CSS Limited (known as "Channel Ship Services (CSS)") is the data controller responsible for your  personal information. We are a maritime employment and recruitment services company based in  Jersey, providing staffing and placement services in the maritime sector. We are registered with the  JOIC under registration number 19662. 

This privacy notice explains how we collect, use, and protect your personal data in accordance with  the Data Protection (Jersey) Law 2018 ("DPJL"). Please read it carefully to understand our privacy  practices. 

The Data Protection Manager ("DPM") 

Channel Ship Services (CSS) has appointed an external Data Protection Manager to oversee our data  protection compliance and to serve as your point of contact for data protection matters. 

Email: GDPR@css-shipservices.com 

You can contact our Data Protection Manager if you have any questions about how we process your  personal data or if you wish to exercise any of your data subject rights. 

The Kind of Information We Hold About You 

Channel Ship Services (CSS) collects and processes personal data to match candidates with suitable  job positions in the maritime sector and to comply with relevant maritime and employment law  obligations. 

We hold two main categories of information about you: 

• Standard personal data (such as your name, contact details, and work history) • Special category data (such as health information and information about your ability to work  at sea) 

We explain each category in detail below. 

How Is Your Personal Information Collected? 

We collect your personal information in a number of ways: 

• Directly from you when you complete application forms, submit your CV, or contact us about  job opportunities
• From references you provide to us
• From our recruitment platform when you create or update your candidate profile • From documents you supply to us (such as educational certificates, professional  qualifications, and medical assessments)
• During telephone or email communication with us

What Information Do We Collect About You? 

Special Category Data 

In addition to the standard personal data listed above, we also collect and process special category  data about you. Special category data is information about your health, disability status, or other  sensitive personal circumstances. 

We collect the following special category data: 

• Health information and medical records
• Information about disabilities
• Details of previous injuries or medical conditions
• Your ability to work at sea (fitness assessments)
• Information about allergies
• Details of medication use 

We process this information because it is necessary to assess your suitability for maritime roles, to  comply with maritime health and safety regulations, and to ensure your wellbeing in the workplace.  We handle this sensitive information with the highest level of care and confidentiality.

How We Will Use Information About You 

Channel Ship Services (CSS) uses your personal data for a number of purposes. We rely on different  legal grounds (called "lawful bases") to process your information depending on the nature of the  use. Below we explain each lawful basis we rely on, together with realistic examples of how we use  your data: 

1. Contractual Necessity 

We process your personal data because it is necessary to perform a contract with you or to take  steps at your request before entering into a contract. 

Example: When you apply for a maritime position through us, we use your CV, employment history,  qualifications, and health information to assess your suitability for the role and to match you with  appropriate job opportunities. We also use your contact details to communicate with you about  vacancies and to arrange interviews. This processing is necessary to fulfil our recruitment services  and to establish the terms of any placement. 

2. Legal Obligation 

We process your personal data because we are required to do so by law, including maritime  regulations and employment law. 

Example: Maritime law and international conventions (such as the International Safety Management  Code) require us to verify that candidates meet specific health and safety standards before they are  deployed on vessels. We therefore collect and verify your health information, medical certificates,  and safety-related qualifications to comply with these legal requirements. We also retain records of  your fitness to work at sea as required by maritime regulatory authorities. 

3. Legitimate Interests 

We process your personal data where it is necessary for the legitimate interests pursued by us or a  third party, provided that this does not override your rights and freedoms. 

Example: We have a legitimate interest in maintaining an accurate database of candidates so that  we can efficiently match your skills and experience with suitable roles in the future. We also have a  legitimate interest in contacting you by email or telephone about opportunities that align with your  career aspirations, and in sharing your information (with your knowledge) with prospective  employers in the maritime sector. This helps us to provide an effective recruitment service and to  support the growth of the maritime industry in the Channel Islands. 

4. Consent 

We process your personal data where you have given us your explicit consent to do so. 

Example: We may ask for your consent to process health information that goes beyond what is  required by maritime law, such as consent to contact your doctor or occupational health provider for  additional medical information. We will only process this information if you have given us clear  permission to do so. You are free to withdraw your consent at any time by contacting us.

Change of Purpose 

Channel Ship Services (CSS) will use your personal data only for the purposes for which we collected  it, as set out above. If we intend to use your data for a new purpose, we will provide you with  information about that new purpose and the lawful basis for the processing before we begin. 

We will not use your personal data in a way that you would not reasonably expect, unless we have a  lawful basis for doing so and we have notified you of the change in advance. 

If we wish to use your data for a purpose that requires your consent (such as marketing), we will ask  for your explicit permission before we proceed. 

Data Sharing 

Channel Ship Services (CSS) shares your personal data with carefully selected third parties who help  us to deliver our services and meet our legal obligations. We only share your data where it is  necessary and lawful to do so. All organisations that process your data on our behalf are required to  maintain the same high standards of data protection and security that we apply. 

The table below sets out the main processors who handle your data:

We may also be required to share your personal data where the law requires us to do so, for  example with maritime regulatory authorities, employment law enforcement agencies, or in  response to a court order or legal process. 

International Data Transfers 

Your personal data may be transferred outside Jersey as part of our service delivery. Channel Ship  Services (CSS) ensures that appropriate safeguards are in place for any such transfers to protect your  data to the same standard required under the Data Protection (Jersey) Law 2018. 

Data Security 

Channel Ship Services (CSS) takes the security of your personal data very seriously. We have  implemented appropriate technical and organisational measures to protect your data against  unauthorised access, alteration, disclosure, or destruction. These measures include encryption,  access controls, secure data storage, regular security reviews, and staff training on data protection  and information security. 

However, please note that no system is completely secure. If you become aware of a security breach  or have concerns about the security of your information, please contact us immediately using the  details provided below. 

Data Retention 

Channel Ship Services (CSS) retains your personal data only for as long as necessary to fulfil the  purposes for which it was collected, or as required by law. Our approach to data retention is set out  in a Data Retention Schedule, which is available upon request. 

To help ensure that retained personal data remains accurate and up to date, Recruit CRM and CMM automatically send an email every two years to employees, former employees, candidates,  contractors, and other individuals whose personal data is held on these platforms. Individuals who  wish to review, update, or request deletion of their personal data will be provided with login details  that allow access only to their own records. If no response is received, personal data may be  retained or deleted in accordance with our retention schedule.  

Rights of Access, Correction, Erasure and Restriction 

Under the Data Protection (Jersey) Law 2018, you have the following rights in relation to your  personal data:

• Right of access: You have the right to request a copy of the personal data we hold about you  and to receive information about how we process it.
• Right to rectification: You have the right to ask us to correct any inaccurate or incomplete  personal data we hold about you.
• Right to erasure: In certain circumstances, you have the right to request that we delete your  personal data. This is sometimes called the "right to be forgotten".
• Right to restrict processing: You have the right to ask us to restrict the processing of your  personal data in certain circumstances, for example where you dispute its accuracy. • Right to data portability: You have the right to receive your personal data in a structured,  commonly used, and machine-readable format, and to transmit that data to another  controller.
• Right to object: You have the right to object to the processing of your personal data in  certain circumstances, including where we are processing your data on the basis of a  legitimate interest.
• Rights in relation to automated decision-making: You have rights in relation to decisions  based solely on automated processing, including profiling. 

These rights are not absolute and may be limited in certain circumstances. For example, we may be  unable to delete your data where we are required by law to retain it, or where we need it to defend  a legal claim. 

How to Request Your Information 

To exercise any of the rights listed above, please submit your request using our Data Rights Portal. 

Alternatively, you can also email your request to GDPR@css-shipservices.com or write to us at  Channel Ship Services (CSS), 3rd Floor, Herald House, 8 Hill Street, St Helier, Jersey, JE2 4UA. 

Please make your request as clear as possible and include any information that helps us to identify you (such as your full name, email address, and any reference number we may have issued to you).  If you ask us to provide information, we will need to verify your identity before we can do so. 

Channel Ship Services (CSS) will respond to your request within four weeks of receipt. Where a request is complex or where you have made multiple requests, we may extend this period by a  further eight weeks. We will inform you of any extension and the reasons for it within the original  four-week period. 

Right to Withdraw Consent 

Where we are processing your personal data on the basis of your consent (for example, to process health information or other special category data), you have the right to withdraw that consent at  any time. You can withdraw your consent by contacting us using the details in the section "How to  Request Your Information" above, or by using our Data Rights Portal. 

Withdrawal of consent will not affect the lawfulness of processing that took place before your withdrawal. 

Automated Decision-Making 

We do not use automated decision-making or profiling in relation to your personal information.

Changes to this Privacy Notice 

Channel Ship Services (CSS) may update this privacy notice from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the revised privacy notice on our website or by sending you an email. Your  continued use of our services following any changes will constitute your acceptance of the revised privacy notice. 

Complaints 

If you have any concerns about how Channel Ship Services (CSS) handles your personal data, or if  you believe we have breached the Data Protection (Jersey) Law 2018, please contact us in the first  instance: 

Channel Ship Services (CSS) 

3rd Floor, Herald House 

8 Hill Street 

St Helier 

Jersey, JE2 4UA 

Tel: +44 (0) 1534 888227 

Email: GDPR@css-shipservices.com 

Our Data Protection Manager is available to assist with any data protection queries or complaints: Email: GDPR@css-shipservices.com 

If you are not satisfied with our response, or if you wish to lodge a formal complaint, you have the  right to contact the Jersey Office of the Information Commissioner (JOIC), which is the independent  supervisory authority responsible for data protection in Jersey: 

Jersey Office of the Information Commissioner 

2nd Floor 

5 Castle Street 

St Helier 

Jersey, JE2 3BT 

Tel: +44 (0) 1534 716530 

Email: enquiries@jerseyoic.je 

Web: jerseyoic.org 

You have the right to lodge a complaint with the JOIC at any time. Channel Ship Services (CSS) is  registered with the JOIC under registration number 19662.