Privacy Policy

Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The Data Protection (Jersey) Law 2018 (DP(J)L) and the General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that DP(J)L & GDPR do not apply to information already in the public domain.

The Safeguarding Partnership Board is pleased to provide the following Privacy / Cookie Notice:

Personal Data

The Safeguarding Partnership Board uses the information collected from you to provide Advice, Guidance, make telephone contact and to email you information which the Safeguarding Partnership Board believes may be of interest to you and your family. In you making initial contact you consent to the Safeguarding Partnership Board maintaining a dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in providing our services.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. The Safeguarding Partnership Board may from time to time use such information to identify its visitors. The Safeguarding Partnership Board may also collect statistics about the behaviour of visitors to its website.

Cookies and how we use them

A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.

Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.

For more information on what cookies we use and how you can control them please visit our cookie notice here.

Legal basis for processing any personal data

We will only collect and process personal data about you where we have lawful basis. There are a number of lawful reasons for us to collect and use your personal data. These include consent (where you have given consent), Vital interest (where processing is necessary to protect your vital interests or the vital interests of another person), contract (where processing is necessary for the performance of a contract with you), Public Function (where we have a statutory duty), Employment and Social Fields (mainly for staff and employees) and Protection against malpractice and mismanagement (in order to protect the public against mismanagement and failures in the services provided by anybody or association which falls under our remit).

Public Function

The processing is necessary for –

(a) the administration of justice;
(b) the exercise of any functions conferred on any person by or under any enactment;
(c) the exercise of any functions of the Crown, the States or any public authority; or
(d) the exercise of any other functions of a public nature with a legal basis in Jersey law to which the controller is subject and exercised in the public interest by any person.

Vital Interest

The processing is necessary in order to protect the vital interests of –

(a) the data subject or another person, in a case where consent cannot be given by or on behalf of the data subject, or the controller cannot reasonably be expected to obtain the consent of the data subject;

or

(b) another person, in a case where consent by or on behalf of the data subject has been unreasonably withheld.

Consent

Where possible, we will always ask for your consent for the Safeguarding Partnership Board to process your personal data for the purposes outlined. You can withdraw consent at any time by emailing  [email protected] or writing to us (see last section for full contact details).

Contract

We have a lawful basis for processing if:

We have a contract with you and we need to process your personal data to comply with our obligations under the contract.

We haven’t yet got a contract with you, but they have asked us to do something as a first step (eg provide a quote) and we need to process your personal data to do what you have asked.

Employment and Social Fields

The processing is necessary for Employment, Social Security, Tax and other employment obligations on the controller.

Protection against Malpractice and Mismanagement

The processing –

(a) is in the substantial public interest;
(b) is necessary for the discharge of any function that is designed for protecting members of the public against –

(i) dishonesty, malpractice, or other seriously improper conduct by, or the unfitness or incompetence of, any person, or
(ii) mismanagement in the administration of, or failures in services provided by, any body or association; and

(c) in order not to prejudice the discharge of that function, is required to be carried out without the controller’s seeking the explicit consent of the data subject.

Disclosure

The Safeguarding Partnership Board may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. The Safeguarding Partnership Board requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and DP(J)L & GDPR.

The Safeguarding Partnership Board do not broker or pass on information gained from your engagement with the agency without your consent. However, the Safeguarding Partnership Board may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of the Safeguarding Partnership Board, its clients and/or the wider community.

Retention Policy

The Safeguarding Partnership Board will process personal data during the duration of any contract and will continue to store only the personal data needed for five years after the contract has expired to meet any legal obligations. After five years any personal data not needed will be deleted.

Data storage

Data is held in Jersey and the UK using different (multiple) secure servers. The Safeguarding Partnership Board does not store personal data outside the EEA. However, some companies that provide services to us run their services from outside the European Economic Area. We only let that happen if we are satisfied with their levels of security. Keep in mind that when you give us personal information it could be transferred, stored or processed in a location outside the EEA.

Your rights as a data subject

At any point whilst the Safeguarding Partnership Board is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is in accurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that the Safeguarding Partnership Board refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

The Safeguarding Partnership Board at your request can confirm what information it holds about you and how it is processed.

You can request the following information:

• Identity and the contact details of the person or organisation (The Safeguarding Partnership Board) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of the Safeguarding Partnership Board or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

The Safeguarding Partnership Board will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Safeguarding Partnership Board is dissatisfied with the quality, further information may be sought before personal data can be released.

Requests should be made through www.gov.je or follow Subject Access Request.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by the Safeguarding Partnership Board or its partners, you have the right to complain to the Safeguarding Partnership Board’ Board Manager. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The details for each of these contacts are:

The Safeguarding Partnership Board, attention of the Data Protection Advisor

16 Britannia Place
Bath Street
St Helier
JE2 4YS

Telephone: 01534 444516
Email: [email protected]

Jersey Office of the Information Commissioner

2nd Floor
5 Castle Street
St Helier
Jersey
JE2 3BT

Telephone: 01534 716530
Email: [email protected]