sensitive personal, financial, and employment data. This policy outlines our standards for data collection, use, and the governance structures we use to protect your information.

2. Data Governance Management Structure

To ensure accountability, CTSL operates under a multi-layered data governance framework:

• The Board of Directors: Holds ultimate legal responsibility for data protection and compliance with the Superannuation Act 2000.

• Audit, Risk & Compliance Committee (ARCC): Oversees the effectiveness of data security controls and audits the data handling practices of our external service providers.

   

• Fund Administrator (Kina Investments & Superannuation): Acts as the primary data processor, mandated to follow CTSL’s strict data protection protocols.

• Data Protection Officer (DPO): An internal role responsible for monitoring internal compliance and acting as a point of contact for member data inquiries.

3. Collection of Information

We collect “Protected Information” as defined under Section 104 of the Superannuation Act, which includes:

• Personal Identifiers: Name, date of birth, military ID, and gender.

• Contact Information: Physical address, email, and phone numbers.

• Financial Data: Salary details, contribution history, and bank account numbers for benefit payments.

• Beneficiary Details: Names and relationships of nominated beneficiaries.

4. Use and Disclosure of Data

Your data is used strictly for:

1. Fund Administration: Maintaining member accounts and processing contributions.

    

2. Benefit Payments: Assessing and paying out retirement, medical, or death benefits.

3. Communication: Sending annual statements and fund updates.

4. Legal Compliance: Reporting to the Bank of Papua New Guinea (BPNG) and Internal Revenue Commission (IRC).

Note: We do not sell member data. Disclosure to third parties is limited to authorized service providers (e.g., Kina Bank, Actuaries) under strict confidentiality agreements.

5. Data Security & Protection Standards

We employ “Defense-in-Depth” security strategies to protect member records:

• Encryption: All digital “Protected Documents” are encrypted at rest and in transit.

• Access Control: Only authorized personnel with a “need-to-know” basis are granted access to member databases.

• Physical Security: Hard copy records are stored in secure, fire-proof facilities with restricted access.

• Audit Trails: Every access or modification to a member’s record is logged and monitored for unauthorized activity.

6. Member Rights

Under our governance standards, members have the right to:

• Access: Request a summary of the personal information held by CTSL.

• Correction: Update or correct inaccurate personal or beneficiary information via a Member Details Update Form (MDUF).

• Anonymity: While limited by the nature of superannuation, you may browse our public website without providing personal data.

7. Data Breach Notification

In the event of a data breach that poses a risk to member identity or financial security, CTSL commits to:

1. Notifying the Bank of Papua New Guinea within the required regulatory timeframe.

2. Directly informing affected members with clear steps on how to protect their accounts.

8. Contact Information

For questions regarding this policy or to exercise your data rights, contact:

The Compliance Officer Comrade Trustee Services Limited

Level 6, Defense Haus, Hunter St, Port Moresby

Email: memberservices@ctsl.com.pg

Phone: +675  79987900