Version: October 2018
This privacy notice was last updated on 19th October 2018 and is supplemental to the Department of Infrastructure’s main Privacy Notice.
This notice sets out the basis on which we collect and process your personal data through the use of our website, our digital applications, and/or signing up for newsletters and other activities either in person or online.
Any changes we make to this policy in the future will be posted on this page so please check this page regularly.
Who We Are
The Department of Infrastructure (using the brand name MyProm IOM for this project) is the Data Controller responsible for your personal data within the context of the data you choose to directly pass to us through our website, digital applications, marketing activities, by email, phone or face to face.
MyProm, Douglas Promenade Refurbishment (DPR) will sometimes refer to themselves in this notice as “we” or “us”. The Department will determine the purposes and way in which any personal data are, or will be, processed, in conjunction with the MyProm DPR team.
Our office is at the Sea Terminal Building (ground floor), Douglas, Isle of Man IM1 2RF.
If you have any questions about this privacy notice, the use of your personal information, your dealings with our website or our digital applications, you can contact us at email@example.com or see more information about the Department’s detailed Privacy Notice at https://www.gov.im/about-the-government/departments/infrastructure/data-protection/
Our Principles of Data Protection
The Department is committed to safeguarding the privacy of our website visitors and service users and complying with the General Data Protection Regulation and the Data Protection Act 2018.
Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you the best user experience.
We have published this notice to help you understand
- how and why MyProm DPR collects information from you;
- who we share your information with, why and on what basis; and
- what your rights are.
What information we collect and why?
Information you provide to us directly
When you visit or use some parts of our website and/or services we might ask you to provide personal data to us. For example we ask you for your contact information when you submit an enquiry, submit your CV for a job application, book an appointment, give feedback, send us a brief etc...
Where you are requested to fill in form (either online or offline), it’s your choice as to which fields to complete and with what data.
If you don’t want to provide us with your personal data you don’t have to but it might mean you can’t use some parts of our website or service.
Information we collect automatically
We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our website and digital applications such as what pages you looked at and what links you clicked on and so on. This information is useful as it helps us get a better understanding of how you use our websites and services so that we can continue to provide the best experience possible.
Information we get from third parties
The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials. We may use this information to supplement the personal data we already hold on you, in order to better inform, personalise and improve our services and to validate the personal information you provide.
Where we collect personal data, we’ll only process it:
- To perform a contract with you, or
- In accordance with a legal obligation or
- Where we have your consent
How do we use your information?
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
|What We Use Your Personal Information For||Our Reasons (Legal Basis)||Our Explanation Of MyProm IOM's legal basis for processing your data|
|To communicate with you||Consent||
To keep you up to date in the way you have indicated that you wish to be communicated with
|To advertise to you using targeted display advertising|
|To provide you with services||Contract or Legal Obligation||
In order to perform a contractual relationship
Provide you with the information you’ve requested
Operational communications like changes to our websites and services, security updates or assistance with using our services
|To detect, investigate and report financial crime (e.g. Fraud) and ensure compliance with a legal obligation||Legal Obligation||Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators. Complying with any regulations that apply to us. Complying with legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Process efficiency in dealing with such activity, and to make service and process improvements.|
|Maintaining network and data security||To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.|
Who we share your information with and why?
There may be times when we need to share your data with third parties. We will only disclose your personal data to:
- Within the Department of Infrastructure for the purposes of performing its contractual obligations and services
- Third party providers and partners who assist and enable us to use the personal data to support delivery of services or functionality of services
- Regulators, law enforcement, government agencies, courts or other third parties where we think it is necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights
- Other people where we have your consent
- Payment processors
- Sub processors who are vetted for GDPR compliance
- Debt Recovery, Credit Checking Services and Fraud Prevention Services
How long we keep your information?
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.
What are your rights
You are entitled to request the following from MyProm IOM, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk
- Right of access – to request access to your personal information and information about how we process it
- Right to rectification – to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased.
- Right to restriction of processing – to restrict processing of your personal information
- Right to data portability - to electronically move, copy or transfer your personal information in a standard form
- Right to object - to object to processing of your personal information
- Rights with regards to automated individual decision making, including profiling – rights relating to automated decision making, including profiling
If you have any general questions or concerns about your rights or want to exercise those rights please contact our Data Protection Officer at firstname.lastname@example.org or telephone 686785. If you wish to read the Department’s full Privacy Notice you can do so at https://www.gov.im/about-the-government/departments/infrastructure/data-protection/Updated on 22 January 2019