Introduction
Crime Stoppers Bermuda (“CSB”) is committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that CSB collects from or about you, and how we use and to whom we disclose that information.
Application
CSB is a company incorporated in Bermuda. It has adopted this Privacy Policy in order to comply with the Bermuda Personal Information Protection Act 2016. This Privacy Policy applies to the personal information of all individuals who are directors, officers, members, patrons, donors or sponsors of CSB.
If you are unsure as to whether this Privacy Policy applies to you, please contact our Privacy Officer for clarification.
What is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e. information that cannot be associated with or tracked back to a specific individual).
What Personal Information Do We Collect?
CSB collects and maintains different types of personal information in respect of individuals who are directors, officers or members of CSB, including the personal information contained in:
– Application forms
– Applications for Police Criminal Record Checks
– Identification documents and details necessary to meet our compliance obligations, such as those related to anti-money laundering and ‘know your customer’ requirements, e.g. copies of passports and utility bills or bank statements
CSB also collects and maintains different types of personal information in respect of individuals who are patrons, donors or sponsors of CSB, including the personal information contained in:
– Emails and/or other forms of communication
– Bank transfers or cheques provided to CSB in respect of patronage or sponsorship How is this Personal Information Collected?
As a rule, CSB collects personal information directly from you.
Why Do We Collect Personal Information?
The personal information collected is used and disclosed for our business purposes. Such uses include:
– Determining eligibility for membership or for appointment or election to the board of directors, including the verification of references and employment and police records checks
– Legal and/or regulatory requirements
– Compliance with the requirements of our service providers, e.g. banks and insurers – Fundraising and marketing
How Do We Use Your Personal Information?
We may use your personal information:
– For the purposes described in this Privacy Policy; or
– For any additional purposes that we advise you of and, where your consent is required by law, we have obtained your consent in respect of the use or disclosure of your personal information.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When Do We Disclose Your Personal Information?
Your personal information may be disclosed:
– As permitted or required by applicable law or regulatory requirements. In such a case, we will endeavour not to disclose more personal information that is required under the circumstances;
– To comply with valid legal processes;
– For marketing purposes;
– Where the personal information is publicly available; or
– With your consent where such consent is required by law.
Notification and Consent
Privacy laws do not generally require CSB to obtain your consent for the collection, use or disclosure of your personal information for the purpose of establishing or managing your professional relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to CSB collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
How is Your Personal Information Protected?
CSB endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.
How Long is Your Personal Information Retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, CSB endeavours to retain your personal information only for as long as it believes is necessary to fulfil the purposes for which the personal information was collected, including for the purpose of meeting any legal or reporting requirements or obligations.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information changes during the course of your association with CSB, please keep us informed of such changes.
Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why.
Inquiries or Concerns?
If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer. We will endeavour to answer your questions and advise you of any steps taken to address any issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner.
Privacy Officer
We have appointed a Privacy Officer to oversee CSB’s compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:
Carlnika Roser
(441) 336-1828
Revisions to this Privacy Policy
CSB may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will communicate any revised version of this Privacy Policy.
Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change.
This Privacy Policy was last reviewed on 9 November 2021.
Interpretation of this Privacy Policy
Any interpretation associated with this Privacy Policy will be made by the Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’. This Privacy Policy does not create or confer upon any individual any rights, or impose upon CSB any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual’s personal information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
