Last Updated: 04 June 2024

INTEGRITY COMMISSION

ELECTRONIC DELCARATION SYSTEM (“eDS”)

PRIVACY NOTICE

1. About the Electronic Declaration System (“eDS”)

The Electronic Declaration System (“eDS”) is an Internet-based application owned, operated and managed by the Integrity Commission (“we”, “us”, “our”, or the “Commission”) that facilitates the electronic input of information into the statutory declaration (the “declaration”) and the electronic submission of the relevant supporting documents accompanying the declaration, pursuant to Section 39(1) the Integrity Commission Act (the “Act”) and the Integrity Commission (Amendment of Third Schedule) Regulations, 2023, Resolution.

2. Scope of the Notice

This Privacy Notice (the “Notice”) explains how we processes information, particularly personal identifiable information collected and/or provided on eDS. This Notice also describes the types of personal identifiable information we process, the reasons for which we process this personal identifiable information, your data protection and privacy rights and how the law protects you.




This Notice is supplemental to the Integrity Commission’s General Data Protection and Privacy Policy (the “Policy”) and should be read in conjunction with the Statement. The Statement can be found on the Integrity Commission’s website.

3. Commitment to Your Privacy

The Commission always handles individuals’ personal identifiable information in a responsible and confidential manner that acknowledges your rights protected by law, particularly, the Act and the Data Protection Act, 2020 (the “DPA”).




We are committed to protecting all personal identifiable information, in our possession and we understand our obligations to all individuals whose personal identifiable information is processed by us and is in our possession.




We will maintain appropriate administrative, physical and technical safeguards to ensure the protection, security, integrity, and confidentiality of your information and personal identifiable information processed by us and in our possession. These safeguards also include measures designed to protect your personal identifiable information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. We will also strive to incorporate commercially acceptable and local, regional and global best practices and standards to protect your personal identifiable information.




The security of your personal identifiable information is important to us, however, no method for the electronic transmission and electronic storage of information is one hundred percent (100%) secure. As such, we cannot guarantee the absolute security of your information and personal identifiable information submitted and stored on eDS.

4. Consent to the Collection and Processing of Your Personal Identifiable Information

By using eDS, you agree to the collection, use and processing of your information and personal identifiable information in accordance with this Notice.

5. Children's Privacy

eDS is not available to and cannot be used by any individual under the age of eighteen (18) years of age. However, where relevant and necessary, we may collect information and personal identifiable information about your child or children under the age of eighteen (18) years of age.




If you are a parent or guardian and you are aware that your child has provided us with any personal identifiable information without your consent, please contact us. If we become aware that we have directly collected personal identifiable information from any individual under the age of eighteen (18) years of age without verification of parental consent, we will take steps to remove that information from our website and servers.

6. The Personal Identifiable Information Collected through or Provided on eDS

While using eDS, we may ask you to provide us with certain personal identifiable information which includes but is not limited to:

1. Your full name (first name, last name and middle name);
2. Your Account login credentials (username and password);
3. Your telephone number (home, work or mobile number);
4. Your e-mail address (work or personal e-mail address);
5. Your years of employment;
6. Your place of employment;
7. Your address (home or work address);
8. Your Taxpayer Registration Number (“TRN”);
9. Information about your Spouse (including full name, address, maiden name, TRN, years of employment);
10. Information about your Child and/or Children (including full name, address, and date of birth);
11. Your financial information (including information about your bank accounts, salary, real estate, motor vehicles, assets, expenses, liabilities, insurance policies, investments, stocks, bonds, and shares, gifts, etc.);
12. Your Spouse’s Financial Information (including information about his/her bank accounts, salary, real estate, motor vehicles, assets, expenses, liabilities, insurance policies, investments, stocks, bonds, and shares, gifts, etc.); and
13. Your Child and/or Children’s Financial Information (including information about his/her bank accounts, salary, real estate, motor vehicles, assets, expenses, liabilities, insurance policies, investments, stocks, bonds, and shares, gifts, etc.).

7. Types of Usage Data Collected and Processed Through eDS

Usage Data is collected automatically when visiting, accessing or using eDS on your computer or mobile device. The Commission uses Cookies to track the activity on eDS and store certain personal identifiable information, such as, your Internet Protocol (“IP”) address and internet browser information such as, the type of operating system and browser version as well as your usage activity on the eDS.




Presently, eDS only uses strictly necessary and essential Cookies. You will not be able to use or access eDS without using these strictly necessary and essential Cookies.




eDS uses the following Cookies:

Cookie Name	Type	Description
csrftoken	Strictly Necessary and Essential Cookies	A Cross-Site Request Forgery (“CSRF”) token protects web applications from unauthorized or malicious requests. This cookie verifies the authenticity of requests made by a user of an Internet-based application.
sessionid	Strictly Necessary and Essential Cookies	A Session Cookie last for a session. A session starts when you launch a website or web application and ends when you leave the website or close your browser window. Session cookies contain information that is stored in a temporary memory location which is deleted after the session ends. Unlike other cookies, a session cookie is not stored on your device.

8. The Commission’s Use of Your Personal Identifiable Information

Pursuant to the Act, your personal identifiable information will be collected and processed by employees and staff of the Commission.




The Commission may use your personal identifiable information for the following purposes:

1. To provide and maintain our eDS website, including to locate you and monitor your usage of eDS;

2. To manage your Account: to manage your registration as a user of eDS. The personal identifiable information you provide can give you access to different functionalities of eDS that are available to you as a registered user

3. To contact you: To contact you by electronic mail, telephone calls, text messages, physical mail, personal delivery or other equivalent forms of electronic or physical communication, such as, reminders about the deadline for filing a declaration, receipts acknowledging the submission of a declaration, notices regarding the filing of a declaration, a computer or mobile application's push notifications regarding updates or informative communications related to the functionalities of eDS, including the security updates, when necessary or reasonable for their implementation.

4. To manage your requests: To attend and manage your electronic requests to us made through eDS or electronic mail.

5. To perform our functions and responsibilities under the Act:

   1. Pursuant to Section 32(1) of the Act, the Director of Information and Complaints (“DoIC”) is required to:
      1. receive, keep on record and examine all declarations filed annually; and
      2. make such enquiries of third-party entities (including financial institutions, competent authority) considered necessary to certify or determine the accuracy of a declaration;
   2. Pursuant to Section 33(1) of the Act, the Director of Investigation (“DoI”) is required to:
      1. investigate any allegation that involves or may involve an act of corruption or an allegation relating to non-compliance with the provisions of the Act, on the basis of any complaint, information or notification referred to the DoI by the decision of the Commission or by the DoIC.
   3. Pursuant to Section 34(1) of the Act, the Director of Corruption Prosecution (“DoCP”) is required to:
      1. provide advice to the Commission on matters concerning non-compliance of the Act and offenses committed under the Act pertaining to the filing of a declaration; and
      2. institute, undertake and have the conduct of prosecutions in respect of offences committed under the Act relating to the filing of a declaration.

9. Transfer of Your Personal Identifiable Information to Third-Parties

Your information, including personal identifiable information, is processed at the following locations:

1. the Commission’s offices and any other external physical place (s) or location(s) fully operated, controlled and/or managed by the Commission; and
2. any other external place(s) or location(s) operated, controlled and/or managed by our third parties who process personal identifiable information on our behalf.




Our third-party service providers are located in and operate in international jurisdictions that have data protection and privacy laws that are equivalent to the data protection laws and regulations in Jamaica. We also ensure that your personal identifiable information is not transferred to our third-party service providers unless they have adequate technical and organizational controls in place to effectively secure your personal identifiable information.

We do not sell your personal identifiable information to third-parties. We also do not allow any personal identifiable information to be used by third parties for their own marketing purposes.

Your consent to this Notice and submission of any personal identifiable information to eDS represents your agreement to the transfer or sharing of your information and personal identifiable information with our third-party service providers. We will take all steps reasonably necessary to ensure that your personal identifiable information is secure and protected in accordance with this Notice and the DPA.

We may transfer and/or share your personal identifiable information in the following situations:

• With Our Third-Party Service Providers:

  We may share your personal identifiable information with our electronic mail and text messaging third-party service providers, being, Elastic Mail and Twilio respectively, to assist us with sending notifications, receipts and/or updates regarding eDS, the filing of declarations on the eDS and sending password authentication codes to you.

  The following information is shared with our third-party service providers:
  • Twilio – full name and telephone number; and
  • Elastic Mail – full name and email address.

10. Links to Third-Party Websites

This Notice, eDS and electronic mail and text message communications correlated to the use of the eDS may contain links to other websites that are not operated by us. If you click on a third-party website link, you will be directed to that third party's website.

The Commission strongly advises you to review the privacy policy, privacy statements or privacy notice of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

11. Disclosure of Your Personal Identifiable Information

Under certain circumstances, the Commission may be required to disclose your personal identifiable information if required to do so by law or in response to valid requests by law enforcement or public authorities (e.g. a court or a government agency).

We may disclose your personal identifiable information in good faith belief that such action is necessary to:

• Comply with a legal obligation;
• Prevent or investigate possible wrongdoing, non-compliance, or offenses committed in connection with eDS, a declaration, or the Commission;
• Protect the personal safety of you, other eDS Users or the general public; and
• Protect against legal liability.

12. Retention of Your Personal Identifiable Information by the Commission

The Commission will retain your personal identifiable information only for as long as necessary for the purposes set out in this Notice and in compliance with our legal obligations pursuant to the Act and DPA.

13. Deletion of Your Personal Identifiable Information

You may have the right to delete or request that the Commission assist in deleting certain personal identifiable information that we have collected about you. You may also have the ability to directly delete certain information about yourself, your spouse or your child/children from Eds.

You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your personal identifiable information.

You may also Contact Us to request access, to correct, update, amend, or delete any personal identifiable information that you have provided to us.

14. Your Data Protection and Privacy Rights

You have the following rights under the DPA in respect of any personal identifiable information we collect, use and process about you:

Your Rights	What They Mean
The right to access your personal identifiable information	You have the right to be informed whether, and to what extent, we process your data. Subject to certain exceptions, you have the right to obtain a confirmation as to whether we process your personal identifiable information, and if we do, request access to your data.
The right to consent to processing	You have the right to consent to the processing of your personal identifiable information. If your personal data is processed based on your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
The right to prevent processing	You have the right to object to the processing of your personal identifiable information in certain situations.
Rights in relation to automated decision making	You have the right to object to decisions based exclusively on the automated processing of your personal identifiable information.
The right to rectification	If the personal identifiable information that we process is incomplete or incorrect, you have the right to request their completion or correction at any time.

Please note that some of the rights listed above may be restricted because some of the rights described above can only be exercised in certain circumstances. If we are unable to fulfill a request from you to exercise one of your rights, we will write to you to explain the reason for refusal.

15. Changes to this Privacy Notice

We may update this Notice from time to time and you will be notified of any changes made to this Notice by the posting of a new and updated Privacy Notice on the eDS homepage. You will also be informed on any changes to this Notice via email and/or a prominent notice on our website, prior to the changes to the Notice becoming effective. Additionally, the "Last Updated" date at the top of this Notice will also be changed.

You are advised to review this Notice periodically for any changes. Changes to this Notice are effective as soon as they are posted on the eDS homepage.

Contact Us

1. If you have any questions and/or concerns about eDS, you can contact ICD:

   Email:	[email protected]
   Telephone:	(876) 968-6227 or (876) 960-0470
   Address:	Information and Complaints Division Integrity Commission 4th Floor, Sagicor SIGMA Building 63-67 Knutsford Boulevard Kingston 5, Saint Andrew Jamaica W.I.
   Visiting our Contact Us Page:	https://declarations.integrity.gov.jm/declarant/contact-us/

2. For any assistance in the exercise of your rights under the DPA or if you have any concerns For any assistance in the exercise of your rights under the DPA or if you have any concerns regarding this Notice, please contact our Data Protection Officer at:

   Email:	[email protected]
   Telephone:	(876) 968-6227, (876) 960-0470 or (876) 960-5617 | Ext. 6427
   Address:	Data Protection Officer Integrity Commission 3rd - 6th Floors, Sagicor SIGMA Building 63-67 Knutsford Boulevard Kingston 5, Saint Andrew Jamaica W.I.

3. If you are not satisfied with the way that we have handled your complaint, you have the right to raise the matter with the Office of the Information Commissioner using the contact details below:

   Email:	[email protected]
   Telephone:	(876) 920-4390
   Address:	Office of the Information Commissioner The Masonic Building (2nd Floor) 45-47 Barbados Avenue Kingston 5, Saint Andrew Jamaica W.I.

Definitions

For the purposes of this Notice, the following words and terms shall have the same meaning regardless of whether they appear in singular or in plural and are defined as follows:

Term	Definition
Account	a unique account created for you to access eDS.
Act	the Integrity Commission Act, 2017
Assets	an item of property owned by a person regarded as having value in or outside of Jamaica. (Examples: house, car, cash, equivalent, goodwill, art work, intellectual properties)
Child	this is: a natural person or individual under eighteen (“18”) years of age; or a natural person who is a son or daughter of any age.
Commission (also referred to as "we", "us" or "our" in this Notice)	refers to the Integrity Commission, 3rd to 6th Floors, Sagicor SIGMA Building, 63-67 Knutsford Blvd, Kingston 5, Saint Andrew, Jamaica, W.I. and is a body corporate established pursuant to the Integrity Commission Act, 2017.
Cookies	are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
Declaration	the statutory declaration required to be filed by all Parliamentarians and public officials which contains information about his/her assets, liabilities and income pursuant to Section 39 and 40 of the Integrity Commission Act, 2017.
DoCP	the Director of Corruption Prosecution
DoI	the Director of Investigations
DoIC	the Director of Information and Complaints
DPA	the Data Protection Act, 2020.
Data Protection Officer	the person appointed by the Integrity Commission who is responsible for monitoring, in an independent manner, the Integrity Commission’s compliance with the provisions of the Data Protection Act, 2020.
eDS	the Electronic Declaration System (“eDS”) is an Internet-based application owned, operated and managed by the Commission that facilitates the electronic input of information into the statutory declaration (the “declaration”) and the electronic submission of the relevant supporting documents accompanying the statutory declaration, pursuant to Section 39(1) the Integrity Commission Act (the “Act”) and the Integrity Commission (Amendment of Third Schedule) Regulations, 2023, Resolution. eDS is accessible at: https://declarations.integrity.gov.jm
Income	amounts received for work, or through investments in or outside of Jamaica, profits made on the sale of assets or monetary gifts etc.
Information Commissioner	the appointed Regulator in Jamaica for data protection and privacy pursuant to the Data Protection Act, 2020.
Liabilities	an amount owed to a supplier, bank, lender, or other provider of goods, services, or loans in or outside of Jamaica. (Examples: mortgage, credit cards etc.)
Personal Identifiable Information	information (however stored) relating to: a living individual; or an individual who has been deceased for less than thirty years, who can be identified from that information alone or from that information and other information in the possession of, or likely to come into the possession of, the data controller; and includes any expression of opinion about that individual and any indication of the intentions of the data controller or any other person in respect of that individual.
Parliamentarian	a member of the House of Representative or a member of the Senate.
Process	the obtaining, recording, or storing information or personal identifiable information, or carrying out any operation or set of operations (whether or not by automated means) on the information, including: organization, adaptation, or alteration of information; retrieving, consulting, or using information; disclosing information by transmitting, disseminating, or otherwise making it available; or aligning, combining, blocking, erasing, or destroying information, or rendering information anonymous.
Public Officials	any person who: holds an executive, an administrative or a judicial office, or a parliamentarian, whether appointed or elected, whether permanent or temporary, or whether paid or unpaid; is employed to a public body; and is any member of the Security Forces, that is: the Jamaica Constabulary Force, Jamaica Defence Force and the Rural Police. Public officials required to file a statutory declaration are: those in receipt of total emoluments of Twelve Million Dollars (J$ 12,000,000.00) and above per annum; those required by notice published in the Jamaica Gazette Vol. CXLVI No. 39 dated Wednesday December 20, 2023; or those requested in writing by the Commission.
Service Provider	any natural or legal person who processes personal identifiable information on behalf of the Commission. It refers to third-party companies or individuals contracted by the Commission to facilitate, provide, or perform a service related to eDS.
Spouse	includes: your husband or wife as duly married or partnered under Jamaican law; in relation to a single man, a single woman who, for a period of not less than five (5) years, has cohabited with the single man as if she were in law his wife; and in relation to a single woman, a single man who, for a period of not less than five (5) years, has cohabited with the single woman as if he were in law her husband spouse who is or was living separately and apart from you throughout the period in relation to which the declaration is made.
Usage Data	data collected automatically, either generated by the use of the eDS or from the eDS infrastructure itself (for example: the duration of a page visit).
Website	a group of World Wide Web pages usually containing links to each other and made available online by an individual, company, or organization.
You (also referred to as “you” or “your” in this Notice)	the individual and declarant accessing and using eDS.