Introduction

This is a guide to how we use your personal information to do the work that we do, and how we protect your privacy. It explains: 

• The types of personal information our office collects, and how we use it 

• How we keep your personal information safe 

• How long we keep your personal information for 

• What your rights are, and
  Who you can talk to if you are unhappy with the way we use your personal information. 

The Office of the Children’s Commissioner for Jersey is registered as a ‘Controller’, under the Data Protection (Jersey) Law 2018 (the DPJL) as we collect and process personal information about you. We process and hold your information in order to carry out public functions and meet our statutory obligations primarily under the Commissioner for Children and Young People (Jersey) Law 2019. When we say “process” we mean how we collect, record, hold, use, share and ultimately dispose of your information. 

We will regularly review and update this privacy notice to reflect changes in our services and any feedback we receive, as well as to comply with changes in the DPJL. You should therefore check this policy from time to time to ensure that you are happy with any changes. It is important to us that you can use and understand this guide. If you have any ideas about how we can make this privacy notice better, please contact us with your suggestions. 

This privacy notice is available on our website www.childcomjersey.org.je

WHAT

What information do we collect about you? 

Personal information: 
Your personal information is any information that can be identified as being about you. For example, imagine we sent out a form that asked you to tell us your name, which school you go to and your opinion about something. Your name and the school you go to would be your personal information, because we could use it to identify you. 

The type of information we collect will depend on why you’re in contact with the office, but the below are examples of the types of personal information we might collect about you: 

We may collect the following types of information about you: 

• name;

• email address;

• telephone number; 

• address;

• bank account (for employment or invoice payment purposes only);

• data for employment and recruitment purposes; gender; and

• date of birth.

• Photos from events for promotional material 

Special Category Data:
Special category information is particularly sensitive personal information. Because it’s more open to misuse than other personal information and because of this, we need to be extra careful in how we process this data. 

It includes information about someone’s: 

• race or ethnic origin

• political opinions 

• religious or philosophical beliefs 

• trade union membership 

• medical data (including details about a person’s disabilities) 

• sex life 

• sexual orientation 

• criminal record or alleged criminal activity 

Sometimes we will need special category data to help us resolve issues that affect the rights of individual or groups of children and young people in Jersey.

WHY

Why do we collect information from you and how do we use it? 

We collect and use personal information from you in several ways: 

Advice and support: 

• When you contact us to ask for information, advice or tell us about a children’s rights issue we use the personal information you provide to allow us to respond to you (this includes when you contact us via our online web form, via email, in person or by phone) 

• Sometimes, where there is an overriding public function or public interest, and where we have a legal basis to do so, we may need to contact another organisation about a problem you have raised. 

•  One of our jobs is to consider and carry out investigations of organisations who have not upheld children’s rights. To help us do this job we may require more information from you, the organisation or someone else who has the information we need. Sometimes this information will be about you. 

Complaints to us: 

• When you bring a complaint to us about the Commissioner, one of our employee’s or about how we are doing our job, we will use the personal information you provide to allow us to respond to you. 

Contacting and visiting us: 

• When you are requesting or attending a meeting with us we use the personal information you provide to allow us to manage the meeting. 

• When you contact us, we will use the personal information you provide to allow us to respond to you. 

• When you visit us in our office, we have CCTV for the purposes of security and staff safety and wellbeing – images may be used as evidence should acts of an illegal nature occur. 

Supply of products or services: 

• When we agree to a contract for a product or service that you or your company provide, we may use the personal information you provide to allow us to manage that contract. 

• When we purchase a product or service from you or your company, we may use your personal information to allow us to pay for it. 

Data protection rights and freedom of information requests: 

• When you send us a request to access your personal information that we hold we will use your personal information to allow us to respond to you. 

• When you send us a freedom of information request or request for a review, we will use your personal information to allow us to respond to you. 

Events: 

• When we are hosting an event, we may use your contact details to allow us to invite you to the event. 

• When you register to attend one of our events, we will use your contact details and other information that you have provided (e.g. dietary requirements) to help us manage the event. 

• When we hold events, we may take photos of you to use in future promotional material.

Recruitment: 

• When you submit a job application to us we will use the personal information you provide to allow us to recruit the most suitable candidate for the job. 

• When you are interviewed for a job with us we will use interview evaluations and external references about you to allow us to recruit the most suitable candidate for the job. 

Survey responses: 

• We need information to allow us to fulfil our statutory functions to promote and protect the rights of children and young people. Surveys can be a useful way for us to collect this information. When you respond to one of our surveys we will collect and analyse the information you give us. We will not keep your response after the work has been completed. We will use a third-party (Smart Survey) to manage our survey. 

Using our website and social media: 

• When you use our website, we collect information to help us understand how our website is being used. You can find out more about how and why we do this in our cookie’s privacy notice. 

• When you send us a direct message via social media, we will use the personal information you provide so we can respond to you.

HOW

How will we use the information about you and who will we share your data with 

Protecting your privacy and looking after your personal information is important to us. We work hard to make sure that we have the right policies, training and processes in place to protect our manual and electronic information systems from loss, corruption or misuse. Where necessary we use encryption, particularly if we are transferring information out of the department. Encryption means the information is made unreadable until it reaches its destination. 

We will use the information you provide in a manner that conforms to the Data Protection (Jersey) Law 2018. 

We may not be able to provide you with a service unless we have enough information or your permission to use that information. 

We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances, local legislation sets the length of time information has to be kept. Please ask to see our retention schedules for more detail about how long we retain your information. 

If you have contacted us to ask for information, advice or to tell us about a children’s rights issue we might need to contact another Government department or organisation about a problem you have raised so that we can look into your concern. 

There might be other situations where we will need to share your personal information with someone outside the Children’s Commissioner’s Office. We have listed when and why we would need to do this below: 

• We may share your personal information if we’re worried about your health or safety, or the safety of someone close to you. This might involve us contacting:

• Your social worker

• The Multi-Agency Safeguarding Hub (MASH)

• States of Jersey Police

• Jersey General Hospital 

• We must release your personal information if a court or law requires us to. 

• We use companies to provide us with services, and they may need to process personal information to do this. This may include people or organisations that provide us with:

• IT services

• Website hosting

• Legal services

• Confidential waste services

• Professional advisers and consultants
  
  

• We do not use web services that are hosted outside the European Economic Area. 

• At no time will your information be passed to organisations for marketing or sales purposes or for any commercial use without your prior express consent.

Publication of your Information

We may need to publish your information on our website, for example, where you have responded to a public survey or consultation, although your data or comments will always be anonymised to protect your identity. Where we have taken photos from events or projects, we may publish photos which contain your image, on our website, for promotional purpose. where you have given, us consent to do so. 

Email and Letters

If you email us or contact us by post we may keep a record of your email address and a copy of the email or letter for record keeping purposes. 

We will not share your email address or your email contents unless it is necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation or where permitted under other legislation. 

Telephone Calls

We do not record or monitor any telephone calls you make to us using recording equipment, although if you leave a message on our voicemail systems your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record keeping purposes. We will not pass on the content of your telephone calls, unless it is necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation or where permitted under other legislation.

Your rights

You can ask us to stop processing your information
You have the right to request that we stop processing your personal data in relation to any of our services. However, this may cause delays or prevent us from delivering a service to you. Where possible we will seek to comply with your request, but we may be required to hold or process information to comply with a legal requirement. 

You can withdraw your consent to the processing of your information
In the few instances when you have given your consent to process your information, you have the right to withdraw your consent to the further processing of your personal data. However, this may cause delays or prevent us from delivering a service to you. We will always seek to comply with your request, but we may be required to hold or process your information in order to comply with a legal requirement. 

You can ask us to correct or amend your information
You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary. We will seek to ensure that corrections are made not only to the data that we hold but also any data held by other organisations/parties that process data on our behalf. 

You request that the processing of your personal data is restricted
You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed is inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request, but we may be required to continue to process your information in order to comply with a legal requirement. 

You can ask us for a copy of the information we hold about you
You are legally entitled to request a list of, or a copy of any information that we hold about you. However, where our records are not held in a way that easily identifies you, for example your response to anonymous survey, we may not be able to provide you with a copy of your information, although we will do everything we can to comply with your request.

Complaints

You can complain to us about the way your information is being used. 

If you have an enquiry or concern regarding the processing of your personal data, please contact our Data Protection Coordinator in the first instance 

Telephone: +44 (0)1534 867310
Email: contact@childcomjersey.org.je 

Office of the Children’s Commissioner for Jersey 2nd Floor
13 Broad Street
St Helier
JE2 3RR 

You can also complain to the information Commissioner about the way your information is being used.

The office of the information Commissioner can be contacted in the following ways:

Telephone: 44 (0)1534 716530
Email: enquiries@occj.je

Office of the Information commissioner
2nd Floor
5 Caste Street
St. Helier
Jersey
JE2 3BT