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Cayman Islands: Ombudsman issues enforcement order against school for lack of legal basis in processing employee data

The Office of the Ombudsman ('the Ombudsman') announced, on 24 March 2021, that it had issued an enforcement order against St. Ignatius Catholic School for recording a meeting and processing the personal information of an employee without appropriate consent. In particular, the order outlines that the consent of the employee was not unambiguous or freely given, and was not appropriate given the imbalance of power, which resulted in the school not having a legal basis for the processing of personal data. As such, the order requires the school to:

  • destroy all copies of the recording, including any transcripts or extracts, within 10 days of receipt of this enforcement order, including any copies of the recording held on behalf of the school, such as that held by legal advisers;
  • develop procedures allowing it to recognise when consent is an appropriate legal basis for the processing of personal data in accordance with the data protection law; and
  • develop procedures on documenting consent and managing situations where consent is withdrawn.

You can read the press release here and the order here.