Privacy Notice

Version 1.0

1. Scope

The Cayman Islands Government Health Insurance Commission, (“HIC”), respects your privacy and takes care in protecting your personal data. As a data controller, we comply with the Cayman Islands Data Protection Act (2021 Revision) (the “DPA”). This privacy notice (“Privacy Notice”) demonstrates our commitment to ensuring your personal data is handled responsibly and applies to the Health Insurance Commission.

This Privacy Notice does not apply to Health Insurance Commission when we are processing personal data relating to our employees, who are covered under our Employee Privacy Notice. This Privacy Notice also does not apply to the Health Practice Commission or any of the Health Practice Councils. HPC Privacy Notice. 

2. What Personal Data We Collect

The HIC collects personal data, including sensitive personal data, directly from you and may also collect your personal data indirectly from third party sources. Personal data collected by the HIC is limited to what is necessary for our processing activities. In this Privacy Notice, personal data includes any data relating to an identified or identifiable living individual and includes: insurance coverage information, medical data, employment data, marital status, dependant information, pay stubs, other information provided as part of a query or complaint, and other information obtained during a compliance check or investigation.

Personal data we collect directly from you

The HIC may collect the following information directly from you:

  1. Personal data you provide through the HIC website, such as:
    1. Personal data provided within comments and questions, including your name and/or email address if you provide these details in our web form. If you ask questions about our public services and programmes or provide information about your relationship with us, this may also reveal other personal data, e.g. your place of employment, employment status, health information, or immigration status;
    2. Your email address and subscription preferences if you sign up for our newsletters or notifications, and how you utilise our emails, including whether you open them and which links you click; and
    3. Your Internet Protocol (“IP”) address, details of which device or version of web browser you used to access our website content, and other information about how you used our website;
  2. Personal data you provide when you visit the HIC offices and other locations; contact us by email or telephone; or access our programmes and services, including our online services;
  3. Personal data that you provide when you inquire about a job with the HIC; if you apply for a job with the HIC via the CIG e-recruitment platform, an additional privacy notice is available here: https://careers.gov.ky/application/custom/English/privacy-statement.html;
  4. Any other personal data where the collection is necessary to achieve our lawful purpose(s).

Personal data collected from other sources

The HIC may collect the following personal data from other sources:

  1. Personal data collected from insurance companies e.g. notice of termination of insurance policy, insurance policy details, employment information, dependant information, marital status, medical records, proof of payment, high-risk insurance applications, other information related to a claim or investigation;
  2. Personal data collected from hospitals or other medical facilities e.g. information related to an unpaid medical bills;
  3. Personal data collected from an individual’s employer or former employer related to health insurance coverage, e.g. start date, termination date, information regarding the employer’s liability, marital status, dependant information, medical information, claim information, pay stubs, proof of residency; 
  4. Personal data collected from Workforce Opportunities & Residency Cayman (“WORC”) during an investigation, e.g. to determine if you are a resident of the Cayman Islands, determine which employer is responsible for providing health coverage to you;
  5. Personal data collected via CCTV at the HIC premises, if lawfully disclosed to the HIC by the CIG Facilities Management Department as the initial Data Controller that collected the footage at the premises; and
  6. Personal Data may be collected indirectly from Workforce Opportunities & Residency Cayman (“WORC”), Customs & Border Control (“CBC”), Department of Commerce & Investment (“DCI”), Health Practice Commission (“HPC”) & other Government entities, third parties that verify personal data provided by the Data Subject.
  7. Any other personal data where the collection is necessary to achieve our lawful purpose(s).

3. How We Use Your Personal Data

The purpose of the Civil Service is to make the lives of those we serve better. We are dedicated to supporting the elected government by delivering caring, modern and customer-centred public services and programmes, which deliver value for money. The HIC may use your personal data for the following purposes:

  1. Implementing policies, providing services and programmes, and managing your relationship with us;
  2. Responding to your inquiries;
  3. Investigating and responding to complaints you have made to us, including complaints against your employer or insurance company which are related to your insurance coverage;
  4. Monitoring compliance with the Health Insurance Act (2021 Revision), e.g. collecting termination of coverage information directly from your insurance company, contacting your employer or previous employer to request proof of insurance;
  5. Verifying your identity;
  6. Measuring how users interact with the HIC’s website and continually improving our communications channels (including by aggregating personal data collected using cookies);
  7. Communicating and interacting with website visitors;
  8. Communications and public relations activities;
  9. Managing accounts payable and receivable, preventing fraud, and protecting public funds;
  10. Statistical and other reporting, both internally and externally;
  11. Seeking legal advice, and exercising or defending legal rights; and
  12. Complying with our legal obligations, including all legislation that applies across the public sector, e.g. legislation that provides for records and information management, procurement, human resource management, financial management, audit, and similar functions and activities.
  13. Complying with our legal obligations including conducting inspections
  14. Carrying out our public function to exercise the right to address matters involving non-compliant employers by way of referring cases to the Director of Public Prosecutions.

4. How We Share Your Personal Data

The HIC may share your personal data as required, including under applicable legislation, with recipients that include joint data controllers, our data processors, and third parties. We will only share your personal data as permitted by the DPA.

Your personal data may be shared with the following recipients that support our public functions and operations:

  1. With other public authorities: Personal data may be shared with other public authorities – here, “public authorities” means Ministries, Portfolios, Offices, Departments, Statutory Authorities, Statutory Bodies and Government Companies – for the purposes set out in this Privacy Notice.
  2. With data processors external to the CIG: Personal data may be shared with persons providing services to the HIC as a data processor in compliance with the DPA. When they are acting as data processors, these service providers are only able to use personal data under our instructions. We engage data processors for a variety of processing activities, which may include:
    1. Information Technology;
    2. Records and Information Management, including storage facilities;
    3. Communications; and
    4. Security operations and fraud prevention.

      In limited circumstances, service providers who act as data processors for the HIC may also act as a separate data controller in relation to their own purposes for processing your personal data, e.g. to provide customer support, or for analytics or machine learning in order to improve their services. These are unrelated to the purposes for which the HIC processes your personal data and should be clearly and directly disclosed to you by the service provider through their own separate privacy notice. However, you may contact us to ask about our current service providers and specific instances, if any, that we are aware of where your personal data may be processed for a service provider’s own purposes.
  3. With legal advisors and other persons if required by law or in relation to legal proceedings or rights: Personal data may be disclosed as legally required, for the purpose of or in connection with proceedings under the law, if necessary to obtain legal advice, or if the disclosure is otherwise necessary to establish, exercise or defend legal rights. This may include disclosing your personal data for the following purposes:
    1. Seeking legal advice;
    2. Exercising or defending legal rights;
    3. Complying with internal and external audits or investigations by competent authorities; and
    4. Complying with information security policies or requirements.
  4. With other third parties: Personal data may be disclosed to other third-party recipients for the purposes set out in this Privacy Notice and in accordance with the DPA. Third parties may include:
    1. Hospitals and other health care facilities
    2. Approved Insurers (Insurance companies)
    3. Your employer or previous employer e.g. to investigate complaints made by you

5. Our Legal Bases for Processing Your Personal Data

Depending on applicable laws and other circumstances, the HIC will rely on specific legal bases, or “conditions of processing”, under the DPA to process your personal data. These may include:

  1. A legal obligation to which the HIC is subject, including to comply with various obligations under the Health Insurance Commission Act (2016 Revision), Health Insurance Act (2021 Revision), Health Insurance Regulations (2017 Revision), Procurement Act (2023 Revision) and Procurement Regulations (2022 Revision), the Public Management and Finance Act (2020 Revision) and Financial Regulations (2022 Revision), the Public Service Management Act (2018 Revision) and Personnel Regulations (2022 Revision), the Data Protection Act (2021 Revision) and Data Protection Regulations, 2018, and the National Archive and Public Records Act (2015 Revision);
  2. To exercise public functions, including the functions of the HIC to monitor the conduct of approved insurers;
  3. To protect your vital interests;
  4. Consent, e.g. to administer surveys and polls; and
  5. For the purposes of legitimate interests pursued by the HIC or by a third party or parties to whom the personal data may be disclosed, e.g. when disclosing records containing third party personal data in response to a request submitted under the Freedom of Information Act (2021 Revision).

Where we process your sensitive personal data, we will also meet a second legal basis. These may include:

a.    Consent, e.g. you have asked us to do 
b.    To exercise our public functions;
c.    To protect your vital interests;
d.    In relation to legal proceedings, including obtaining legal advice and otherwise establishing, exercising or defending legal rights; and

6. Children’s Personal Data

The HIC collects personal data relating to children under the age of 18 to enable us to deliver public services and programmes and carry out our functions. We may collect children’s personal data for any of the purposes set out in section 3 of this Privacy Notice

7. Security and International Transfers

The HIC has put in place appropriate technical, physical and organisational measures in order to keep your personal data secure. These safeguards maintain the confidentiality, integrity and availability of your personal data.
We will only transfer your personal data to a country or territory that ensures an adequate level of protection for your rights and freedoms in relation to the processing of your personal data, unless there is a relevant exemption or exception under the DPA. Exceptions may include your consent or appropriate safeguards.
Certain personal data collected and processed by the HIC is hosted on cloud infrastructure geographically located in Canada, the United Kingdom, and Germany, managed by the Department of eGovernment in its role as data processor, and its sub-processor, Liferay Inc. In limited circumstances, personal data may also be processed by Liferay Inc. and its authorised sub-processors for the purposes of disaster recovery, maintenance, and support.

8. How Long We Keep Your Personal Data

The HIC may store your personal data for as long as we need it in order to fulfil the purpose(s) for which we collected your personal data, and in line with any applicable laws. This includes the National Archive and Public Records Act (2015 Revision), which governs the creation, maintenance and disposal of all public records. Sometimes, we may anonymise your personal data so that it is no longer associated with you

9. Cookies

Cookies, in combination with pixels, local storage objects, and similar devices (collectively, "Cookies" unless otherwise noted), are used to distinguish between visitors to a website.
When you visit DHRS-HIC our website, small files known as Cookies may be stored on your computer, phone, tablet or any other device through your web browser. Information is stored in these text files. 
Enabling Cookies may allow for a more tailored browsing experience and is required for certain website functionality. [In the majority of cases, a Cookie does not provide us with any of your personal data.]
Please see the website’s Cookie Notice for more information about the use of Cookies.

Please see the website’s Cookie Notice for more information about the use of Cookies

10. Your Rights

The HIC will respect and honour your rights in relation to your personal data and implement measures that allow you to exercise your rights under the DPA and other applicable legislation.

In accordance with the DPA, your rights in relation to your own personal data include

  1. The right to be informed and the right of access: The right to request access to all personal data the HIC maintains about you as well as supplementary information about why and how we are processing your personal data. This is commonly known as a Data Subject Access Request and certain supplementary information about our processing is contained within this Privacy Notice.
  2. Rights in relation to inaccurate data: The right to request the rectification, blocking, erasure or destruction of any inaccurate personal data the HIC maintains on you. We will ensure, through all reasonable measures, that your personal data is accurate, complete and, where necessary, up‑to‑date, especially if it is to be used in a decision-making process.
  3. The right to stop or restrict Processing: The right to restrict or stop how the HIC uses your personal data in certain circumstances.
  4. The right to stop direct marketing: The right to cease the use of your personal data by the HIC for direct marketing purposes. The HIC does not currently carry out any direct marketing activities. However, we will update this Privacy Notice and we will also notify you in writing as required if this position changes.
  5. Rights in relation to automated decision making: The right to obtain information about and object to the use of automated decision making by the HIC using your personal data. The HIC does not currently use automated means to make decisions about you. However, we will update this Privacy Notice and we will also notify you in writing as required if this position changes.
  6. The right to complain: The right to complain to the Ombudsman about any perceived violation of the DPA by the HIC.
  7. The right to seek compensation: The right to seek compensation in the Court if you suffer damage due to a contravention of the DPA by the HIC.

You may contact the HIC, using the contact details listed below, to access and review your personal data or to exercise any other rights provided to you under the DPA. The HIC will take into consideration circumstances where, under the DPA or other applicable legislation, your rights may be limited or subject to conditions, exemptions or exceptions.

Upon contacting the HIC, we may need to verify your identity prior to fulfilling a request and may request additional information as required. In accordance with the DPA, the HIC may also charge a reasonable fee in relation to your request if it is unfounded or excessive in nature, or the HIC may reserve the right not to comply with the request at all.

To learn more about your rights, visit www.ombudsman.k

11. Data Protection Principles

When processing your personal data, the HIC will comply with the eight Data Protection Principles defined within the DPA:

  1. Fair and lawful processing: Personal data shall be processed fairly. In addition, personal data may be processed only if certain conditions are met, for example the data controller is subject to a legal obligation that requires the processing or the processing is necessary for exercise of public functions.
  2. Purpose limitation: Personal data shall be obtained only for one or more specified, explicit and legitimate purposes, and not processed further in any manner incompatible with that purpose or those purposes.
  3. Data minimisation: Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are collected or processed.
  4. Data accuracy: Personal data shall be accurate and, where necessary, kept up-to-date.
  5. Storage limitation: Personal data processed for any purpose shall not be kept for longer than is necessary for that purpose.
  6. Respect for the individual’s rights: Personal data shall be processed in accordance with the rights of data subjects under the DPA, including subject access.
  7. Security – confidentiality, integrity and availability: Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
  8. International transfers: Personal data shall not be transferred to a country or territory unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

12. How to Contact Us

The HIC has appointed a Data Protection Leader. If you have any questions about this Privacy Notice or how your personal data is handled, or if you wish to make a complaint, please contact:

       Email Address: hic@gov.ky

The HIC aims to resolve inquiries and complaints in a respectful and timely manner.

13. Changes to this Privacy Notice

The HIC reserves the right to update this Privacy Notice at any time and will publish a new Privacy Notice when we make any substantial updates. From time to time, the HIC may also notify you about the processing of your personal data in other ways, including by email or through our publications.

This Privacy Notice was last updated on 17 October 2025.