Conference attendance

Summary

A request was made for the names and attendance details of political members and civil servants at the ICE Totally Gaming exhibition, including hotel arrangements and accompanying family members. The Department for Enterprise disclosed the names of senior attendees and their schedule but withheld the names of junior staff and information regarding family travel under data protection exemptions.

Key Facts

• The event in question is the ICE Totally Gaming exhibition held in London from 6 to 8 February 2018.
• Senior attendees named include Mrs Daphne Caine MHK, Mr Tony Ure, Mr Tony Jones, and Mr Brian Donegan.
• Names of junior staff members (Marketing Communications Executive, Marketing Content & Communications Officer, e-Gaming Administration Officer) were withheld.
• The Department stated that all junior staff expressed a wish for their names to be withheld.
• Information regarding hotel reservations and accompanying family members was not provided in the response.

Data Disclosed

• 06-Feb
• 07-Feb
• 08-Feb
• 2018-01-17
• 2018-02-23
• section 25
• Data Protection Act 2002
• schedule 2

Exemptions Cited

• Section 25 of the Freedom of Information Act 2015 (absolutely exempt personal information)
• Data Protection Act 2002 (disclosure would contravene data protection principles)

Original Request

How many political members including names and civil servants including names will be attending the ICE exhibition and in which hotel and type of room that has been reserved Will any wives, children and or partners will be travelling with them?

Data Tables (1)

Full Response Text

Chief Executive Mark Lewin Direct Dial No: (01624) 686733 Reception (01624) 686400 www.gov.im/dfe Email: foi.ded@gov.im Date: 23 February 2018 FOI Reference: IM1177-062i

Department for Enterprise • 1st Floor, St George’s Court • Upper Church Street • Douglas • Isle of Man • IM1 1EX
Dear

REQUEST UNDER THE FREEDOM OF INFORMATION ACT 2015 (“the Act”) We write further to your request to the Department for Enterprise (“the Department”), dated 17 January 2018, regarding your request for the following information: Question 01: “How many political members including names and public servants including names will be attending the ICE exhibition” Question 02: “Which hotel and type of room has been reserved?”
Question 03: “Will any wives, children and or partners will be travelling with them?” Response to your request While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested. The statutory exemption sections are shown as part of the corresponding answers below: Question 01: How many political members including names and public servants including names will be attending the ICE exhibition? In response to Question 01, the “ICE exhibition”, or the ICE Totally Gaming 3 day event in London, is the leading global event representing the entire international gaming industry for the purpose of networking and business development. The table below shows which public servants and political members will be attending on each day: Attendees 06-Feb 07-Feb 08-Feb Mrs Daphne Caine MHK ✓

Mr Tony Ure, Head of e-Gaming ✓ ✓ ✓ Mr Tony Jones, e-Gaming Development Manager ✓ ✓ ✓ Mr Brian Donegan, e-Business Development Manager ✓ ✓ ✓ Marketing Communications Executive *

✓

Marketing Content & Communications Officer * ✓

e-Gaming Administration Officer * ✓ ✓ ✓

• While our aim is to provide information whenever possible, in this instance we are unable to provide some the information you have requested because it is absolutely exempt under section 25 of the Act (absolutely exempt personal information). The reasons why that exemption applies are that:  The Department is satisfied that the information amounts to personal data under the Data Protection Act 2002.  The Department is satisfied that disclosure of the information would contravene one of the data protection principles; namely that the Department can only disclose the information where it would be fair, lawful and meet one of the conditions in schedule 2 and in this case, on balance, none of those conditions have been met. The Department has considered the exemption to the names of the public servants and political members (“attendees”) on an individual basis; deciding whether it would be fair, lawful or meet one of the conditions in schedule 2 of the Data Protection Act 2002:  Information as a professional or as an individual As the information requested was in relation to the attendee’s professional roles and not them as individuals; therefore it was decided that there must be some expectation of disclosure, and that in relation to this factor, would be fair.  Seniority It was decided that as our most senior attendees at the ICE Totally Gaming event, it would be fair to disclose the names of the Head of e-Gaming, the e-Gaming Development Manager, the e-Business Development Manager and the attending Political Member, without contravening the data protection principles, given their greater level of accountability and decision-making within the Department. With that, disclosure of the less senior attendee’s names was determined to be unfair.  Extent of public facing nature of the role While all attendees were present at the event in order to promote our island and our Department, less senior staff do not hold a position they are accountable/ responsible for Departmental decisions; therefore disclosure would be unfair.  Potential harm that could be caused by disclosing that person’s name Given the status of the less senior attendees it would be unfair to disclose their names as this information might result in various adverse consequences for these staff members (see above); therefore disclosure of their names would be unfair.  Expectation of privacy The Department acknowledges that while there is no set grade by Government, below which all public servants’ personal information will be withheld, it does have a duty of care towards these staff members. The Department does routinely ask all staff for whom personal information is requested, if they are happy for this information to be disclosed; this is without an expectation or guarantee of absolute privacy, but staff know that their preferences will be considered. In this case, all such staff expressed a wish for their names to be withheld. It was also felt that disclosing their names added no more value to our response than their job titles alone. Therefore, disclosure of these names would be unfair.

Taking all of these factors into account, the Department has decided to disclose the names only of the more senior attendees to the ICE Totally Gaming Event; and apply section 25 exemption of the Act, to withhold the names of our less senior attendees.

Question 02: Which hotel and type of room has been reserved? In response to Question 02, attendees from e-Gaming and e-Business will be staying in the Aloft London ExCel Hotel (the hosting venue) in double rooms. Those from the Marketing will be staying in Travelodge, Central Aldgate East, also in double rooms. Question 03: Will any wives, children and or partners will be travelling with them? In response to Question 03, there will be no wives, children or partners travelling with any DfE political members or public servants.

Your right to request a review
If you are unhappy with this response to your Freedom of Information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post to the Freedom of Information Coordinator, IGP Freedom of Information Team, 1st Floor St George’s Court, Upper Church Street, Douglas, Isle of Man, IM1 1EX. An electronic version and paper version of our complaint form can be found by going to our website www.gov.im/about-the-government/freedom-of-information/how-to-make-a- freedom-of-information-request/ . Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.
If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on:

1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act; or
2. Whether we are justified in refusing to give you the information requested.
   In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision.
   Further information about Freedom of Information requests can be found on the Information Commissioner’s website at: www.inforights.im/information-centre/freedom- of-information. Should you have any queries concerning this letter, please do not hesitate to contact us. Yours Sincerely

Freedom of Information Coordinator IGP Freedom of Information Team
Department for Enterprise