The Commissions Secretariat (the “Secretariat”) is the data controller for the processing of personal data defined under section 2 of the Data Protection Act (2021 Revision) (the “DPA”) on behalf of the AntiCorruption Commission (the “Commission”), and for the purpose of managing reports and/or complaints received in accordance with section 4 of the Anti-Corruption Act (2019 Revision) (as amended) (the “ACA”).
We are committed to making sure your personal data is safe and that you are informed as required under the DPA. This privacy notice contains clear and concise information about who we are and what we do with your personal data when you submit a report and/or complaint.
Any inquiries regarding this privacy notice and our privacy practices should be sent by email to firstname.lastname@example.org.
Our full contact details are as follows:
Manager, Commissions Secretariat: Marilyn Conolly
4th Floor, George Town Financial Center
PO Box 391
Grand Cayman, KY1-1106
Tel: +1 (345) 244-3685
E-mail: email@example.com or firstname.lastname@example.org
Personal data is information that relates to a living individual who can be identified directly from the information or indirectly when put together with other information. It also includes any expression of opinion or indication of intentions in respect of an individual.
We collect personal data for the primary purpose, under section 4 of the ACA, of receiving, considering, analysing, disseminating, detecting, investigating, processing, managing and doing anything else that is required or authorized for achieving the purposes of the ACA concerning any report(s) and/or complaint(s) of corruption.
If further information is needed from you relating to your report and/or complaint we will also use your personal data to enable the Commission or its staff to contact you to verify aspects of your report and/or complaint, carry out an investigation, or carry out other powers and duties as outlined in section 4 of the ACA. The personal data to be processed consists of:
Depending upon the initial assessment of your complaint by the Commission, you may be asked to supply additional information to us. For example, when submitting a complaint, you may be asked to provide additional details including, but not limited to, any third party information such as witnesses or information about person(s) that may be in possession of evidence.
Third party personal data will be processed and protected in accordance with the ACA and in compliance with the DPA.
We will only keep your personal data for as long as necessary in accordance with the Commissions Secretariat Disposal Authority and to fulfil the purposes we collected it for, including to satisfy any legal, accounting, audit or reporting requirements.
Your personal data will be stored securely and only accessed by authorized employees and other persons who act on our behalf.
We will under no circumstances sell or pass your information to third partiesfor the purposes of marketing or any purpose incompatible with the purpose for which it was collected.
Given the nature of the work of the Commission the security of data is paramount and your personal data will only be shared where absolutely necessary for the Commission to carry out its legal mandate. Therefore, your personal data may be disclosed to third parties who are also involved in investigations of breaches of the ACA. This includes other public entities who are data controllers for specific processing activities such as:
If your personal data are disclosed to any other person in order to facilitate investigation logistics, we will endeavour to inform you before this happens and let you know exactly who will receive your data and why. We will also only disclose the minimum amount of data necessary for that purpose.
The Commission may disclose your information under the ACA in relation to corruption, to the Cayman Islands Monetary Authority established by section 5 of the Monetary Authority Act (2018 Revision), or to such other institutions or person in the Islands as may be designated in writing by the Attorney General and may also disclose to any overseas anti-corruption authority as provided under section 5 of the ACA.
In limited circumstances, such as under court order, we may have a legal obligation or other reason to disclose your personal data to a third party that is unrelated to an investigation. This includes if we are required to participate in legal proceedings, obtain legal advice, or defend or exercise legal rights.
The ACA provides for disclosure of information by way of court order under section 33 in which a professional legal adviser is ordered to disclose information available to him or her in respect of any transaction or dealing relating to any property which is liable to seizure.
We may keep your personal data in our electronic systems, in the systems of our Data Processor, or in paper files.
We are committed to protecting your personal data. We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data. We may keep your personal data in our electronic systems, or in paper files. Systems and processes exist to prevent unauthorised access to, or disclosure of your data. We take all possible steps to protect the personal data we hold about you (on paper and electronically) in a secure way, and we will only make them available to those who have a right to see them. Examples of our security include:
Under the DPA you have rights in relation to your own personal data.
We want to make sure you are fully aware of all of your data protection rights. Every individual who submits a complaint is entitled to the following, amongst others:
Further information concerning individual rights can be found on the Ombudsman’s website at: ombudsman.ky/data-protection-organisation/individual-rights.
Exemptions may also apply, whereby specified rights or other provisions of the DPA do not apply. The DPA recognizes exemptions from the right to be informed which can be found on the Ombudsman’s website at: ombudsman.ky/data-protection-organisation/individual-rights/the-right-to-be-informed.
You can submit any requests, questions or complaints to us at email@example.com. Information about the Cayman Islands Data Protection Act is available on ombudsman.ky/data-protection.
Information about how to complain to the Ombudsman is available on ombudsman.ky/data-protection-organisation/individual-rights/the-right-to-complain-seek-compensation.
We have the right to update the contents of this Privacy Notice from time to time to reflect any changes in the way in which we process your personal data or to reflect legal requirements as these may change.
The "last updated" date is indicated at the bottom of this page. Any changes will apply to you and your data immediately.
Last updated 21 March 2023.