AIC Record Preservation Policies


Authority	[[department-of-infrastructure
Date received	2026-02-17
Outcome	Some information sent but part exempt
Outcome date	2026-03-13
Topic	[[transport-roads

Summary

The requester sought policies regarding record preservation and deletion authority for Airport Identity Card (AIC) applications, specifically concerning disputes and legal proceedings. The Department of Infrastructure partially disclosed the 'Pass Office Programme' document (Version 7.0) but redacted specific sections citing Section 25 exemptions.

Key Facts

The response includes the 'Pass Office Programme' document, Version 7.0, issued in April 2025.
The document has a default review period of 1 year and a retention period of 5 years.
Multiple sections of the provided document were redacted under Section 25 of the Freedom of Information Act.
The document is authored and owned by Kelly Quirk, Head of Passenger Operations.
The request specifically targeted governance around sponsor deletion of AIC applications and litigation holds.

Data Disclosed

31-Jan-2020
10/APR/2025
10/APR/2026
5 Years
1 Year
V7.0
IOMA/SEC/003
48 pages
2 documents

Exemptions Cited

Section 25

Original Request

I write to request recorded information held by the Department of Infrastructure (including Isle of Man Airport) under the Freedom of Information Act 2015 (Isle of Man).

This request concerns record preservation safeguards applicable to Airport Identity Card (AIC) decision-making.

Please provide the following recorded information held at the date of this request (including archived records and system-level governance records where applicable).

For the avoidance of doubt, this request includes any such recorded information that is currently operative, has been superseded, withdrawn, replaced, or amended, provided it is held by the Department at the date of this request, including any version history, amendment logs, or change control records.

Any recorded policy, procedure, guidance or standard operating instruction governing preservation of records relating to AIC applications where:

1.1 a dispute, complaint, or appeal is raised;

1.2 employment consequences are foreseeable; or

1.3 legal proceedings, regulatory complaints, tribunal claims, or judicial review are reasonably contemplated or foreseeable; and

1.4 any retention schedule, retention period, or deletion policy applicable to AIC application records and associated audit logs.

Any litigation hold, dispute-preservation, document retention suspension, or equivalent policy applicable to:

2.1 the Airport ID Centre;

2.2 AIC decision-making processes; or

2.3 ID Digital Gateway records held on the Department's behalf or within systems relied upon by the Airport.

Any recorded instruction, protocol, or system rule governing whether sponsor deletion of an AIC application overrides, is subject to, or must comply with preservation requirements in circumstances where a dispute, complaint, appeal, or proceedings are reasonably contemplated or foreseeable.
Any recorded policy, instruction, technical specification, or system governance document setting out:

4.1 who holds authority to delete an AIC application within the Gateway system;

4.2 whether deletion is automatic or manually authorised;

4.3 whether deletion is suspended where a dispute, complaint, appeal, or proceedings are reasonably contemplated or foreseeable;

4.4 whether the Airport retains any independent audit log, metadata, or system event record following sponsor deletion of an application.

If no recorded policy, procedure, instruction, or governance framework exists in respect of any of the above matters, please confirm this explicitly.

If any part of the requested information is considered exempt, please identify the specific exemption relied upon and provide partial disclosure where reasonably practicable.