How we use your information
The Isle of Man Information Commissioner is the data controller for any personal data you provide.
The information you provide will only be used to respond to your query or deal with your complaint and will be retained in accordance with our retention policy.
People who email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.
Data controllers who register (notify) under the Data Protection Act
Many businesses are required by law to ‘notify’ certain specified information to the Information Commissioner. This may contain personal information, for example where the business is a sole trader or an individual. The Commissioner compiles this information into a register which it is required by law to make publicly available. The Commissioner cannot therefore give any guarantees as to how the information contained on the register will be used by those accessing it.
When businesses fill in their registration forms, they are asked to provide the contact details of a relevant member of staff. The office will use this for its own purposes, for example where we have a query about a registration, but will not put it on the public register.
When we request information as part of the registration process, we make it clear where the provision of information is required by law and where it is voluntary.
Data controllers reporting a data security breach
We use the data collected to record the breach, to make decisions about the action we may take, and as relevant in order to carry out those actions. We retain personal information only for as long as necessary to carry out these functions, and in line with our retention schedule.
This means that logs and breach reports will be retained for two years from receipt, and longer where this information leads to regulatory action being taken. We retain de-personalised information about organisations for as long as is necessary to help inform future actions, but no individuals are identifiable from that data.
Complaints or queries
The Information Commissioner tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of the Information Commissioner’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Access to personal information
The Information Commissioner tries to be as open as possible in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request you need to put the request in writing to the Information Commissioner, PO Box 69, Douglas, IM99 1EQ.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting us.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 2 February 2017.