Digital Isle of Man at SiGMA Malta

Summary

A request for meeting details, expenses, and objectives regarding a Digital Isle of Man trip to Malta was partially fulfilled, with specific documents released but significant information withheld due to data protection and economic interest exemptions.

Key Facts

• The Department for Enterprise released a document titled 'Malta Trip Meetings' but redacted personal data and company names.
• Information regarding specific attendees and discussion content was withheld to protect the Isle of Man's economic interests.
• The authority cited Section 25(b)(i)&(ii) for personal data exemptions and Section 30(1)(a) for economic prejudice.
• The response included hotel booking confirmation details and directions for a Premier Inn near Gatwick Airport.
• The request was received on 2024-12-09 and the final outcome was issued on 2024-12-24.

Data Disclosed

• 2024-12-09
• 2024-12-24
• 26/07/2024
• 25GBP
• 24 pages
• 2 documents
• 4309885

Exemptions Cited

• Section 25(b)(i)&(ii) - Absolutely exempt personal information
• Section 30(1)(a) - Prejudice to economic interests

Original Request

1. A copy of all meeting held during the period of the recent Malta trip including all attendees, location and discussions. 2. Copy of the expenses receipts for the trip. 3. did they meet with the Philippines regulator (a follow up from the Manila trip). 4. What were the objectives and KPI's, were these met?

Data Tables (1)

Full Response Text

Exit M23 at J9 for Gatwick. Follow signs for Gatwick North Terminal, at North Terminal r/about enter at Arrivals Road (2nd exit), turn right onto Northway (Drop Off point), hotel is on the right. From South - follow M23 for Gatwick/London. Exit M23 at J9 for Gatwick. Follow signs for Gatwick North Terminal. At North Terminal roundabout enter at Arrivals Road (2nd exit). Turn right onto Northway (Drop Off point), hotel is on the right. From Airport and Train Station (on foot) - follow signs for the North Terminal (take the transit from the South Terminal) and head to Drop Off point. Exit Terminal, the hotel is opposite the Drop Off point. Overnight parking is available in the North Terminal short stay car park numbers 5 or 6 at a discounted rate of 25GBP. Live Chat 26/07/2024, 14:36 Confirmation https://www.premierinn.com/gb/en/business-booker/booking-business/confirmation?reservationId=BBP-be239112-859e-4a60-817e-ab1ef3a4fff1 2/2

Freedom of Information Co-ordinator 1st Floor, St Georges Court Upper Church Street, Douglas Isle of Man IM1 1EX

Telephone: (01624 686400) Website: https://www.iomdfenterprise.im/

Our ref: 4309885 24 December 2024

Dear ###

We write further to your request, received 9 December 2024, which states:

"1. A copy of all meeting held during the period of the recent Malta trip including all attendees, location and discussions. 2. Copy of the expenses receipts for the trip. 3. did they meet with the Philippines regulator (a follow up from the Manila trip). 4. What were the objectives and KPI's, were these met?"

Our response to your request is as follows:

“1. A copy of all meeting held during the period of the recent Malta trip including all attendees, location and discussions.”

Please see the attached document titled “Malta Trip Meetings”. Please be aware that this document is subject to a Section 25(b)(i)&(ii) exemption and a Section 30 (1)(a) exemption:

Section 25(b)(i)&(ii)

Whilst our aim is to provide information whenever possible, in this instance we are unable to provide some of 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 for Enterprise is satisfied that the information amounts to personal data of which you are not the data subject; and • The Department for Enterprise is satisfied that disclosure of the information would contravene one of the data protection principles as set out at Article 5 of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018, namely that the Department for Enterprise can only disclose the information where it would be fair, lawful and meet one of the conditions for lawful processing in Article 6 and in this case, none of those conditions have been met.

Section 30(1)(a)

Whilst our aim is to provide information whenever possible, in this instance the information is exempt from disclosure under section 30 of the Act as disclosure would prejudice the, and the economic interests of the island.

Prejudice would occur if the names of companies and the content of discussions held during business development and strategic exploratory trips were disclosed. The disclosure of this information could directly undermine the Isle of Man's reputation as a secure jurisdiction for commercial engagements. This could damage confidence among current and prospective business partners, discouraging future collaboration and significantly affecting the Island's ability to attract investment and maintain economic competitiveness.
Furthermore, the businesses involved could face tangible harm, including competitive disadvantages and potential disruption to commercial negotiations, which could further weaken their ability to operate effectively within the Isle of Man's economy, or relocate operations to the Island. These combined impacts demonstrate that prejudice to the Isle of Man's economic interests would occur, not merely that it would be likely.

Disclosing the names of companies and the content of discussions held during business development and strategic exploratory trips would likely prejudice the Isle of Man's economic interests. Specifically:
• The release of such information could undermine confidence in the Isle of Man as a jurisdiction that upholds discretion in commercial dealings, a key competitive advantage in maintaining a stable economic framework.

• Releasing company names might discourage future companies from engaging in similar discussions with the Isle of Man Government, hindering efforts to promote and sustain a competitive digital economy As section 30 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.

Factors in favour of disclosure

Accountability for public spending:

• Disclosure would demonstrate how public funds are used for business development and strategic trips, ensuring transparency regarding the expenditure and its alignment with government objectives.
Building public trust and transparency:

• Releasing the information could enhance public confidence in the Isle of Man Government's operations, particularly in its approach to fostering economic development and engaging with businesses.

Promoting public understanding and informed debate:
• Making details of the meetings available could enable the general public to better understand the Government's strategies and priorities, fostering a constructive public discourse on economic policy.

Scrutiny of government actions:

Ensures the Government is acting in accordance with its stated policies and maintaining fairness in its dealings with the private sector.
Legitimacy of economic policy:

• Demonstrating the alignment of activities with the Isle of Man's broader economic strategy could reinforce the Government's credibility and reputation as a fair and ethical jurisdiction.

Encouraging business engagement:

• Transparency about government initiatives could attract businesses by showcasing opportunities for collaboration and investment in the Isle of Man.

Factors in favour of withholding

Harm to the Isle of Man's economic interests:

• Disclosure could undermine confidence in the Isle of Man as a jurisdiction that ensures discretion in commercial dealings, deterring businesses from engaging in future collaborations. The eGaming sector currently employs a significant number of highly skilled professionals, with a large volume of eGaming operators, and contributes significant sums to the Exchequer annually through income tax, gambling duty, licence fees, and local spending. This is further supported by a broader ecosystem, including significant contributions from the financial services sector.

The disclosure of sensitive information could result in not only the loss of future opportunities and also the erosion of the Isle of Man's existing eGaming base. Businesses may choose to relocate or regulate elsewhere, jeopardising the jobs, revenues, and economic benefits that the sector currently provides. An exposure in one sector, eroding confidence could give similar concerns across other sectors.

Damage to commercial interests:

• Releasing sensitive business information could harm the competitive position of the companies involved, exposing them to commercial disadvantage and risking financial loss.

Loss of investor confidence:

The Isle of Man's economy is sensitive to shifts in investor confidence. Disclosure could lead to uncertainty, affecting investment decisions and overall economic stability.

Impact on confidential relationships:

The release of information provided in confidence could damage relationships with businesses, regulators, and international stakeholders, reducing the likelihood of future cooperation.

Disruption of ongoing negotiations:

Publicising the content of discussions could prematurely expose plans or negotiations, hindering their successful conclusion and weakening the Government's ability to secure beneficial outcomes.

Commercial sensitivity:

The information constitutes commercially sensitive material, and its disclosure could reveal strategic plans or insights that competitors could exploit, weakening both the businesses involved and the Isle of Man's economic standing.

Precedent for future disclosures:

Releasing the information could set a precedent, creating concerns among potential partners about the confidentiality of their dealings with the Isle of Man Government.

Broader economic harm:

Damage to the Isle of Man's reputation as a trustworthy jurisdiction by not upholding what could be reasonable expected to be confidential information could have a long- term adverse impact on the Government's ability to attract businesses and investment and the Department as a main conduit to this goal.

In taking these factors into account the Department for Enterprise determined that the factors in favour of maintaining the exemption outweigh the factors in favour of disclosing the information.

“2. Copy of the expenses receipts for the trip”

Please see the attached document titled “Receipts”. Please be aware that this is also subject to Section 25, absolutely exempt personal information. Page 14 of this document is subject to two redactions, totalling £16. This is related to personal expenses, that were not claimed via The Departments expense procedure. The individual items have also been redacted but the totals have been included for transparency.

“3. did they meet with the Philippines regulator (a follow up from the Manila trip)”

We can confirm that Digital IOM did not meet with the Philippines regulator during this trip.

“4. What were the objectives and KPI's, were these met?”

OBJECTIVES AND KPI’S MET

• Pre-prospecting of over 50 exhibitors prior to the event - 56 ACHIEVED. • Attend at least 3 networking events - 5 ACHIEVED. • Establish at least 12 licensing opportunity - 12 ACHIEVED.

Please quote the reference number 4309885 in any future communications.

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.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. 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 2015; 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. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.

This response took five hours to complete.