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Data Protection Privacy Statement

This Privacy Notice explains who we are, how to contact us, when we collect personal data, how we use that data, how long we may keep that data and your rights.

We use your personal information in line with the rules set out in the Data Protection Act 2018. If you have any questions about the way in which we process personal data, please contact us.

The privacy policy does not cover any links within this site which are not controlled by the Clerk of Tynwald.

If you have any questions about the way in which we process personal data, please contact us (details at the bottom of this page).

Your personal data will not be used by the Clerk of Tynwald for any automated decision making.

Who we are

The Clerk of Tynwald is the controller for all personal data processed by the Clerk and staff in the Office of the Clerk of Tynwald.

The Office of the Clerk of Tynwald undertakes a parliamentary administrative function for Tynwald and its branches and Committees. The Clerk of Tynwald is the controller and processor for all information processed in Tynwald (the parliament) and through the Office of the Clerk of Tynwald.

Please be aware that the Clerk of Tynwald is not the controller for;

• any individual Tynwald Member, or

• the Tynwald Commissioner for Administration.

Tynwald Members and the Tynwald Commissioner for Administration are required to be registered as individual controllers in their own right.

Why we collect personal data

The Office of the Clerk of Tynwald collects and processes personal information to assist it with:

• the functioning of parliament

• undertaking substantive parliamentary business

• staff administration

• protecting the safety of officers and the public in the Tynwald Precincts

• the prevention and detection of crime using CCTV

Our legal basis for processing your information

We will only process your personal information if there is a legal reason for us to do so. We may rely on:

• the exercise of a function of Tynwald and its branches

• your consent – if we rely on your consent to process your information you may withdraw your consent at any time by contacting the Data Protection Officer

• the need to meet a request you have made for information or a service

• the need to retain information for historical or archiving purposes by the Public Record Office under the Public Records Act 1999 – more information on retention is available from the Public Record Office

The Isle of Man Information Commissioner’s website explains the conditions for processing personal data under GDPR: https://www.inforights.im/organisations/data-protection-law-2018/legislation-and-case-law/data-protection-act-2002/data-protection-principles/first-principle-fair-and-lawful-processing/conditions-for-processing-personal-data/

Collection and use of personal data

Committee Evidence

Parliamentary committees may choose to make public any information that is submitted to them. Personal contact details are routinely redacted in advance of publication but your submission may include information that can be used to identify individuals. If there is any information in a Committee evidence submission which you do not wish the Committee to publish, or which you believe the Committee should not publish, you should include this request with your submission and explain why. The Committee will take your explanation into account in deciding whether, and if so how much, to publish.

Any personal information you have given will be processed in accordance with the provisions of the Data Protection Act 2018 for the purposes of attributing the evidence you submit and contacting you as necessary in connection with its processing.

Committee information is retained indefinitely and is passed to the Public Record Office after 25 years. This is in accordance with our draft retention policy.

Processing of personal information by the Clerk of Tynwald on behalf of a parliamentary committee may be exempt from certain provisions of data protection legislation if the exemption is required for the purpose of avoiding an infringement of the privileges of Tynwald.

Petitions

Tynwald and its branches may choose to make public any information that is submitted to them. Petitions are published as a matter of routine. Personal contact details are routinely redacted in advance of publication but your petition may include information that can be used to identify individuals. Information which is not suitable for publication should not be included in petitions. If you have submitted a petition and subsequently find that it contains information which you believe should not be published, please contact us (details at the bottom of this page) explaining this. The Clerk of Tynwald will take your explanation into account in deciding what is published.

Any personal information you have given will be processed in accordance with the provisions of the Data Protection Act 2018 for the purposes of attributing the evidence you submit and contacting you as necessary in connection with its processing.

Information submitted for a petition is retained indefinitely and is passed to the  Public Record Office after 25 years. This is in accordance with our draft retention policy.

Processing of personal information by the Clerk of Tynwald for the purposes of the Petition processes may be exempt from certain provisions of data protection legislation if the exemption is required for the purpose of avoiding an infringement of the privileges of Tynwald.

Evidence submitted to Tynwald and its Branches

Tynwald and its branches may choose to make public any information that is submitted to them. This includes information submitted to Tynwald, the House of Keys or the Legislative Council in response to a request made by one of those Chambers. It also includes solicited or unsolicited information circulated by a Member, by the Clerk of Tynwald, or by anyone else. Personal contact details are routinely redacted in advance of publication but your submission may include information that can be used to identify individuals. If there is any information in a submission or circular which you do not wish to be published, or which you believe should not be published, you should make this clear within your submission and explain why. The Clerk of Tynwald will take your explanation into account in deciding what is published.

Any personal information you have given will be processed in accordance with the provisions of the Data Protection Act 2018 for the purposes of attributing the evidence you submit and contacting you as necessary in connection with its processing.

Information which is submitted in response to a request from a Chamber or is circulated to Members by the Clerk of Tynwald is retained indefinitely and is passed to the Public Record Office after 25 years. This is in accordance with our draft retention policy.

Processing of personal information by the Clerk of Tynwald in relation to the functioning of Tynwald and its Branches may be exempt from certain provisions of data protection legislation if the exemption is required for the purpose of avoiding an infringement of the privileges of Tynwald.

Provision of Visitor Services

We provide visitor services for conferences and events, visits and travel arrangements where personal data is collected in order to undertake the required activity. We will only use the personal data we collect to provide a specific service.

Your personal data will be retained in accordance with our draft retention policy.

Website

The Office of the Clerk of Tynwald does not automatically capture or store personal data from visitors to this site, except to log the user's IP address and session information such as the duration of the visit to the site and the nature of the browser used. This information cannot be used to identify individuals. It will be used only for administration of the system and in the compilation of statistics used to assess the level of use of the site.
Personal data in relation to statistical website information is retained for 12 months.

The Information Advertising Bureau website provides in depth information about cookies. This site also tells you how to remove cookies from your browser.

Enquiries

We will only use the personal data we collect to process your query and to check on the level of service we provide and will be retained in accordance with our draft retention policy.

We do not record telephone calls.

Any email sent to us, including any attachments, may be monitored for reasons of data security and compliance with office policy. Email monitoring includes blocking software which may result in your email being blocked or deleted.

Recruitment

Information you provide for recruitment purposes will be processed in accordance with the provisions of the Data Protection Act 2018 for the purposes of recruitment and for contacting you as necessary in connection with its processing.

Personal data in relation to recruitment is retained for six months in accordance with our draft retention policy.

Complaints

When we receive a complaint from a person we record details of the complaint in a file. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal data 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.

CCTV

Tynwald Precincts are monitored by CCTV cameras. Access to CCTV images is limited to the Seneschal and will be accessed only if an incident is recorded.

CCTV images are retained for 30 days in accordance with our draft retention policy.

Records

Your personal data may be transferred in accordance with our draft retention policy.

All Isle of Man public bodies have a legal obligation to transfer records to the Public Record Office if the records are selected for permanent preservation under the Public Records Act 1999. Records are selected for preservation at the Public Record Office if they have long-term research value, historical or cultural significance.

If your personal data is included in records selected for transfer to the Record Office, it will be retained securely and permanently. Records transferred to the Public Record Office may include special category (sensitive) personal data and data about children.

Access to and use of records at the Isle of Man Public Record Office is governed by legislation, in particular the Public Records Act 1999, the Public Records Order 2015 and the Freedom of Information Act 2015.

Where your personal data is included in records transferred to the Record Office, an assessment will be made of whether the records should be ‘closed’ (unavailable to the public for a certain time) based on this legislation.
Closure periods will be applied to records as appropriate under this legislation to prevent unlawful access to your personal data.

Your personal data, including data in closed records, may be shared with researchers for historical, statistical or scientific research purposes where this is lawful under section 4 of the Public Records Act 1999 and under Article 89 of the EU General Data Protection Regulation (Regulation (EU) 2016/679) and with regard to section 18 (2) of the GDPR and LED Implementing Regulations 2018.

Security of Information

The law mandates the Clerk of Tynwald to protect your personal information.

Access to the personal data you provide will be securely controlled and all processing will be undertaken in accordance with, and as permitted by, the requirements of the Data Protection Act 2018.

We keep all personal information in line with our retention policy. It is retained in a secure environment and access to it is restricted according to the ‘need to know’ principle.

Sharing of Information

Where you provide personal information to the Office of the Clerk of Tynwald it will be used only for the purposes for which it was provided.

If the law allows, we may give information about you to Isle of Man Government Departments and similar bodies.
In most circumstances we will not disclose personal data without your prior knowledge. 

Requesting information we hold about you

Right of access to personal information

The Clerk of Tynwald will provide any individual with access to their personal data upon request, unless, and to the extent necessary, that the right of access is restricted.

If you require access to information we hold about you, please submit a Data Subject Access Request and address your request to the Data Protection Officer. We will respond to you within 30 days of receipt of your request. (Contacting us: see below)

The Information Commissioner’s website has an easy to follow guide on how to Make a Subject Access Request
The law allows us to refuse your request for information in certain circumstances.

Other rights

If we do hold information about you, you can ask us to correct any mistakes. You also have the right, subject to any statutory limitations, to object to processing, to erasure or restriction of processing, and to data portability.

No automated decisions, or profiling, are undertaken by the Clerk of Tynwald.

Should any information we hold about you be incorrect or inaccurate, please contact us.

You can read more about your rights by visiting the Isle of Man Information Commissioner's Office (ICO) website and reading about Data Protection law available at https://www.inforights.im/

Our Retention Policy

Our draft retention policy is available on request. Please contact us using the details below.

Contacting Us

Contact details for the Office of the Clerk of Tynwald are:

Office of the Clerk of Tynwald, Legislative Buildings, Finch Road, Douglas, Isle of Man, IM1 3PW

The Office of the Clerk of Tynwald also has a designated Data Protection Officer (DPO). If you wish to contact the DPO directly you can write to the DPO at the address provided below, or email dpo@tynwald.org.im 

If you would prefer to write to us please address your letter to:

Data Protection Officer, Office of the Clerk of Tynwald, Legislative Buildings, Finch Road, Douglas, Isle of Man, IM1 3PW.

The Office of the Clerk of Tynwald is open to the public between the hours of 09.00 and 17.00 Monday to Friday. We will endeavour to respond to you by the next working day.

If you wish to complain about our use of your personal data you may complain to the Isle of Man Information Commissioner - https://www.inforights.im/