The Cayman Islands Government Computer Services Department, CSD, respects your privacy and takes care in protecting your personal data. As a data controller, we comply with the Cayman Islands Data Protection Act (2021 Revision) (the “Cayman Islands DPA” or “the DPA”). This privacy notice (“Privacy Notice”) demonstrates our commitment to ensuring your personal data is handled responsibility and applies to the CSD.

The CSD collects personal data, including sensitive personal data, directly from you and may also collect your personal data indirectly from third party sources. Personal data collected by the CSD is limited to what is necessary for our processing activities. In this Privacy Notice, personal data includes any data relating to an identified or identifiable living individual.

Personal data we collect directly from you

The CSD collects the following information directly from you:

1. Personal data you provide through the CSD website(s), such as:
   1. Your Internet Protocol (“IP”) address, details of which device or version of web browser you used to access our website content, and other information about how you used our website (see our Cookie Notice for more information https://www.gov.ky/cookies);
2. Personal data you provide when you visit the CSD office, or contact us by email or telephone;
3. Personal data that you provide when you inquire about or apply for a job with the CSD;
4. Any information you choose to provide when interacting with the CSD on social media platforms, including:
   1. Facebook: https://www.facebook.com/caymangov/
   2. LinkedIn: https://www.linkedin.com/company/caymangov/
   3. Instagram: https://www.instagram.com/caymangov/
   4. X (formerly Twitter): https://twitter.com/caymangovt
   5. YouTube: https://www.youtube.com/c/CaymanIslandsGovernment

The purpose of the Civil Service is to make the lives of those we serve better. We are dedicated to supporting the elected government by delivering caring, modern and customer-centred public services and programmes, which deliver value for money. The CSD may use your personal data for the following purposes:

1. Implementing policies, providing services and programmes, and managing your relationship with us;
2. Responding to your inquiries;
3. Verifying your identity;
4. Statistical and other reporting, both internally and externally;
5. Seeking legal advice, and exercising or defending legal rights;
6. Complying with our legal obligations, including all legislation that applies across the public sector; and
7. Communicating and interacting with job applicants and related third parties (e.g. references) and carrying out recruitment and selection processes.

The CSD may share your personal data as required, including under applicable legislation, with recipients that include joint data controllers, our data processors, and third parties. We will only share your personal data as permitted by the Cayman Islands DPA.

Your personal data may be shared with the following recipients that support our public functions and operations:

1. With other public authorities: Personal data may be shared with other public authorities – here, “public authorities” means Ministries, Portfolios, Offices, Departments, Statutory Authorities, Statutory Bodies and Government Companies – for the purposes set out in this Privacy Notice.
2. With data processors external to the CIG: Personal data may be shared with persons providing services to CSD as a data processor in compliance with the Cayman Islands DPA. These service providers are only able to use personal data under our instructions and may include:
   1. Information Technology;
   2. Records and Information Management, including storage facilities;
   3. Communications; and
   4.  Security operations and fraud prevention.
3. With legal advisors and other persons if required by law or in relation to legal proceedings or rights: Personal data may be disclosed as legally required, for the purpose of or in connection with proceedings under the law, if necessary to obtain legal advice, or if the disclosure is otherwise necessary to establish, exercise or defend legal rights. This may include disclosing your personal data for the following purposes:
   1. Seeking legal advice;
   2. Exercising or defending legal rights;
   3. Complying with internal and external audits or investigations by competent authorities; and
   4. Complying with information security policies or requirements.

Depending on applicable laws and other circumstances, the CSD will rely on specific legal bases, or “conditions of processing”, under the DPA to process your personal data. These may include:

1. A legal obligation to which the CSD is subject, and to comply with various obligations under the Procurement Act, 2016 and Procurement Regulations (2022 Revision), the Public Management and Finance Act (2020 Revision) and Financial Regulations (2022 Revision), the Public Service Management Act (2018 Revision) and Personnel Regulations (2022 Revision), and the National Archive and Public Records Act (2015 Revision);
2. To exercise public functions, including the functions of the CSD in relation to the processing and contacting of data subjects about their job applications, and FOI, Data Protection or general enquiries; and
3. For the purposes of legitimate interests pursued by the CSD or by a third party or parties to whom the personal data may be disclosed, e.g., when disclosing records containing third party personal data in response to a request submitted under the Freedom of Information Act (2021 Revision).

Where we process your sensitive personal data, we will also meet a second legal basis. These may include:

1. To exercise our public functions; and
2. In relation to legal proceedings, including obtaining legal advice and otherwise establishing, exercising or defending legal rights.

Unless explicitly stated or implied otherwise, our website and our various public services and programmes are not intended for, or intentionally targeted at, children. The CSD does not knowingly collect or maintain personal data about children under the age of 16. We may collect personal data about young people between the age of 16 and 18 when they apply for or participate in internship opportunities with the CSD.

The CSD has put in place appropriate technical, physical and organisational measures in order to keep your personal data secure. These safeguards to maintain the confidentiality, integrity and availability of your personal data may include:

• Privileged Access Management Systems which provide workflow-based access control and session recording and auditing.
• 24-Hour Logging and Auditing of our systems (Email systems, Print Manager Servers, Network Access Control Systems).
• Availability is also supported by a backup/restoration system. are run according to an approved backup plan.
• Email security (sender identification, attachment content and SPAM protection).
• Internal network threat detection and blocking systems.
• Technical controls are in place to provide physical security to highly secured areas where data is stored (swipe ID's), and access times are automatically logged. Camera systems are also used.

The CSD will not transfer personal data to countries or territories that do not ensure an adequate level of protection for personal data.

We will only transfer your personal data to a country or territory that ensures an adequate level of protection for your rights and freedoms in relation to the processing of your personal data, unless there is a relevant exemption or exception under the Cayman Islands DPA. Exceptions may include your consent or appropriate safeguards.

The CSD may store your personal data for as long as we need it in order to fulfil the purpose(s) for which we collected your personal data, and in line with any applicable laws. This includes the National Archive and Public Records Act (2015 Revision), which governs the creation, maintenance and disposal of all public records. Sometimes, we may anonymise your personal data so that it is no longer associated with you.

Cookies, in combination with pixels, local storage objects, and similar devices (collectively, "Cookies" unless otherwise noted), are used to distinguish between visitors to a website.

When you visit https://www.gov.ky/csd/, small files known as Cookies may be stored on your computer, phone, tablet or any other device through your web browser. Information is stored in these text files.

Enabling Cookies may allow for a more tailored browsing experience and is required for certain website functionality. In the majority of cases, a Cookie does not provide us with any of your personal data.

Please see the website’s Cookie Notice for more information about the use of Cookies (https://www.gov.ky/cookies).

The CSD will respect and honour your rights in relation to your personal data and implement measures that allow you to exercise your rights under the DPA and other applicable legislation.

In accordance with the DPA, your rights in relation to your own personal data include:

1. The right to be informed and the right of access: The right to request access to all personal data the CSD maintains about you as well as supplementary information about why and how we are processing your personal data. This is commonly known as a Subject Access Request and certain supplementary information about our processing is contained within this Privacy Notice.
2. Rights in relation to inaccurate data: The right to request the rectification, blocking, erasure or destruction of any inaccurate personal data the CSD maintains on you. We will ensure, through all reasonable measures, that your personal data is accurate, complete and, where necessary, up‑to‑date, especially if it is to be used in a decision-making process.
3. The right to stop or restrict Processing: The right to restrict or stop how the CSD uses your personal data in certain circumstances.
4. The right to stop direct marketing: The right to cease the use of your personal data by the CSD for direct marketing purposes. The CSD does not currently use direct marketing. However, we will update this Privacy Notice and we will also notify you in writing as required if this position changes.
5. Rights in relation to automated decision making: The right to obtain information about and object to the use of automated decision making by the CSD using your personal data. The CSD does not currently use automated means to make decisions about you. However, we will update this Privacy Notice and we will also notify you in writing as required if this position changes.
6. The right to complain: The right to complain to the Ombudsman about any perceived violation of the DPA by the CSD.
7. The right to seek compensation: The right to seek compensation in the Court if you suffer damage due to a contravention of the DPA by the CSD.

You may contact the CSD, using the contact details listed below, to access and review your personal data or to exercise any other rights provided to you under the DPA. The CSD will take into consideration circumstances where, under the DPA or other applicable legislation, your rights may be limited or subject to conditions, exemptions or exceptions.
Upon contacting the CSD, we may need to verify your identity prior to fulfilling a request and may request additional information as required. In accordance with the DPA, the CSD may also charge a reasonable fee in relation to your request if it is unfounded or excessive in nature, or the CSD may reserve the right not to comply with the request at all.
To learn more about your rights, visit www.ombudsman.ky.

When processing your personal data, the CSD will comply with the eight Data Protection Principles defined within the Cayman Islands DPA:

1. Fair and lawful processing: Personal data shall be processed fairly. In addition, personal data may be processed only if certain conditions are met, for example the data controller is subject to a legal obligation that requires the processing or the processing is necessary for exercise of public functions.
2. Purpose limitation: Personal data shall be obtained only for one or more specified, explicit and legitimate purposes, and not processed further in any manner incompatible with those purposes.
3. Data minimisation: Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are collected or processed.
4. Data accuracy: Personal data shall be accurate and, where necessary, kept up-to-date.
5. Storage limitation: Personal data processed for any purpose shall not be kept for longer than is necessary for that purpose.
6. Respect for the individual’s rights: Personal data shall be processed in accordance with the rights of data subjects under the DPA, including subject access.
7. Security – confidentiality, integrity and availability: Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
8. International transfers: Personal data shall not be transferred to a country or territory unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Our website contains links to other websites. These websites are not within our control and may not follow the same privacy, security, or accessibility policies. Once you link to another site, you are subject to the policies of that site.

The CSD has appointed a Data Protection Leader. If you have any questions about this Privacy Notice or how your personal data is handled, or if you wish to make a complaint, please contact:

The CSD aims to resolve inquiries and complaints in a respectful and timely manner.

If you would like to make a Subject Access Request, the Data Protection Leader for the CSD also handles these requests. Requests relating to your own personal data may be made in writing to the contact details listed above. Depending on the scope of your request, to ensure you receive all records and information you are entitled to by law, your request may be processed under the DPA, under the Freedom of Information Act (2021 Revision), or under both enactments.

The CSD reserves the right to update this Privacy Notice at any time and will publish a new Privacy Notice when we make any substantial updates. From time to time, the CSD may also notify you about the processing of your personal data in other ways, including by email or through our publications.

Any amendments or revisions to this notice by the Data Protection Leader shall be documented in the "Notice Review" section below.

Notice Review: