Effective Date: June 12, 2026

Entity: Comrade Trustee Services Limited (CTSL)

1. Your Privacy Matters

At Comrade Trustee Services Limited (CTSL), protecting your personal information is a core responsibility.

As Trustee for the DFRBF, we manage sensitive member information including personal, employment, and financial records. We are committed to handling that information responsibly, securely, and in accordance with applicable laws and regulatory standards.

This Privacy Policy explains:

• what information we collect,
• how we use it,
• how we protect it, and
• the rights members have regarding their personal information.

2. Our Commitment to Data Protection

CTSL maintains a strong governance framework to ensure personal information is protected and handled appropriately.

Oversight responsibilities include:

• the CTSL Board of Directors,
• the Audit, Risk & Compliance Committee (ARCC),
• our appointed Fund Administrator, and
• internal compliance and data protection personnel.

Together, these governance structures help ensure compliance with the Superannuation Act 2000 and other applicable legal obligations.

3. Information We Collect

To administer member accounts and provide fund services, CTSL may collect information such as:

• personal identification details,
• contact information,
• salary and contribution records,
• banking details for benefit payments, and
• beneficiary nominations.

This information is treated as protected and confidential.

4. How We Use Your Information

Your information is used only for legitimate superannuation and fund administration purposes, including:

• maintaining member records,
• processing contributions and benefits,
• communicating with members,
• complying with legal and regulatory obligations, and
• supporting the administration of the DFRBF.

We do not sell or trade member information.

Where necessary, information may be shared with trusted service providers such as administrators, banks, actuaries, auditors, and professional advisers who are required to comply with strict confidentiality and data protection obligations.

5. Protecting Your Information

CTSL applies multiple layers of security to protect member information from unauthorised access, misuse, loss, or disclosure.

Our safeguards include:

• encrypted systems and secure data transmission,
• restricted access controls,
• monitored audit logs,
• secure storage facilities for physical records, and
• ongoing oversight of external service providers.

Only authorised personnel with a legitimate business need are permitted to access member information.

6. Your Rights

Members may:

• request access to their personal information,
• request correction of inaccurate information, and
• update beneficiary or contact details through the appropriate CTSL processes.

You may also browse publicly available sections of our website without submitting personal information.

7. Data Breach Response

If a data breach occurs that may affect your privacy or financial security, CTSL will act promptly to:

• notify the relevant regulators where required; and
• contact affected members with information about the incident and recommended protective measures.

8. Cookies & Website Usage

Our website may use cookies and similar technologies to improve functionality, security, and user experience.

These technologies help us:

• understand website traffic,
• improve website performance, and
• enhance online services.

By continuing to use our website, you consent to this use.

9. Contact Us

If you have questions about this Privacy Policy or would like to access or update your information, please contact:

General Manager – Risk & Compliance

Comrade Trustee Services Limited (CTSL) Level 6, Defens Haus Hunter Street, Port Moresby Papua New Guinea

Email: randc@ctsl.com.pg
Phone: +675 7998 7900