Introduction

This Privacy Notice explains how Management Control Systems Limited (“MC Systems”) collects, uses, and discloses your personal information. The personal information we collect from you depends on the nature of the services we provide and how we interact with you.

Who We Are

MC Systems is a member company of The Jamaica National Group Limited. We provide leading edge technology solutions for businesses in the Caribbean.

Our Data Protection Commitment

The JN Group respects our customers, employees, and other stakeholders’ right to privacy. We commit to adopt and observe appropriate data protection standards in compliance with the Data Protection Act, 2020, the General Data Protection Regulations (GDPR), and all other applicable Privacy laws and regulations.

The Types of Information We Collect

We collect various types of information that may identify you as an individual (“personal information”). The personal information that we collect varies depending on the type of product being offered.

Personal Identifiers

• For example: name, photo ID, TRN

Contact Details

• For example: email address, telephone numbers, residential address, mailing address

Employment Information

• For example: employment status, employer name and address, employment history

Demographic Details

• For example: date of birth, gender, age, nationality, marital status

Banking Information

• For example: bank name and branch, account number, account type

Professional Information

• For example: company name, position

Health Information

• For example: medical history, family medical history, health status, test results and outcomes of medical reports

Employee Information

• For example: employment history, dependent information, emergency contact, background check information, character references, qualifications

Online Details

• For example: IP address, operating system, and browser type, when you visit our sites or use our online services.

Criminal History

• Criminal charges and convictions

How We Get Your Personal Information

Directly from You

• Request information about our products and services.
• Apply for a product or service from us.
• Speak to us on the phone or in one of our locations.
• Supply us with information in the normal course of our providing a product or service to you.
• Send us correspondences (such as letters and emails).
• Use our websites, web chats, and mobile device apps.
• Participate in customer surveys.
• Apply for and maintain employment with MC Systems.
• Attend an event hosted by us or take part in our competitions or promotions.

Indirectly

• Information we Collect Automatically
• Information Collected from Third Parties

How We Use Your Personal Information

We will use the information we collect about you, in connection with the following:

• To offer, administer and manage the products and services we provide to you.
• To carry out the services covered under our data processing contracts.
• To carry out “Know Your Customer” due diligence checks.
• To manage customer transactions.
• To administer, investigate and settle claims or complaints.
• To facilitate the prevention, detection, investigation and reporting of crime.
• To ensure adherence to internal controls and external regulatory requirements.
• To enforce our contracts and recover any outstanding debt.
• To fulfil our legal and regulatory obligations.
• To carry out “Know Your Employee” due diligence checks.
• To provide employment and post-employment benefits.
• To respond to your requests, inquiries, comments, and concerns.
• To manage how we work with other companies that provide services to us.
• To analyze trends, perform benchmarking, modelling, market research and data analysis.
• For research, audit, reporting and other business operations purposes.
• To tell you about products and services that may be of interest to you.

When We Share Your Personal Information

We do not rent or sell your information to anyone and will only share your information in circumstances where we are legally permitted to do so.

Our Lawful Basis for Processing Your Information

We rely on the following lawful basis for processing your information:

• Performance of a contract to which you are a party
• Compliance with a legal obligation or duty
• For the purposes of our legitimate interests or that of a third party
• Consent

International Transfer of Your Information

We will only send your data outside of Jamaica for the purposes outlined in this Notice.

Accuracy of Your Information

You should notify us of any changes to your personal information.

Retention of Your Information

We retain appropriate records of your personal information to operate our business and comply with our legal and regulatory obligations.

Information Security

The security of your personal information is important to us, and we have implemented appropriate security measures to protect the confidentiality, integrity, and availability of the personal information we collect about you.

Your Rights in Relation to Personal Data

You have the following rights under the Data Protection Act in respect of any personal information we collect and use about you:

• The right to access your personal data
• The right to consent to processing
• The right to prevent processing
• Rights in relation to automated decision making
• The right to rectification

How to Exercise Your Rights in Relation to Your Personal Data

You may exercise any of the rights available to you by contacting us using the information found in the “How to Contact Us” section of this Notice.

Use of Automated Decision-Making

Where you apply to receive a service from us, we may carry out an automated assessment to determine whether you are eligible to receive the service.

Marketing

Unless you have told us that you do not want to hear from us, we will send you relevant marketing information by mail, phone, email, text and other forms of electronic communication.

Use of Cookies and Other Technology

We use cookies and other internet tracking software to collect data while you are using our websites or mobile apps.

Links to Other Websites / Third Party Content

For your convenience, hyperlinks may be posted on our website that link to other websites. We are not responsible for these sites.

Information Pertaining to Children

We do not knowingly collect or solicit personal information directly from anyone under the age of 18.