The Ministry of Border Control and Labour (“MBCL”) is the Data Controller for the temporary function of processing Personal Data in order to approve and manage travel to the Cayman Islands during the COVID-19 pandemic.

MBCL respects your privacy and is committed to making sure your data is safe. This privacy notice will explain how we use the Personal Data we collect from you when you use the Travel Cayman website (“Website”) at www.travelcayman.gov.ky.

The Website is designed to inform you about travel requirements to the Cayman Islands. Only in a few places on our Website do we ask you for your Personal Data in order to be able to offer you certain services, e.g. travel authorization certificate. You may also use the Website without disclosing or otherwise leaving any Personal Data to us, especially if you deactivate cookies and do not communicate with us via the Website.

Purpose of this Privacy notice

This privacy notice aims to give you information on how MBCL processes your Personal Data through your use of this Website, including any data you may provide through this Website when you use any of our sign-up forms.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. It is designed to also reflect the requirements of applicable privacy laws, including the EU General Data Protection Regulation and the Cayman Islands Data Protection Act (2021 Revision).

 

Who we are (Controller) And How You Can Contact Us

a) Who we are
Ministry of Border Control and Labour, Government Administration Building, Box 111, 133 Elgin Avenue, Grand Cayman, KY1-9000, Cayman Islands, is the controller and responsible for processing your Personal Data (collectively referred to as ”MBCL’’, “we”, “us” or “our” in this privacy notice) in the context of this Website.

MBCL is a government entity who performs tasks in the public interests of the Cayman Islands. As such, MBCL does not formally have to appoint a local EU representative.

b) Our Data Protection Compliance Manager
We have appointed a Data Protection Compliance Manager (DPCM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPCM using the details set out below or at tcdpcm@gov.ky.

What personal data we collect and why we collect it

a) Personal Data
Personal Data, or Personal Information, means any information about a living individual who can be identified directly or indirectly by means reasonably likely to be used by the data controller or by any other person. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer (together “process”) different kinds of Personal Data about you.

We collect Personal Data for the purpose of determining whether you are eligible to travel to the Cayman Islands under current public health requirements.

If you are approved to travel to the Cayman Islands on a specific date, we will also use your Personal Data to arrange for you to be tested for the COVID-19 virus (as required), to assign wearable gps technology (as required), to coordinate your transportation within the islands, and to approve where you plan to quarantine. Data categories include:

  • Identity Data includes first name, last name, maiden name (as required), passport number, passport issuing country, gender, vaccination status, immigration status, or similar identifiers.
  • Contact Data includes quarantine location (as required), email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Usage Data includes information about how you use our Website.
  • Other Personal Data that data subjects provide to us which is specified in the respective forms or similar unless data subjects provide it to us without specific occasion.

Details of individuals who will travel or quarantine with you will also be collected.

Where you are asked to provide Personal Data relating to individuals who will travel or quarantine with you, we ask that you ensure you are authorised to provide those details and that each individual is made aware of how their Personal Data will be processed.

b) Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for certain purposes. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

 

Our data processor

Our application website is hosted in Microsoft Azure. Your data will be stored securely in Microsoft Azure datacentres in the European Union. For Microsoft Azure legal information, please visit at https://azure.microsoft.com/en-us/support/legal/.

How we collect your personal data?

a) Direct interactions. By filling in forms on the Website or by corresponding with us by phone, email or otherwise, you may give us the Personal Data requested or that you decide to provide us with to access a service.

b) Automated technologies or interactions. As you visit the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. When wearing gps technology, we may also collect information. We collect this Personal Data, by using cookies and other similar technologies. See ‘’Cookies’’ below for more information.

c) Third parties. We may collect data from third parties we are partnered with (e.g. other government departments) to undertake joint protection activities to minimize the risk of COVID-19 exposure.

How We Process And Use Your Personal Data

We will only use your Personal Data when the law allows us to as described below. Most commonly, we will use your Personal Data in the following circumstances:

Purposes for which we process your Personal Data

We have set out below, in a table format, a description of all the ways we may process your Personal Data in connection with your visit of the Website, and which of the legal bases we rely on to do so. Please note that not all processing activities may be applicable to your Personal Data and that this depends on how you use the Website and interact with us. Wherever the legal basis is consent, we will ask you explicitly to consent on our Website or otherwise.

#

Purpose/Activity

Type of Personal Data
 

Legal basis for processing

1

To manage our relationship with you which will include:
(a) Processing travel applications

(b)Responding to inquiries

(c) Notifying you about changes to our terms or privacy notice

(d) Payment of government services or programmes

(i) Identity
 
(ii) Contact

(a) Necessary to comply with a request from you (travel to destination).
(b) Necessary to comply with legal obligations.
(c) Necessary for our legitimate interests (to keep our records updated)

2

To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(i) Identity
 
(ii) Technical
 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security.
(b) Necessary to comply with a legal obligation

3

To deliver relevant website content to you and measure or understand the effectiveness of the communication (including in emails) that we serve to you

(i) Identity

(ii) Usage
(iii) Technical

(a) Necessary for our legitimate interests (to ensure accurate information)

(b) Necessary to comply with a legal obligation

4

To use data analytics to improve our Website, services, customer relationships and experiences

(i) Technical

(ii) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our Website updated and relevant, to develop our organization and to inform our strategy)

 

Cookies

a) What are cookies and how do we use them?

“Cookies” are pieces of information that may be placed on your computer by us or a service we use for the purpose of facilitating and enhancing your communication and interaction with that service. There are other technologies with similar purposes, such as beacons or pixels, that we also call “cookies” in this notice. Beacons and pixels are content included on the Website and in emails to collect Technical Data about your equipment, Usage Data, and Marketing and Communications Data when you interact with the Website and emails.

b) Which types of cookies do we use?

We use the following types of cookies on the Website:

Essential Site Functions Cookies
  • These cookies are necessary to allow you to browse the Website and use Website functions. Without these cookies the Website would not function properly. The data processed by this type of cookies is more of a technical than a personal nature and concerns e.g. the type and settings of your device.
Analytical cookies
  • We use analytical cookies to see, for example, which content on the Website is highly frequented and also to analyse if content should be updated or improved. These cookies are also used to provide you with personalized content based on the pages you have shown interest in. These cookies process and save data like your browser type, referrer URLs, operating system, date / time stamp, views and clicks on the Website and your (truncated) IP address. We use these cookies only if you have consented via our cookie settings page.

 

How We Share Your Personal Data

We may disclose your Personal Data to third parties who are also involved in travel approval and management during the COVID-19 pandemic. This includes other Cayman Islands Government public authorities who are data controllers for specific processing activities as well as any other third parties as set out below:

  • Customs and Border Control, to confirm your immigration status in the Cayman Islands and your eligibility to travel to the Cayman Islands, as relevant
  • Travel Cayman, to consider your application, determine your quarantine status (as required) and, if you are approved for the Quarantine At Residence programme, to arrange for electronic monitoring of you and any other person who will quarantine with you
  • the Health Services Authority, to determine your quarantine period (as required) and organise testing for the COVID-19 virus
  • Cayman Airways, for the purpose of the provision of operational assistance
  • Royal Cayman Islands Police Service, for the purpose of managing breaches of Public Health regulations
  • MBCL agreed partners providing technical assistance
  • Service providers who provide IT and system administration services
  • Customer Relationship Management (CRM) platforms
  • Hosting platforms and
  • Data validation / storage platforms.

We require all Data Processors to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our Data Processors to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Data Processors may only process your Personal Data for their own purposes if you have consented to this, directly communiticated with them, or as otherwise allowed to do so under our agreements in accordance with applicable privacy laws.

We do not rent, sell, or share Personal Information about you that we collect on the Website with other people or unaffiliated companies for their direct marketing purposes.

If your Personal Data are disclosed to any other person in order to facilitate travel and quarantine logistics, we will endeavour to inform you before this happens and let you know exactly who will receive your data and why. We will also only disclose the minimum amount of data necessary for that purpose.

International Transfers
Whenever we transfer your Personal Data to another country or territory, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards such as the following are implemented:

  • We will only transfer your Personal Data to another country or territory that has been deemed to provide an adequate level of protection for Personal Data.
  • Where we use certain service providers, we may use specific contracts which give Personal Data the same protection it has under the EU GDPR (so called Standard Contractual Clauses).

 

Third-Party Links

This Website may include links to third-party websites, news articles, social media platforms and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to and disclosure of your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data as required for the respective purpose or on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How Long Will You Process My Personal Data For?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, audit or reporting requirements, or until you ask us to delete it.

 

What are your data protection rights?

a) Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

As a user of our Website, you have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate personal data, including data that are misleading, incomplete or out of date, we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please keep us also informed if your Personal Data changes during your relationship with us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove your personal data, under certain conditions. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with an order from the Ombudsman. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data, including in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

If you wish to exercise any of the rights set out above, please contact us at dpcm@caymanislands.ky.

EU Users:  For more information on your rights and accordant requirements, please see the information provided by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

You also have the right to complain to us or to the Ombudsman if you believe we are processing your Personal Data in a way that breaches the Cayman Islands Data Protection Law.

You can submit any requests, questions or complaints to us at tcdpcm@gov.ky. Information about the Cayman Islands Data Protection Law and how to contact the Ombudsman is available on www.ombudsman.ky/data-protection

b) No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

c) What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

d) Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Changes to our Privacy Notice

This version was last updated on 3 November 2021. We will inform you in advance if we make substantial changes to this privacy notice via the Website.

We have the right to update the contents of this Privacy Notice from time to time to reflect any changes in the way in which we process your Personal Data or to reflect legal requirements as these may change. In case of updates, we will post the revised Privacy Notice here on our website.

 

Quarantine At Residence Privacy Notice

If you will be in Quarantine At Residence read the privacy notice here.