Privacy Notice

Visit Isle of Man Privacy Notice

Visit Isle of Man is an Executive Agency of the Isle of Man Government Department for Enterprise. The purpose of Visit Isle of Man is to realise the fullest economic growth potential of the Island as a visitor destination. This privacy notice tells you what to expect when Visit Isle of Man collects personal information.

Your rights as a data subject

Under the Data Protection Act, you have rights as an individual which you can exercise in relation to the information we hold about you. At any point while we are in possession of or processing your personal information, you, the data subject, have the following rights:

Access - You have the right to request a copy of the information that we hold about you

Rectification - You have the right to correct data that we hold about you that is inaccurate or incomplete

Erasure - In certain circumstances you can ask for the data we hold about you to be erased from our records

Restriction of processing - Where certain conditions apply, you have the right to restrict the processing of your data

Portability - You have the right to have the data we hold about you transferred to another organisation

Objection - You have the right to object to certain types of processing such as direct marketing

Objection to automated processing - You also have the right to be subject to the legal effects of automated processing including profiling

Judicial review - In the event that the Department for Enterprise refuses your request under rights of access, we will provide you with a reason as to why. You then have the right to complain as outlined in Complaints.

You can find out more about these rights here - or by contacting our Data Protection Officer using the details at the end of this notice.

How we use your information

This privacy notice tells you what to expect when Visit Isle of Man collects personal information. It applies to information we collect when people:

• visit our websites

• contact us by email, in person or over the phone

• send us a private message on social media

• sign up to marketing (our newsletter) or request print materials

• register to use our Visit Isle of Man Trade website

• enter our competitions or promotions or complete any of our surveys

• consent to the use of cookies or passive technologies on your browser

Visiting our websites

Visit Isle of Man has two websites, one for consumers and one for trade. If we do want to collect personally identifiable information through our websites, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

The only people who have access to personal information are those who have a legitimate need to; this includes Visit Isle of Man staff and any Department staff or contractors involved in Marketing and Business Intelligence. In addition, New Mind, the developers of the Visit Isle of Man websites, also have administrative access in order to support the website and the DMS system therein.

Isle of Man Government Website

The Isle of Man Government website is owned by the Cabinet Office. Their Privacy Notice in relation to how you use gov.im can be found at the top of each page next to the Terms and Conditions.

Contact us by email, in person or over the phone

We will only ask for your name and postal or email contact details. You may choose to provide extra information if you are making an enquiry.

Email mailboxes are accessed by the team responsible for that service/product; this includes Visit Isle of Man staff and any Department staff involved in Marketing and Business Intelligence. Such emails will only be shared with your consent, and only in order to address your enquiry or request.

We securely store personal information electronically and manually:

• Ongoing email communications are stored on our Isle of Man Government email system, Microsoft Outlook

• We have three main records management tools all specifically designed for the type and use of the information recorded: Microsoft Dynamics, CRM, DMS and the Isle of Man Government secure network. We may store your emails on one of these systems depending on the nature of your enquiry or request.

• In normal circumstances we will only keep a record of this communication in Outlook until the request or enquiry has been fulfilled; after this time they will be kept for six months in one of our records management systems.

Sending us a private message on social media

You may also choose to provide us with personal information on our social media platforms; we ask that you do also check the platform's privacy policy and terms of service prior to sending us anything.

Social media message boxes are accessed by the team responsible for that service/product; this included Visit Isle of Man staff and any Department staff involved in Marketing and Business Intelligence. Such messages will only be shared with your knowing, and only in order to address your enquiry or request. The Marketing and Business Intelligence Division may at certain times require a third party to manage the Visit Isle of Man social media; if this happens this policy will be revised.

Social media messages will only be kept for a month after the conclusion of the enquiry.

Signing up to marketing (our newsletter or requesting print materials)

We use Mailchimp as our marketing platform. By clicking subscribe, you acknowledge that your information will be transferred to Mailchimp for processing. Learn more about Mailchimp's privacy practices.

Visit Isle of Man is legally required to ask for your explicit consent when we have no statutory reason to use or hold your information (known as 'processing'). We must provide you with all relevant information about how we will use your information so you can make an informed decision about whether to allow us to have your information by choosing to 'opt-in.'

You will definitely know if you are opting-in to us using your information; the request to use your information (opt-in options) are very clearly marked, as are the purposes for us wanting to use your information. There is no way for you to accidentally provide us with information, or to accidentally consent to you using.

At the bottom of all of Visit Isle of Man marketing emails it says: "unsubscribe from this list". This then takes you to a new internet browser window that reads: "By clicking Unsubscribe, you’ll no longer receive marketing emails from the list, Visit Isle of Man - Consumer". This will automatically remove you from the mailing list for that newsletter, preventing us from processing your personal information any further.

When requesting print materials (e.g. the Visit Isle of Man "One Stop Guide"), you will be asked to provide your name and address. This information will be held on a separate list for the purpose of posting materials, accessible only by those who post the materials, and only kept for a month after the materials have been posted (just in case we need to resend anything, or if you have a question).

Register to use our Visit Isle of Man Trade website

While the trade website provides a portal for our trade partners and providers to manage their business through our page (up to date business information, add promotions or activities, etc.), we acknowledge that some smaller business may use their personal contact details to manager their business. For this reason, we have decided to include processing for this purpose in our Privacy Notice in order to provide you with reassurance that we take your privacy seriously and will treat your data in the same way as all other personal data we hold.

Entering our competitions or promotions or completing any of our surveys

You have the choice as to whether you would like to enter any competitions or submit any information within a survey, however, if you do you will only be asked for your name, so we can identify you, your contact information, so we can contact you, and any other relevant information that you agree to provide. The information you provide will be treated in the same way as personal information submitted in any other way.

Consenting to the use of Cookies and passive technologies on your browser

What is a Cookie?

Cookies and passive technologies are pieces of information that a website transfers to your computer. Cookies can make the web more useful by storing information about your preferences on particular sites, enabling us to provide more useful features for you. They contain no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. The cookies used are listed below.

Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or inform you when they are set. However, given that we may sometimes use cookies to ensure and enhance the performance of our websites, you may not be able to take full advantage of our website if you do disable them.

Passive technologies

On both our websites we also use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our websites.

Our websites use search engines are powered by New Mind. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either us or any third party.

Consenting to cookie and passive technology use

The first time you visit each of our websites, you will be provided with an option to approve (or "opt-in") to the use of all cookies on the website with a pop up in the bottom right-hand corner. Visit Isle of Man has no way of knowing whether you allow cookies or not, and no way to trace your selection back to you. Instead, your own internet browser remembers the selection so it will treat that cookie the same each time (until you change your cookie settings).

Withdrawing consent to cookie and passive technology use

You can usually manage and disable all cookies and passive technologies directly through your internet browser; you may therefore find it helpful to check the guidance provided by your internet browser provider. The most common providers and links to their guidance on cookies and passive technologies have been provided below:

Google Chrome

Microsoft Internet Explorer

Microsoft Edge

Mozilla Firefox

Apple Safari

Opera

What cookies do Visit Isle of Man and Visit Isle of Man Trade use?

Cookie:          ASPSESSIONID*

                       ASP.NET_*

Issued by this website.

Purpose: Identification. These cookies identify a user, making it easier for them to use the dynamic features of the site without having to provide the same information again as they move from one page to another.

Expiration: Until the website browser is closed.

Cookie:          Google Analytics

                       __utma

Purpose: Performance: to measure and improve site quality through analysis of visitor behaviour.

Expiration: 2 years from when set or updated. Can be removed by user in browser settings.

Cookie:          Google Analytics

                        __utmb __utmc

Purpose: Performance: these cookies are used to record how long a visitor remains on the site. Used to measure and improve site quality through analysis of visitor behaviour.

Expiration: until the website browser is closed.

Cookie:          Google Analytics

                       __utmz

Issued by this website.

Purpose: Performance: this cookie is used to record where a visitor came from - e.g. search engine traffic, ad campaigns and page navigation. Used to measure and improve site quality through analysis of visitor behaviour.

Expiration: 6 months from when set or updated. Can be removed by user.

Cookie:          ASPSESSIONID

Shared by js.nmspace.net

Purpose: These cookies identify a user, making it easier for them to use the dynamic features of the site without having to provide the same information again as they move from one page to another.

Expiration: Until the website browser is closed.

We will only process your personal information if a lawful bias exists:

Consent - if we rely on your consent to process your information, we will make it obvious what we are asking for consent to do and always tell you how you can withdraw your consent e.g. registering for services, newsletters and competitions.

Legal obligation - if we process information to meet a legal obligation in carrying out statutory government functions; e.g. registering as an accommodation provider under the Tourist Act (1975)

Public task - if it is the public interest for us to collect or store e.g. when handling enquiries from members of the public

How will we securely process personal data?

All personal information is kept with the highest standards and safeguards in place. This includes technical security, preventing unauthorised access, undertaking audits and maintaining backups:

• Emails - Email communications are stored on our Isle of Man Government email system, Microsoft Outlook. We encrypt and protect all our emails in line with government standards. If your email service does not support this encryption, you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law

• Microsoft Dynamics CRM - Only certain members of staff will have access to your personal information on CRM and there is security in place to ensure this. Some of the Visit Isle of Man marketing lists are held on CRM. The administration of CRM is undertaken by Government Technology Services in the Cabinet Office; however, they are unable to access the content of any records and so will not be able to access your personal information.

• DMS and the Visit Isle of Man websites - The websites are managed for us by a third party provider, New Mind. We would not ever ask or allow New Mind to have access to any of this information about you and their access is based solely on providing administrative support to the websites and the records management tools. Some of the Visit Isle of Man marketing lists are held on CRM.

• Isle of Man Government Secure Network – There are strict access controls in place meaning that only Visit Isle of Man have access to their folders on the network; in addition, only the teams within Visit Isle of Man who are able to access personal information, are those that have a business need to do so. The administration of the IOMG Secure Network is undertaken by Government Technology Services in the Cabinet Office; however, they are unable to access the content of any records and so will not be able to access your personal information

• Manual records - We do not routinely store manual records, however, if we are required to hold any manual records they are either stored onsite or in a third party storage facility with whom we have a data protection agreements in place.

Miscellaneous

Under what circumstances can Visit Isle of Man contact me?

Our aim is never to be intrusive, and we aim to always avoid asking irrelevant or unnecessary questions. Moreover, any information you provide us will always be subject to rigorous measures and procedures to maintain your privacy. You will never be contacted by a means you did not consent to when providing us with your data.

Retention period

We only use personal information for as long as it is needed and will store it for the shortest amount of time possible, in accordance with the law. To view our Retention of Records Procedure please contact DPO-DfE@gov.im to request this.

Complaints

In the event that you wish to make a complaint about how your personal information is being processed by the Visit Isle of Man (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the Department’s Data Protection Officer in the first instance; as well as the Isle of Man Information Commissioner.

Processing special category (sensitive) data and the data of children (under 16s)

We have to put additional measures in place if we plan to process any special category personal data[1], including ethnic origin or religion; however, Visit Isle of Man does not process any special category personal information. In order to process the personal information of children, we would have to put additional measures in place because they may be less aware of the risks involved [2]. Visit Isle of Man does not target any services to children and does not process the personal information of children for marketing purposes, competitions or registering for services or user profiles.

Contact

For any privacy enquiries, please feel free to contact our Data Protection Officer, or the Isle of Man Information Commissioner:

Department for Enterprise Data Protection Officer
St George’s Court, Upper Church Street, Douglas, Isle of Man
Tel: +44 (0) 1624 682381
Email: DPO-DfE@gov.im

Isle of Man Information Commissioner
P.O. Box 69, Douglas, Isle of Man, IM99 1EQ
Tel: +44 (0) 1624 693260
Email: ask@inforights.im
Web: www.inforights.im

Notice Issued under DfE Data Protection Policy on 28-Oct-2021. For annual review

[1] for more information visit the UK ICO website ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data 

[2] for more information visit the UK ICO website ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/applications/children/