Privacy Policy

We (The Health Improvement Commission) take our responsibilities as a data controller seriously and are committed to using the personal data that we hold in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017. Your privacy is important to us and this policy tells you about us, why and how we use your data and the rights you have over your data.

Who are we?

We are The Health Improvement Commission for Guernsey and Alderney LBG. Any enquiries about the use of your personal data should be addressed by post, email or telephone to the contact details below.

Address: Raymond Falla House, Burnt Lane, St Martins, GY1 6AF
Tel: 01481 233546
Data Privacy Manager: Dr Simon Sebire
Emailsimon.sebire@healthimprovement.gg

Data Protection Principles

We will comply with the Data Protection (Bailiwick of Guernsey) Law, 2017. This says that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is not meant for those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and kept up to date
  • Kept as long as necessary for the purposes we have told you about
  • Kept securely and processed in line with the rights of data subjects
  • Not transferred outside the Bailiwick, without adequate protection

When do we collect personal data?

  • When emails are sent to hello@healthimprovement.gg or to any of our staff’s email addresses
  • When you register as a volunteer for the Commission
  • When you interact with us through partners/suppliers working on the Commission’s behalf
  • As part of registering for one of our events, initiatives or programmes
  • As a result of enquiries made by telephone or in person
  • When you interact with our online content via third parties
  • When you sign up to a Commission newsletter
  • As part of our recruitment process (Data protection information relating to recruitment / employment is available on request).

What kind of information do we collect?

Personal data, or personal information, means any information relating to an identified or identifiable individual. Depending on the purpose for which we collect your data, we may hold ‘special category’ personal data which require a higher level of protection.  This includes racial or ethnic origin, political opinion, religious or philosophical belief, genetic data, health data, sexual orientation data or criminal data (this list is not exhaustive and only details the data the Commission may collect).

The types of information we may collect and process include:

  • Personal information (name, age, gender, date of birth, postal address, telephone number, email address)
  • Relevant medical / health information
  • Relevant criminal history (e.g. DBS/vetting check for staff or volunteers)
  • Website usage data, cookies and/or app information (See Cookie Policy)

Legal basis of processing

Personal data collected by the Commission is processed under Schedule 2 of the Data Protection (Bailiwick of Guernsey) Law, 2017, in the following circumstances:

  • The data subject has requested or given consent to the processing of the personal data for the purpose for which it is processed
  • The processing is necessary for the performance of a contract to which the data subject is party or that is in the interests of the data subject
  • The processing is necessary for a health or social care purpose
  • The processing is in the context of not-for-profit organisations that exist for political, philosophical, religious or trade-union purposes
  • The processing is necessary for historical or scientific purposes

Whilst the majority of the information you provide to us is given on a voluntary basis, it may be necessary to collect some information to comply with another law or the Commission’s safeguarding and recruitment policies, for example vetting checks for volunteers.  We will inform you of any legal or procedural requirements for information at the point of data collection.

Website Data Collection

The section below details how your data is processed when you interact with our website www.healthimprovement.gg.

Analytics

The services contained in this section enable the Owner (The Health Improvement Commission) to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics 

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location The Health Improvement Commission is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of The Health Improvement Commission, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies; Usage Data. 

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Privacy Shield participant.

Contacting the User

Contact form (The Health Improvement Commission)

By filling in the contact form with their Data, the User authorizes The Health Improvement Commission to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address; first name; last name; phone number. 

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of The Health Improvement Commission and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts 

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location The Health Improvement Commission is accessed from, that allows The Health Improvement Commission to incorporate content of this kind on its pages.

Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. 

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

MyFonts (Monotype Imaging Inc.)

MyFonts is a typeface visualization service provided by Monotype Imaging Inc. that allows The Health Improvement Commission to incorporate content of this kind on its pages.

Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. 

Place of processing: United States – Privacy Policy

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable The Health Improvement Commission to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of The Health Improvement Commission.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service. 

Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

DigitalOcean (DigitalOcean Inc.)

DigitalOcean is a hosting service provided by DigitalOcean Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service. 

Place of processing: United Kingdom – Privacy Policy. Privacy Shield participant.

Infrastructure monitoring

This type of service allows The Health Improvement Commission to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of The Health Improvement Commission.

Bugsnag (Bugsnag Inc.)

Bugsnag is a monitoring service provided by Bugsnag Inc.

Personal Data collected: app information. 

Place of processing: United States – Privacy Policy.. Privacy Shield participant

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of The Health Improvement Commission.

The interaction and information obtained through The Health Improvement Commission are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out from the respective services in order to make sure that the processed data on The Health Improvement Commission isn’t being connected back to the User’s profile.

AddThis (Oracle Corporation)

AddThis is a service provided by Oracle Corporation, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of The Health Improvement Commission.

Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.

Personal Data collected: Cookies; Usage Data. 

Place of processing: United States – Privacy Policy.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Campaign Monitor (Campaign Monitor Pty Ltd)

Campaign Monitor is an email address management and message sending service provided by Campaign Monitor Pty Ltd. We use Campaign Monitor for our newsletters. 

Personal Data collected: email address. 

Place of processing: Australia – Privacy Policy.

SPAM protection

This type of service analyses the traffic of The Health Improvement Commission, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA 

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on the location The Health Improvement Commission is accessed from.

The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data collected: Cookies; Usage Data. 

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

How we use your personal data.

Your data will only be processed for the purpose that it was given to us. This purpose will be explained to you at the point of data collection or within this Privacy Notice. We will take reasonable steps to ensure that personal data we hold about you is accurate. If it is necessary to change the purpose for which the data is processed, we will inform you before any new processing occurs, unless the new purpose is related to complying with another law.

Data Sharing

The Commission will keep your information confidential except where disclosure is required or permitted by law. The Commission does not intend to transfer any personal data to authorised jurisdictions outside of the EU, or to unauthorised jurisdictions unless we are required to do so by Law. The Commission does not sell or otherwise transfer personal data to commercial companies or other organisations except for web statistics which are hosted and managed by a third-party company. This process is detailed above and in the Cookie Policy on the Commission’s website at www.healthimprovement.gg/cookie-policy. This information helps us to understand how the website is used and enables us to maintain and improve it. This information is only processed in a way that does not identify anyone.

Data Retention

The Commission will ensure your data is securely retained for the duration of your involvement with the Commission in line with our Data Retention Policy and Photography and Filming Policy, unless we are legally or procedurally compelled to store the data for longer.

Your rights

The Law provides you with a number of specific rights which you can read about here.

If you have a concern about the way we are collecting or using your personal data you should raise your concern with us, free of charge, in the first instance (Who are we?), or directly with the Guernsey Data Protection Authority at www.odpa.gg.

Changes to this privacy policy

We reserve the right to update this privacy policy from time to time, and the up to date version will always be available via our website www.healthimprovement.gg.

Last updated: 4 March 2020