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STATES OF JERSEY
JERSEY DATA PROTECTION AUTHORITY: AUDITED FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2019
Presented to the States on 3rd December 2020
by the Minister for Economic Development, Tourism, Sport and Culture
STATES GREFFE
2020 R.134
JERSEY DATA PROTECTION AUTHORITY (JDPA)
AUDITED FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2019
AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
CONTENTS Page
General Information
Board report 2 Statement of Board's Responsibilities 3 Independent auditor's report to the Minister 4 - 5 Statement of Comprehensive Income and retained earnings 6 Statement of Financial Position 7 Notes to the Financial Statements 8 - 11
AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
GENERAL INFORMATION Members of the Authority
Jacob Kohnstamm Chair
Clarisse Giro! Voting Member
David Smith Voting Member
Gailina Liew Voting Member
Paul Routier Voting Member (appointed 19 June 2019)
Helen Hatton Voting Member (appointed 19 June 2019)
Dr Jay Fedorak Information Commissioner (non-voting member)
Registered Office 2nd Floor
5 Castle St
St Helier
Jersey
JE2 3BT
Banker
HSBC
PO Box 14
27 Halkett Street St Helier
Jersey
JE4 8NJ
Independent Auditors
Baker Tilly Channel Islands Limited 1st Floor Kensington Chambers 46/50 Kensington Place
St Helier Jersey
Jersey
JE4 0ZE
Page 1
JERSEY DATA PROTECTIOW.UTHORITY (JDPA) AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
BOARD REPORT
The Board present their report and the audited financial statements of the Jersey Data Protection Authority (JDPA) ("The Authority") for the year ended 31st December 2019.
Incorporation
The JDPAwas incorporated in Jersey under the Data Protection Authority (Jersey) Law 2018 ("OPAL") on 25 May 2018.
Corporate governance and delegation of authority
The JDPA, through the Board, carries the ultimate responsibility for the discharge of the responsibilities under the OPAL. The JDPA operates under the name of the Jersey Office of the Information Commissioner (JOIC).
The JDPA is the guardian of independence, sets the organisation's strategic direction, holds the Commissioner to account and provides the Commissioner with advice, support and encouragement. It ensures that JOIC provides value for money and complies with appropriate policies and procedures with respect to human resources, financial and asset management, and procurement.
The JDPA has the authority to appoint (or re-appoint) the Commissioner or remove the Commissioner from office. The JDPA has very limited operational responsibilities and these do not include day-today operations, individual casework or most enforcement decisions. The Board has the ability to delegate functions to the Commissioner, but cannot delegate the following functions: this power of delegation; the function of reviewing any of its decisions; the issuing of a public statement under Article 14 of the OPAL; the making of an order to pay an administrative fine; the preparation of the Annual Report. By
a Board Resolution of 7 January 2019, the JDPA delegated all its functions to the Commissioner, in accordance wrth Article 10, except 'Reserved Functions'. In performing the 'Reserved Functions' the Board will have the assistance of the Commissioner.
Resutt~~dends ·.
. ,: 1t]e fin~al ~ta!ements provide an overview of the Jersey Data Protection Authority's income and expenditure for 2019 .
Going Concern
The Board consider, given the financial condition of the Authority, the use of the going concern basis is appropriate for the current period and for 12 months from the date of signing these financial statements.
Auditors
The Comptroller and Auditor-General exercised her power under Article 43(3)(a) of the Data Protection Authority (Jersey) Law 2018 (as defined by the Comptroller and Auditor General (Jersey) Law 2014), to appoint Baker Tilly Channel Islands as auditor of the authority for the 5 years from the year ended 31st December 2018 to 31st December 2022 .
. "l~.Q~~ Date
Page 2
FOR THE YEAR ENDED 31 DECEMBER 2019
STATEMENT OF BOARD'S RESPONSIBILITIES
The JDPA is responsible for preparing the board's report and the financial statements in accordance with applicable law and regulations.
The Data Protection Authority (Jersey) Law 2018 requires the board to prepare financial statements for each financial period. Under that law, the board have elected to prepare the financial statements in accordance with United Kingdom Accounting Standards, including Section 1A of the Financial reporting Standards 102, the Financial Reporting Standard in the United Kingdom and Republic of Ireland ("FRS 102 1A") (collectively, United Kingdom Generally Accepted Accounting Practice ("UK GAAP"). The board must not approve the financial statements unless they are satisfied that they give a true and fair view of the state of affairs of the Authority and of the surplus or deficit for that period.
In preparing these financial statements, the JDPA is required to:
select suitable accounting policies and then apply them consistently;
make judgements and estimates that are reasonable and prudent;
state whether applicable accounting standards have been followed, subject to any material departures as disclosed and explained in the financial statements; and
prepare the financial statements on a going concern basis unless it is inappropriate to presume that the Authority will continue in business.
The voting members are responsible for keeping adequate accounting records that are sufficient to show and explain the Commission's transactions and disclose with reasonable accuracy at any time the financial position of the Authority and enable them to ensure that the financial statements comply with the Data Protection Authority (Jersey) Law 2018. They are also responsible for safeguarding the assets of the JDPA and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities
The JDPA at the date of approval of this report confirm that:
so far the board are aware, there is no relevant audit information of which the Authority's auditor is unaware; and
each board member has taken all steps that they ought to have taken as a member to make themselves aware of any relevant audit information and to establish that the JDPA's auditor is aware of that information.
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Page 3
JERSEY DATA PROTECTION AUTHORITY (JDPA)
INDEPENDENT AUDITOR'S REPORT TO THE MINISTER OF THE GOVERNMENT OF JERSEY
Opinion
We have audited the financial statements of the Jersey Data Protection Authority (referred to as the "Authority") for the year ended 31 December 2019 which comprise of the statement of comprehensive income and retained earnings, statement of financial position and the related notes including a summary of significant accounting policies. The financial framework that has been applied in their preparation is the Data Protection Authority (Jersey) Law 2018 ("the Law") and United Kingdom Accounting Standards, including Section 1A of Financial Reporting Standard 102 The Financial Reporting Standard in the United Kingdom and Republic of Ireland ("FRS 102 1A") (collectively, United Kingdom Generally Accepted Accounting Practice ("UK GAAP").
In our opinion the financial statements:
• give a true and fair view of the state of the Authority's affairs as at 31 December 2019 and of its surplus for the year then ended;
• have been properly prepared in accordance with UK GAAP; and
• have been properly prepared in accordance with the requirements of the Law.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor's responsibilities for the audit of the financial statements section of our report. We are independent of the Authority in accordance with the ethical requirements that are relevant to our audit of the financial statements in Jersey, including the FRC's Ethical Standard, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Conclusions relating to going concern
We have nothing to report in respect of the following matters in relation to which the ISAs (UK) require us to report to you where:
• the Authority's use of the going concern basis of accounting in the preparation of the financial statements is not appropriate; or
• the Authority has not disclosed in the financial statements any identified material uncertainties that may cast significant doubt about the Authority's ability to continue to adopt the going
concern basis of accounting for a period of at least twelve months from the date when the financial statements are authorised for issue.
Other information
The Board of voting members of the Authority ("the Board") with delegation to the Information Commissioner ("the Commissioner") are responsible for the other information. The other information comprises the information included in the financial statements, other than the audited financial statements and our auditor's report thereon. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon. In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether there is a material misstatement in the financial statements or a material misstatement of the other information. If, based on the work performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.
JERSEY DATA PROTECTION AUTHORITY (JDPA) INDEPENDENT AUDITOR'S REPORT - CONTINUED
Matters on which we are required to report by exception
In light of our knowledge and understanding of the Authority and its environment obtained in the course of the audit, we have not identified material misstatements in the Board's report.
We have nothing to report in respect of the following matters where our engagement letter requires us to report to you if, in our opinion:
• whether proper accounting records have not been kept by the Authority;
• whether proper returns adequate for the audit have not been received from branches not visited by us; and
• whether the Authority's accounts are in agreement with its accounting records and returns.
Responsibilities of the Board
As explained more fully in the Board's responsibilities statement on page 3, the Board is responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the Board determines necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the Board is responsible for assessing the Authority's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Board either intend to liquidate the Authority or to cease operations, or have no realistic alternative but to do so.
Auditor's responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.
A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting Council's website at www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor's report.
Use of this report
This report is made solely to the Minister and the Comptroller and Auditor General in accordance with section 43 of the Law. Our audit work has been undertaken so that we might state to the Minister and the Comptroller and Auditor General those matters we are required to state to them in an auditor's report and for no other purpose.
To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the Authority, the Minister and the Comptroller and Auditor General for our audit work, for this report, or for the opinions we have formed.
Baker Tilly Channel Islands Limited Chartered Accountants
St Helier, Jersey
Date: 29 October 2020
JERSEY DATA PROTECTIONII.UTHORITY (JDPA) AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
STATEMENT OF COMPREHENSIVE INCOME AND RETAINED EARNINGS
Notes 2019 2018
£ £
Turnover 4 222,646 61,142 Operating expenses 5 (1,479,260) (724,935) Deficit on ordinary activities (1,256,614) (663,793)
Other income
Government grant 6 1,396,074 663,793
1,396,074 663,793 Taxation 7
Surplus for the year 139,460
The JDPA's turnover and expenses all relate to continuing operations. There are no recognised gains or losses other than those shown above.
JERSEY DATA PROTECTIONII.UTHORITY (JDPA) AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
STATEMENT OF FINANCIAL POSITION
ASSETS Notes 2019 2018 Fixed assets £ £ Tangible assets 8 47,485
Intangible assets 9 74,129
121,614
Current assets
Trade and other receivables 10 74,184 41,567 Cash and cash equivalents 11
74,184 41,567 TOTAL ASSETS 195,798 41,567
CREDITORS - amounts falling due within one year
Trade and other payables 12 (56,338) (41,567) (56,338) (41,567)
TOTAL ASSETS LESS CURRENT LIABILITIES 139,460
EQUITY
Share Capital 13
Reserves 139,460 TOTAL EQUITY 139,460
The financial statements on pages 8 to 11 have been prepared in accordance with the Data Protection Authority (Jersey) Law 2018 and Section 1A of Financial Reporting Standard 102.
The accounts were approved and authorised for issue on 29th October 2020 by the board and signed on its behalf by: c·h~i~ (~ /4:
JERSEY DATA PROTECTIOf\16.UTHORITY (JDPA) AUDITED FINANCIAL STATEMENTS
NOTES TO THE FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2019
- GeneralInformation
The Jersey Data Protection Authority (JDPA) (the "Authority") was created by the Data Protection (Jersey) Law 2018 on 25 May 2018 and is responsible for the registration and regulation of Data Protection in Jersey. This law transferred all responsibilities for registration and regulation of Data Protection prescribed as the duty of the Minister or other States bodies to this new Authority. The Authority is a body corporate and its registered office is 2nd Floor, 5 Castle Street, St Helier, Jersey, JE2 3BT.
- Statement of compliance
The financial statements have been prepared in compliance with Section 1A of Financial Reporting Standard 102 (FRS 102) 'The Financial Reporting Standard applicable in the UK and Republic of Ireland' issued by the Financial Reporting Council and the Data Protection Authority
(Jersey) Law 2018.
- Summary of Significant accounting policies
The principle accounting policies applied in the preparation of these financial statements are set out below. These policies have been consistently applied to all years presented, unless otherwise stated.
Basis of accounting
The financial statements have been prepared on the going concern basis, under the historical cost convention. The Authority has applied the small entities regime under FRS 102(1A). which allows qualifying entities certain disclosure exemptions. The Authority has taken advantage of the exemption from preparing a statement of cash flows under paragraph 7 .1 b.
Functional and presentational currency
The financial statements are prepared in Pounds Sterling (GBP or£) which is the functional and presentational currency of the Authority.
Accounting estimates
The preparation of financial statements requires the use of certain accounting estimates. It also requires management to exercise its judgement in the process of applying accounting policies. Accounting estimates involve management's judgment of expected future benefits and obligations relating to assets and liabilities (and associated expenses and income) based on information that best reflects the conditions and circumstances that exist at the reporting date. There have been no changes to the accounting estimates from the previous financial period.
- Going concern
The board consider, given the financial condition of the Authority, the use of the going concern basis is appropriate for the current period and for 12 months from the date of signing these accounts.
- Provisions
Provisions are recognised when the Authority has a present legal or constructive obligation, as a result of past events, for which it is probable that an outflow of economic benefits will be required to settle the obligation in future and the amount of the obligations can be reliably estimated.
- Economic useful lives of intangible and tangible fixed assets
The Authority's tangible fixed assets are depreciated on a straight-line basis over their economic useful lives. Useful economic lives of equipment are reviewed by management periodically. The review is based on the current condition of the assets and the estimated period during which they will continue to bring an economic benefit to the Authority.
Revenue recognition
Registration fees
Under the terms of Data Protection Authority (Jersey) Law 2018 registrations made to the Authority are valid for one year. The registration fees are non-refundable and fall due each year on an annual basis. Income from registrations is recognised on accrual basis, when they are realized / realizable and when they are earned. Deferred revenue represents revenues collected but not earned as of December 31. This is primarily composed of revenue from entities/individuals accrued in advance.
Operating Expenses
Expenses are accounted for on an accrual basis.
Employment benefits
Short-term benefits
Short-term employee benefit obligations are measured on an undiscounted basis and are expensed as the related service is provided. A provision is recognised for the amount expected to be paid under short-term cash bonus or profit-sharing plans if the Group has a present legal or constructive obligation to pay this amount as a result of past service provided by the employee and the obligation can be estimated reliably.
Pension costs
Staff initially employed by the States of Jersey before 3 September 2010 of which there are several members which are part of the Public Employees Contributory Retirement Scheme ("PECRS"). The Authority is not responsible to fund any deficit and to maintain the specific level of the pension assets to meet pension liabilities. The assets are held separately from those of the States of Jersey. Contribution rates are determined by an independent qualified actuary so as to spread the costs of providing benefits over the members' expected service lives.
Contributions to the scheme have been accounted for as if they are contributions to a defined contribution scheme at a rate of 16% (2018: 16%).
AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
Pension costs (continued)
Actuarial valuations are performed on a triennial basis; the most recently published was the PECRS Actuarial Valuation for 31 December 2016 on 16 March 2018. The main purposes of the valuations are to review the operation of the scheme, to report on its financial condition, and to confirm the adequacy of the contributions to support the scheme benefits. Copies of the latest annual accounts of the scheme, and States of Jersey, may be obtained from the States Treasury, 19-21 Broad St, St Helier, JE2 3RR or online at:
www.gov.je/W orking/W orkingForTheStates/Pensions/PublicEmployeePensionFund/Pages/Public ServicePensionPublications.aspx
Interest receivable
Interest receivable is accounted for on an accrual basis.
Government Grant
Grants are recognised in other income in the year the related costs are incurred by the Authority for which the grant is intended to compensate. For grants which are received by the Authority for compensation for expenses or deficit which have already been incurred, the grant is recognised in income when it is received or receivable.
Tangible assets
Tangible assets consists of office equipment which are stated at historical cost less accumulated depreciation. Cost includes all costs directly attributable to bringing the asset to working condition for its intended use. Depreciation is calculated on the straight-line method to write-off
the cost of equipment to their estimated residual values over their expected useful lives as follows:
- Office equipment 3 years
- IT equipment 3 years
The useful lives and depreciation methods used are reviewed regularly and any adjustments required are effected in the charge for the
current and future years as a change in accounting estimate. Gains and losses on disposal of equipment are determined by reference to their carrying amounts and are taken into account in determining net profit. Repairs and renewals are charged to the statement of profit or loss
and other comprehensive income when the expenditure is incurred. The carrying values of the plant and equipment are reviewed for impairment when events or changes in circumstances indicate the carrying values may not be recoverable. If any such indication exists, and where the carrying values exceed the estimated recoverable amounts, the plant and equipment are written-down to their recoverable amounts.
Intangible assets
Externally acquired intangible assets (softwares) are initially recognised at cost and subsequently amortised on a straight-line basis over their useful economic lives of 5 years. The carrying amount of each intangible asset is reviewed periodically and adjusted for impairment where considered necessary.
The Authority's policy is to review the remaining useful economic lives and residual values of property, plant and equipment on an ongoing basis and to adjust the depreciation charge to reflect the remaining estimated useful economic life and residual value.
Financial assets
Basic financial assets, including trade and other receivables and cash and bank balances are initially recognised at transaction price, unless the arrangement constitutes a financing transaction, where the transaction is measured at the present value of the future receipts discounted at a market rate of interest.
Financial assets are derecognised when (a) the contractual rights to the cash flows from the asset expire or are settled, or (b) substantially all the risks and rewards of the ownership of the asset are transferred to another party or (c) despite having retained some significant risks and rewards of ownership, control of the asset has been transferred to another party who has the practical ability to unilaterally sell the asset to an unrelated third party without imposing additional restrictions.
Trade and other receivables
Trade and other receivables are carried at their anticipated realisable values. An allowance is made for impaired trade and other receivables based on a review of all outstanding amounts at the year-end. Bad debts are written-off during the year in which they are identified.
Cash and cash equivalents
Cash and cash equivalents comprise cash on hand and other short-term highly liquid investments with original maturities of three months or less.
Financial liabilities
Basic financial liabilities, including trade and other payables are initially recognised at transaction price, unless the arrangement constitutes a financing transaction, where the debt instrument is measured at the present value of the future receipts discounted at a market rate of interest. Financial liabilities are derecognised when the liability is extinguished, that is when the contractual obligation is discharged, cancelled or expires.
Trade and other payables
Trade payables are obligations to pay for goods or services that have been acquired in the ordinary course of business from suppliers. Accounts payable are classified as current liabilities if payment is due within one year or less. If not, they are presented as non- current
liabilities. Trade payables are recognised initially at transaction price and subsequently measured at amortised cost using the effective interest method.
Contingencies
Contingent liabilities, arising as a result of past events, are disclosed when it is possible that there will be an outflow of resources but the amount cannot be reliably measured at the reporting date. Contingent liabilities are disclosed in the financial statements unless the probability of an outflow is remote.
Contingent assets are disclosed in the financial statements but not recognised where an inflow of economic benefits is probable.
AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
- Turnover
Turnover is made up of registration fees under the terms of Data Protection Authority (Jersey) Law 2018.
- Operating expenses 2019 2018
£ £
Staff including Commissioner and Deputy Commissioner 753,495 355,870 Supplies and Services 382,156 268,748 Administrative Expenses 18,644 21,738 Audit and accountancy fees 15,000 18,500 Premises and Maintenance 265,351 59,095 Bank charges 2,339 984 Depreciation and amortisation 42,275
1,479,260 724,935
- Governmentgrant
Any net deficit by the Authority is financed by the States of Jersey under the 2018 partnership agreement. Any surplus will be paid to the States of Jersey under the 2018 partnership agreement.
- Taxation
Article 42 of the Data Protection Authority (Jersey) Law 2018 provides that the income of the Authority shall not be liable to income tax under the Income Tax (Jersey) Law 1961
- Tangible assets 2019 2018
£ £
Office
IT equipment
equipment Total Total
Cost
As at beginning of year
Additions in the year 35,815 35,413 71,228
35,815 35,413 71,228
Accumulated depreciation
As at beginning of year
Depreciation charge for the year 11,938 11,805 23,743
11,938 11,805 23,743
Net book value
As at beginning of year
As at end of year 23,877 23,608 47,485
2019 2018
- Intangible assets £ £ Software
Cost
As at beginning of year
Addition 92,661
92,661
Accumulated amortisation
As at beginning of year
Charge for the year 18,532 18,532
Net book value
As at beginning of year
As at end of year 74,129
The Authority has brought forward a website from the previous Data Protection department at nil Net Book Value.
- Trade and other receivables 2019 2018
£ £
Grant Receivable 56,338 21,942 Deposit - PBS office space 7,500 Prepayments 17,846 12,125
74,184 41,567
AUDITED FINANCIAL STATEMENTS
FOR THE YEAR ENDED 31 DECEMBER 2019
- CashandcashequivalentsTheAuthorityhas a nilbalanceattheendoftheyear(2018: nil)asallbalancesaretransferredtotheGovernmentofJerseyinlinewith 2018partnershipagreement(seenote6).
- Trade and other payable 2019 2018
£ £
Accruals and trade creditors (56,338) (41,567) (56,338) (41,567)
- Sharecapital
The J DPA was incorporated in Jersey under the Data Protection Authority (Jersey) Law 2018 and has no share capital.
- RelatedPartyTransactions 2019 2018
£ £
Commissioner 147,759 72,134 Chair 11,250 13,715 Voting member (Non Executive Director) 7,200 1,964 Voting member (Non Executive Director) 7,200 1,800 Voting member (Non Executive Director) 7,200 1,500 Voting member (Non Executive Director) 3,600
Voting member (Non Executive Director) 3,600
187,809 91,113
Key management personnel includes the Commissioners and the Voting Menbers who together have authority and responsibility for planning, directing and controlling the activities of the JDPA
There are no other transactions with key managament personnel other than reimbursement of expenses incurred for JDPA purposes.
The JPDA has recognised £1,397,074 (2018: £663.793) as grant income from the Government of Jersey out of which £56,338 (2018 £21,942) was receivable-net as at 31 December 2019. The JDPA is accountable to the Government of Jersey, who incorporated ii.
- ControllingPartyTheJDPAwasincorporatedinJerseyundertheDataProtectionAuthority(Jersey)Law2018andworksasanindependentAuthority.
- Subsequent Events
In early 2020, the World Health Organisation (WHO) had reported several cases of an unusual form of pneumonia originating in Wuhan, China. Substantive information has come to light identifying coronavirus (or COVID-19) as the cause of a global pandemic which was officially declared in March 2020.
The JDPA does not expect to face any significant problems with operations over the next 12 months as all operations remain virtually open with the JDPA's employees mainly working remotely to decrease the probability of being infected. Furthermore, management is not expecting a major impact on the financial position of the J DPA as, under the partnership agreement, any shortfall is financed by the Government of Jersey through government grants.
The JDPA will continue to closely monitor the pandemic as an increase in magnitude and duration may lead to a long term general economic downturn. A full assessment of the cost of the pandemic will be done in the first quarter of 2021.
The emergence and spread of the COVID-19 virus is not considered to provide more information about conditions that existed at the balance sheet date and thus considered a non-adjusting event.