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Privacy notice

Travel Notification Service (TNS)

This statement is designed to help you understand how your personal data is processed by the Travel Notification Service (TNS) and why. 

Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of TNS.  The definition of personal data includes any expression of opinion about you and any indication of the intentions of TNS or any other person in respect of you.

What personal data is processed and how is it used?

When you first register with the TNS using the online portal, you will be asked to provide identifier information such as your name and date of birth.  These will be used to create a record for you in the CRM, which is the database used by the COVID response team (the CRT) within the Isle of Man government for various COVID related functions.  You will also be asked if you are an Isle of Man resident because the border restrictions for Isle of Man and non-Isle of Man residents differ.

You will be asked to provide contact information such as your email address and telephone number and these will be used to keep in touch with you as necessary and to send you any Direction Notice that might need to be issued in relation to your travel.  This Direction Notice will include a reference number which is held within the CRM and is evidence that you have permission to enter the Island.

If you are not an Isle of Man resident, information about the purpose of your visit to the Island will be requested so that a decision can be taken as to whether there is an exemption available under the Public Health Protection (Coronavirus) Regulations 2020 to admit you to the Island.  Any further correspondence with TNS in this regard will also be retained. 

The address at which you will be isolating when you travel to the Island will be requested and you should be aware that this address can be used by the Ports Access Team (the PAT), a function of the CRT, to visit the address during your period of isolation to establish whether you are in compliance with any Direction Notice.  The start and end dates of your isolation will also form part of your isolation record as will the details of any visit undertaken by the PAT.

Prior to travelling to the Isle of Man, you will be required to complete a landing card.  You will be asked to provide the reference number referred to above and to confirm such information as your contact details and your isolating address.  You will be asked to provide details of your travel which includes the date and time of your intended arrival and how you plan to travel to the Island.  This information is used in the reports that are generated by the PAT to undertake access checks for each flight or sailing to the Island. 

The landing card contains a declaration in relation to your health in respect of COVID-19 and the fact that you completed this declaration is recorded in the CRM.  This is treated as special category data under the data protection requirements.

If you are an adult travelling with minors, you will be required to include information about those minors on your landing card.  This information forms part of your record in the CRM and a separate record is not created for any minor.

Where is the data stored?

Your data will be held within the CRM system which is owned by the Cabinet Office of the Isle of Man Government and which is hosted on servers located in the Isle of Man. 

Information about your travel to the Island will appear in the report that the PAT use to meet the flight or sailing on which you are arriving.  Information about your isolating address could appear in a report that the PAT use to undertake isolation checks on those who have travelled to the Island. 

Who can see the information?

Your personal data will be accessible to the CRT which includes TNS, PAT, the 111 service and Contact Tracing. 

Any isolation information that is held about you forms part of a view in the CRM called the isolation database for the period of time that you are required to be in isolation.  The Emergency Services Joint Control Room (the ESJCR) has access to this database on behalf of the emergency services and if you require the emergency services during your period of isolation, the ESJCR will share with the relevant service that you are in isolation in order that appropriate protective measures can be taken.

The IOM Constabulary can make requests to the CRT for information in the CRM.  Where such requests are made, these are subject to strict disclosure protocols and information will only be released where it is considered that there are appropriate legal grounds to do so.

Will your data be used for marketing purposes?

Your data will not be used for marketing purposes nor will your data be provided to any third party so that they can market their products or services to you.

How long is the data kept for?

The length of time we keep your data depends on the reason(s) that we hold your data in the CRM and some of these reasons require your data to be held for longer than others.  If you would like to find out more about the specific length of time your data will be held for, please contact the Cabinet Office Data Protection Officer using the contact information set out below.

Your rights

If you wish to see the data processed about you by the 111 team, please contact the Cabinet Office Data Protection Officer on;

Data Protection Officer
Cabinet Office
Government Offices
Bucks Road
Douglas
IM1 3PN

Email: DPO-CabOff@gov.im
Phone: +44 1624 686779

You have additional rights under the Isle of Man’s data protection legislation such as the right to rectification of incomplete data, the right to object and the right of erasure of data. 

If you wish to exercise those rights, or if you wish to make a complaint about how your data has been processed, please contact the Cabinet Office Data Protection Officer the details above.

You also have the right to request the Information Commissioner undertake an assessment as to whether the processing of your personal data has been carried out in accordance with the provisions of the Data Protection Act 2018. You can contact the Information Commissioner on =44 1624 693260 or by emailing ask@inforights.im.

Contact Tracing

This statement is designed to help you understand how your personal data is processed by Contact Tracing and why. 

Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of Contact Tracing.  The definition of personal data includes any expression of opinion about you and any indication of the intentions of Contact Tracing or any other person in respect of you.

What personal data is processed and how is it used?

Contact tracing will contact you either because you have tested positive for COVID-19 or because you are a high risk contact of someone who has tested positive.  If you have tested positive for COVID-19 you are referred to as an index case.

You are an index case

If you are an index case, there will already be information in the CRM about you from when you contacted 111 or a test was booked for you by another means.  Your contact details, which form part of that information, will be used to make contact with you for contact tracing purposes.  Your record will be updated with a case number which is used to link you to your high risk contacts within the CRM.

Contact Tracing will ask you a series of questions to establish whether any additional preventative measures need to be taken in any location where you might have been.  These questions will cover information, as applicable, about your workplace, any educational setting you may have attended, any healthcare setting you may have attended, any PPE that you may have used in any setting, any other location that you may have attended, how you travelled to any location, information about your household and information about any off Island travel.

To assist in understanding any risk to you and any further measures that may be necessary in that regard, Contact Tracing will ask whether you have any symptoms, what those symptoms are and other questions related to your general wellbeing.  Some of this information is prescribed by the World Health Organisation (the WHO) and is used for the collection of statistical information which is reported in an anonymised way to the WHO. 

For a period of 14 days from when you test positive, the 111 team may make contact with you on each and every one of those days to check on your welfare.  During any such contact, you may be asked whether you continue to self-isolate, whether you have had cause to ring 111 and whether you have developed any symptoms. 

You are a high risk contact

If you are a high risk contact, it is likely that your name and contact details will be provided to Contact Tracing by the index case.  You may, however, be contacting Contact Tracing yourself as a result of a request from the index case or in response to a public information notice from the Isle of Man Government. 

If a record does not already exist for you in the CRM, a record will be created capturing your name, date of birth and contact information.  Your date of birth is a helpful unique identifier should there be someone else in the CRM that has the same name as you. 

Contact Tracing will ask you a series of questions to establish whether any additional preventative measures need to be taken in any location where you might have been.  These questions will cover information, as applicable, about your workplace, any educational setting you may have attended, any healthcare setting you may have attended, any PPE that you may have used in any setting, any other location that you may have attended, how you travelled to any location and information about any off Island travel.

To assist in understanding any risk to you and any further measures that may be necessary in that regard, Contact Tracing will ask whether you have any symptoms and what those symptoms are.  Contact Tracing will also arrange any swabbing tests that are required as a result of you being a high risk contact.  The Privacy Notice in respect of the 111 team contains more information about the data that is obtained and recorded in relation to swabbing tests.

For a period of 14 days from when you are identified as high risk contact, the 111 team may make contact with you on each and every one of those days to check on your welfare.  During any such contact, you may be asked whether you continue to self-isolate, whether you have had cause to ring 111 and whether you have developed any symptoms. 

Where is the data stored?

Your data will be held within the CRM system which is owned by the Cabinet Office of the Isle of Man Government and which is hosted on servers located in the Isle of Man. 

Who can see the information?

Your personal data will be accessible to the CRT which includes the 111 service, the Travel Notification Service, the Ports Access Team and Contact Tracing.

Any isolation information that is held about you forms part of a view in the CRM called the isolation database for the period of time that you are required to be in isolation.  The Emergency Services Joint Control Room (the ESJCR) has access to this database on behalf of the emergency services and if you require the emergency services during your period of isolation, the ESJCR will share with the relevant service that you are in isolation in order that appropriate protective measures can be taken.

The IOM Constabulary can make requests to the CRT for information in the CRM.  Where such requests are made, these are subject to strict disclosure protocols and information will only be released where it is considered that there are appropriate legal grounds to do so.

Will your data be used for marketing purposes?

Your data will not be used for marketing purposes nor will your data be provided to any third party so that they can market their products or services to you.

How long is the data kept for?

The length of time we keep your data depends on the reason(s) that we hold your data in the CRM and some of these reasons require your data to be held for longer than others.  If you would like to find out more about the specific length of time your data will be held for, please contact the Cabinet Office Data Protection Officer using the contact information set out below.

Your rights

If you wish to see the data processed about you by the 111 team, please contact the Cabinet Office Data Protection Officer on;

Data Protection Officer
Cabinet Office
Government Offices
Bucks Road
Douglas
IM1 3PN

Email: DPO-CabOff@gov.im
Phone: +44 1624 686779

You have additional rights under the Isle of Man’s data protection legislation such as the right to rectification of incomplete data, the right to object and the right of erasure of data. 

If you wish to exercise those rights, or if you wish to make a complaint about how your data has been processed, please contact the Cabinet Office Data Protection Officer the details above.

You also have the right to request the Information Commissioner undertake an assessment as to whether the processing of your personal data has been carried out in accordance with the provisions of the Data Protection Act 2018. You can contact the Information Commissioner on +44 1624 693260 or by emailing ask@inforights.im.

18 May 2021