Public Record Office Privacy Notice
The Public Record Office (PRO) is part of the Isle of Man Government Department for Enterprise. The Public Record Office is the Isle of Man's National Archive – we preserve records of the Isle of Man government and other Manx public bodies that are of historical and cultural significance.
How we use your information
This privacy notice tells you what to expect when the PRO collects personal information. It applies to information we collect when people:
- visit our website
- contact us by email, in person, by post or over the phone
- visit us and register to use our reading room services
- request access to closed records for research purposes
- request copies of copyright material and complete a copyright declaration form
- book a Public Record Office event
This privacy notice also applies:
Visit our website
If we do want to collect personally identifiable information through our website, www.gov.im/pro, 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; it will be kept securely, and the only people who have access to personal information are those who have a legitimate need to.
Contact us by email, in person, by post or over the phone
If you contact us to make an enquiry about our services or the records in our care, you will need to provide us with your name, contact details and any other information necessary to enable us to help you. You may need to supply us with sensitive personal data if necessary to answer your enquiry (for example, if your enquiry is related to your personal healthcare record, family history etc., guardianship or adoption, etc.); such data will be treated with the utmost confidentiality and respect.
We process this information to answer your enquiry or administer your reading room visit. We also use this information to answer any future related enquiries you make and further visits you make to the Record Office. We may share your information with other public bodies where this is necessary to deal with your enquiry or reading room visit (for example, allowing you to access closed records at your request).
Only the PRO team members and senior management can access the information; it will be held securely, for a minimum of 6 years and a maximum of 25 years, according to the retention periods defined by our retention schedule.
Visit us and register to use our reading room services
Under the Public Records Act 1999 section 1(3) we have a legal obligation to take all practical steps for the preservation of public records in the Record Office.
If you visit us and register to use our reading room services, we will ask you to complete a form. You will need to provide your name, contact details, the subject of your research and your signature.
During the registration process, we will ask to view, but not copy, a form of personal identification such as a driving licence, passport or other documentation. In addition, we will also collect your name and signature when you complete a document request slip.
We process this information to ensure the security and preservation of the public records in our care.
Only the PRO team members and senior managers will have access to this information, and only when they are required to do so; however, we may have to share this information when required to do so by law. We will keep the information you provide on this form securely for 25 years after the year of registration/request.
Request access to closed records for research purposes
Some records in the Isle of Man Public Record Office contain personal data or other sensitive information to which access is restricted by law. These records are covered by a closure period under the Public Records Act 1999 or Public Records Order 2015.
If you wish to access closed records for research purposes, we will ask you to complete an application form. You will need to provide your name, contact details (e-mail, postal address and telephone number), signature and the nature of your research.
Only the PRO team members and senior managers will have access to this information, and only when they are required to do so; however, the personal data you provide on this form may be shared with other public bodies where necessary to deal with your enquiry. Access to closed records and information is granted by the record creating body and so we need to share your data with them to enable them to deal with your request.
We will keep the information you provide on this form securely for 25 years after the year of registration/request.
If the closed records you wish to access contain personal data, we will ask you to complete a further form.
This form is used to request access to personal data for the purposes of scientific, historical or statistical research purposes under Article 89 of the EU General Data Protection Regulations (Regulation (EU) 2016/679) and with regard to section 18 (2) of the GDPR and LED Implementing Regulations 2018. You will need to provide your name, contact details (e-mail, postal address and telephone number) and signature on this form.
Only the PRO team members and senior managers will have access to this information, and only when they are required to do so; however, if it is necessary to deal with your enquiry or to allow you to access closed records at your request, your information may be shared with other public bodies where they are responsible for granting access to the records. Data access request forms will be held securely and will be retained by the PRO for the date of provision of access + 6 years.
Request copies of copyright material and complete a copyright declaration form – published and unpublished material including photographs
If you ask us for copies of copyright material, we will ask you to complete a copyright declaration form. You will need to provide your name, address, contact number and e-mail and signature. We have a legal obligation to collect your data in this way to comply with the Copyright Act 1991.
Only PRO team members and senior managers will have access to this information, and only when they are required to do so; however, we may have to share this information when required to do so by law. We will keep the information you provide on this form securely for 6 years after the date of your copying request.
Book a Public Record Office event
If you contact us to book an event, we will collect your name, contact details (telephone, e-mail or postal address as provided by you) and any disability information you provide us with, where required to assist you during your visit.
We will process this data to enable us to arrange your booking and visit to the Record Office or other outreach venue.
Only PRO team members and senior managers will have access to this information, and only when they are required to do so; we will keep the information you provide securely for 2 years after the year of the event.
If you are the subject of any records transferred to the Public Record Office by another public body for permanent preservation
All Isle of Man public bodies have a legal obligation to transfer records to the Public Record Office if the records are selected for permanent preservation under the Public Records Act 1999. Records are selected for preservation at the Public Record Office if they have long-term research value, historical or cultural significance.
If your personal data is included in records selected for transfer to the Record Office, it will be retained securely and permanently. Records transferred to the Public Record Office may include special category (sensitive) personal data and data about children.
Access to and use of records at the Isle of Man Public Record Office is governed by legislation, in particular the Public Records Act 1999, the Public Records Order 2015 and the Freedom of Information Act 2015.
Where your personal data is included in records transferred to the Record Office, an assessment will be made of whether the records should be ‘closed’ (unavailable to the public for a certain time) based on this legislation.
Closure periods will be applied to records as appropriate under this legislation to prevent unlawful access to your personal data.
Your personal data, including data in closed records, may be shared with researchers for historical, statistical or scientific research purposes where this is lawful under section 4 of the Public Records Act 1999 and under Article 89 of the EU General Data Protection Regulations (Regulation (EU) 2016/679) and with regard to section 18 (2) of the GDPR and LED Implementing Regulations 2018.
Your personal data will not be used by the Isle of Man Public Record Office for any automated decision making.
Why will we process personal data (aka “the legal basis”)
We will only process your personal information if a lawful basis 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.|
|Public task||if it is the public interest for us to collect or store e.g. when handling enquiries from members of the public|
|Legal obligation||If we have an obligation under legislation to collect or store your information; e.g. when records are transferred to us under the Public Records Act 1999 for permanent preservation|
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 for the duration of your enquiry/request. Email mailboxes are accessed by the team responsible for that service/product; and will always be PRO staff. Such emails will only be shared with your knowing, and only in order to address your enquiry or request.
- 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.
- Isle of Man Government Secure Network – There are strict access controls in place meaning that only the PRO team and senior managers have access to their folders on the network; in addition, only the teams within the PRO 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 – If we need to hold your personal information manually, we will hold it on site in our own secure, restricted access storage areas.
Your rights as a data subject and access to personal information
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 a right to request the correction of 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 a right to restrict the processing of your data|
|Portability||You have the right to request that the data we hold about you is 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 by contacting our Data Protection Officer using the details at the end of this notice.
The Public Record Office carries out ‘archiving in the public interest’ by preserving records and information of historical and cultural significance. It may not be possible to erase or correct your personal information, or transfer it to another organisation, if your information falls within records that have been selected for permanent preservation as part of the Isle of Man’s National Archive.
In the event that you wish to make a complaint about how your personal information is being processed by the PRO (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with our Data Protection Officer in the first instance; as well as the Isle of Man Information Commissioner.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of the Public Record Office’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Under what circumstances can the PRO 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.
Updates to this Privacy Notice
From time to time we may need to update this Privacy Notice; if we do make any changes we will make this clear on our website and let you know, depending on how you have said we can contact you
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.
Processing special category (sensitive) data and the data of children (under 16s)
We also process special category (sensitive data) and data related to children where this data is included in records transferred to the Public Record Office for permanent preservation under the Public Records Act 1999.
We do not target any services to children or process the personal information of children for marketing purposes, competitions or registering for services or user profiles.
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,
Isle of Man,
Tel: +44 1624 686733
Isle of Man Information Commissioner
Isle of Man Information Commissioner,
P.O. Box 69,
Isle of Man,
Notice Issued under DfE Data Protection Policy on 27 July 2018; subject to annual review