Privacy Policy
INTRODUCTION
At DBM, we are committed to protecting personal data and to fair and transparent processing. Please read our privacy statement: it will help you to understand how we collect and use personal data from individuals, our clients, suppliers or others during the course of our business. We will only use personal data for the purposes described in this privacy statement or as stated at the point of collection. We regularly review this privacy statement and may make changes at any time without giving notice.
OUR LAWFUL BASIS FOR PROCESSING
We rely on several lawful basis of processing when we collect and use personal data to operate our businessand provide products and services to our clients. These include:
- Public interests – where the processing of data is necessary for providing certain services to clients or for certain requirements we are subject to.
- Legal obligations – in order to comply with the legal and regulatory obligations we are subject to as a provider of regulated services and as a financial institution.
- Contract – in order to perform contractual obligations we may have with an individual or to take steps to enter into a contract with an individual.
- Consent – where an individual has freely given consent at the time their personal data was provided to us.
- Legitimate interests – The legitimate interests can be ours, our clients or other third parties (e.g. to provide our services, to develop or protect our business, or to keep people informed about relevant products and services) and we always balance the rights of individuals with ours’ and others’ legitimate interests.
HOW WE KEEP DATA SECURE
Security is of the upmost importance to us. Whilst no data transmission over the internet or any other network can be guaranteed as 100% secure, we take all reasonable steps to safeguard the personal data we hold, and we have in place appropriate technical and organisational measures. These include detailed policies, procedures and training of our people relating to data protection, confidentiality and information security. These are regularly reviewed to ensure they are effective and fit for purpose.
WHO WE SHARE DATA WITH?
We only share personal data with others when necessary for the purposes for which we hold it and where appropriate contractual arrangements and security mechanisms are in place.
- We may pass your personal data to:
- Related companies of DBM where needed to provide services to our clients and for administrative purposes suppliers that support us and help provide services to our clients, such as providers of cloud-based software, IT systems, security, archiving storage, recruitment, marketing and other related services
- professional advisors, auditors or insurers, where we are required by law or as reasonably required in the management of our business
- law enforcement or other government and regulatory agencies or to other third parties, where we are required by law, the courts or any legal or regulatory authority we are subject to. We will only provide personal data in this circumstance where permitted or there is a legal requirement.
- Whilst we store personal data on servers within the Bank or in our disaster recovery site, we may transfer personal data outside the Bank to related companies of DBM or other third parties that help us run our business. Contractual obligations are imposed on the recipients of any data transferred in order to ensure all personal data is protected to the standard required in the Data Protection Act 2017.
HOW LONG DO WE KEEP PERSONAL DATA?
We keep personal data only for as long as necessary and this will reflect the requirements of:
- the activity or service for which it is being processed
- any legal, regulatory or contractual requirements
- the time in which any litigation or investigations might arise from providing a service
- individuals’ rights
- individuals have certain rights over their personal data that we process as data controllers.
If we process your personal data and you exercise any of your rights, we will aim to respond promptly and within any required time limit. However, please note that the length of time it will take us to respond will be dependent on the nature and extent of your request.