Privacy notice
Purpose and lawful basis for processing
The Isle of Man Information Commissioner (hereafter "we") currently acts as Secretariat and co-chair of the Common Thread Network (CTN), alongside the Data Protection Office of Mauritius as co-chair.
As part of our CTN Secretariat work, we process the personal data of CTN members, applicants and observers, and of members of the public who contact us through our communication channels.
We process this data to further international cooperation among authorities overseeing data protection and privacy legislation in the Commonwealth, and to fulfil our role as CTN Secretariat. This includes handling member and observer applications, supporting the establishment of CTN Working Groups, facilitating CTN events, and sharing CTN news and press releases with interested parties, including CTN members, observers and other stakeholders.
The lawful basis we rely on is Article 6(1)(e) of the Applied GDPR, which allows us to process personal data where this is necessary to perform a task carried out in the public interest or in the exercise of our official authority as the Isle of Man's data protection regulator. The Applied GDPR is the GDPR as it applies in the Isle of Man under the Data Protection (Application of GDPR) Order 2018.
Where we send you CTN news updates, we rely on your consent under Article 6(1)(a) of the Applied GDPR.
Where the information we process is special category data, we rely on Article 9(2)(g) of the Applied GDPR, which relates to processing necessary for reasons of substantial public interest.
What personal data we process
We process names and contact details to communicate with relevant individuals about the work of the CTN and its events. We may also process photographs, biographical information and survey responses received from members or individuals involved in CTN activities or, where relevant, attending CTN events.
What we do with it
We will use your name and contact details to correspond with you about the CTN. This includes communicating with you about news and events, and distributing key messages from the CTN membership.
Where we hold contact details for representatives of the media, we will use these to send press releases about the work of the CTN.
We will share data with our data processors (see below) where this is needed to fulfil our role as CTN Secretariat.
How long we keep it
We will keep this data for the duration of our tenure as CTN Secretariat. When our tenure ends, we will transfer the data to the authority taking over the Secretariat role.
Your rights
We process your personal data for our regulatory purposes, so you have the right to object to that processing under Article 21 of the Applied GDPR. There may be legitimate reasons for us to refuse your objection, depending on why we are processing your data.
We rely on your consent to process your contact details for sending you CTN news. You can withdraw your consent at any time. If you want to withdraw your consent to news updates, or object to our processing of your data more generally, please email international@inforights.im or call us on +44 1624 693260. We will then update our records to reflect your wishes.
For more information on your rights, please see 'Your data protection rights'.
Do we use any data processors?
Yes. We use the following data processors:
- IONOS
- Microsoft
Cookies
We only use cookies that are necessary for the functionality, security and accessibility of the website.
Do we transfer data overseas?
Yes. We transfer data from the Isle of Man to Mauritius, whose Data Protection Office acts as co-chair of the CTN, and to other CTN members, a list of which is available on this website.
Where a recipient country is not covered by adequacy arrangements recognised in the Isle of Man, we put in place appropriate safeguards in line with Chapter V of the Applied GDPR.
Controller's contact details
The Isle of Man Information Commissioner currently acts as Secretariat and controller for the CTN.
You can contact our data protection officer at DPO@inforights.im or using the details below.
Isle of Man Information Commissioner PO Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: ask@inforights.im