Introduction
We, Drummond Business Services Jamaica (“DBS Jamaica”, “us”, or “our”) are strongly committed to protecting personal data. This transparency notice describes why and how we collect and use personal data and provides information about individuals’ rights. We may use personal data provided to us for any of the purposes described in this transparency notice or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. DBS Jamaica processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data.
Security
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Collection of personal data
DBS Jamaica processes personal data about contacts (existing and potential DBS Jamaica clients and/or individuals associated with them) using a customer relationship management system (the “DBS Jamaica CRM”).
The collection of personal data about contacts and the addition of that personal data to the DBS Jamaica CRM is initiated by a DBS Jamaica user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the DBS Jamaica CRM may collect data from DBS Jamaica email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between DBS Jamaica users and contacts or third parties.
Visitors to our websites are generally in control of the personal data shared with us. We may capture limited personal data automatically via the use of cookies on our website. Please see the section on Cookies below for more information.
We receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual subscribes to updates from us.
Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.
We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.
Cookies
We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you. The use of cookies is now standard operating procedure for most websites. However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. You need to accept cookies in order register on our website. You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish.
Use of personal data
Personal data relating to business contacts and website visitors may be visible to and used by DBS Jamaica users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:
In addition, the DBS Jamaica CRM uses an algorithm to evaluate the strength of interactions between a DBS Jamaica user and a contact. This ranking is primarily based on interaction frequency, duration, recency and response time.
Unless we are asked not to, we may also use your data to contact you with information about DBS Jamaica’s business, services and events, and other information which may be of interest to you. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email.
Legal basis for processing
We will process our business contacts’ and website visitors’ personal data based on our legitimate business interests or the consent, if the data subject has been requested to express one. We have an interest in marketing our services or providing communications which we think will be of interest to recipients.
Data retention
Personal data will be retained on the DBS Jamaica CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).
Legal basis for processing
The legal bases for processing activity are specified above. When we process personal information for our legitimate interests, we make sure to consider and balance any potential impact on a data subject (both positive and negative), and the data subject’s rights under data protection laws. Our legitimate business interests do not automatically override the interests of the data subjects – we will not process personal data for activities where our interests are overridden by the impact on the data subject (unless we have the consent or are otherwise required or permitted to by law).
When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
We are part of a network of common interest firms and in common with other professional service providers, we use third parties located locally and in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located.
In respect of personal data being regulated in certain regions, please note that: cross border transfers may include countries outside the regulated areas and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside these regions are done lawfully.
Personal data held by us may be transferred to:
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy statement was last updated on 16 January 2025.
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us.
Amendment of personal data
To update personal data submitted to us, you may email us or, where appropriate, contact us via the relevant website contact page or by amending the personal details held on relevant applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us or, to stop receiving an email from a DBS Jamaica marketing list, please click on the unsubscribe link in the relevant email received from us.
Right to restrict or object to our processing of personal data
You have the right to restrict or object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.
In such case, we will no longer process or restrict the processing of the personal data, unless we can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
Other data subject rights
This transparency notice is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access, amendment and restriction or objection to processing referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion and the right to data portability.
If you wish to exercise any of these rights, please send an email.