Poles

Summary

A request was made for communications regarding pole installations for the 20mph rollout, resulting in the disclosure of internal emails and a stop work instruction, though some personal data was withheld under exemption.

Key Facts

• Site works for the Douglas and Onchan 20mph Residential Zone were instructed to remain on hold from 27 July 2025 to 31 October 2025.
• Hooped poles are being retained where existing and proposed speed limits match but removed elsewhere for consistency.
• A complaint was raised by a House of Keys Member regarding a traffic post incorrectly placed on a pavement in Onchan that was subsequently tarmacked over.
• The Department of Infrastructure withheld information containing personal data under Section 25(2)(b)(i) of the Act.
• The final extents of the 20mph scheme were noted as not yet confirmed and likely to change.

Data Disclosed

• 20mph
• 27 July 2025
• 31 October 2025
• 1st November 2025
• 29 July 2025
• 28 August 2025
• 03 July 2025
• 18 August 2025
• 15 October 2025
• 19 pages
• 2 documents
• Section 25
• Section 30
• Section 35
• CI-10
• Document Log No. 100

Exemptions Cited

• Section 25(2)(b)(i) of the Act (absolutely exempt personal information)
• Data Protection (Application of GDPR) Order 2018 Article 5

Original Request

I seek the publication of all internal and external communications since July 1 relating to the installation of and issues raised with any poles installed for the proposed 20mph rollout.

Data Tables (5)

Full Response Text

Isle of Man Government Sea Terminal Building Douglas Isle of Man IM1 2RF CCJ Group Limited Unit 5 Carrs Lane Braddan Isle of Man IM4 2HU Please ask for: Keith Podmore Phone 01624

Email

Cross Ref: Stop Work Instruction 13th June 2025 Date Tue, 29-Jly-2025 Dear Sir/Madam, Document Log No. 100 Douglas and Onchan 20mph Residential Zone Client Instruction: CI-10 Continuation of Stopped Work I instruct the following: Site works are to remain on hold for the period 27 July 2025 to 31 October 2025. This instruction is based on the following: An agreement between the Client and the Contractor, reached at a meeting held on the 29 July 2025, stating the Contractor would not recommence work on site until the 1st November 2025.

Yours faithfully, Keith Podmore on behalf of the Client Tue, 29-Jly-2025 1 of 1 Section 25 Section 25 Section 30 Section 35 Section 35 1 From: Sent: 28 August 2025 13:53 To: Hardinge, Alan Cc: Almond, Kevin Subject: RE: Home Zones - Hooped Poles Hello Alan, The hooped poles are being retained in situ where the exisƟng and proposed speed limits match – as there is already a post and signage in place there is no point duplicaƟng work.
However the home zone plates are being removed for consistency across the 20mph zones. We do not wish to differenƟate between 20mph zones.
Where exisƟng and proposed don’t match, they are being removed. This will be following the consultaƟon responses, review of feedback and modificaƟon of the scheme.
The retained hooped posts will remain in place unƟl they are due for replacement, when they will be replaced by regular posts, for consistency with other speed limit zones.
To summarise, hooped poles that need replacing, should be, and with regular posts, provided they are not due to be removed.
If you would like to discuss specifics I’d be happy to meet, with the caveat that the final extents of the scheme is not confirmed yet and likely to change.
Thanks and regards,

From: Hardinge, Alan <

Sent: 28 August 2025 13:28 To: <

Cc: Almond, Kevin <

Subject: Home Zones - Hooped Poles Hi , I hope you are well. Can you advise what was decided with the above as part of the 20mph roll out please? I know at one meeting it was discussed about removing them.
There are a number damaged and need replacing but I don’t want to spend unnecessary budget replacing them if the intention is to remove them long term?
Regards Alan Hardinge Head of Maintenance Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 From: <

Sent: 03 July 2025 11:32 To: Butt, Richard <

Subject: RE: Highways survey Caution: This email is from an external sender. Please take care before opening any attachments or following any links.  He also said seeing sign poles going up while the consultation is on – loses their trust in government. Thanks, From: Butt, Richard <

Sent: 03 July 2025 09:21 To: <

Subject: Highways survey Good morning, ,

Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 Section 35 Section 35 Section 35 Section 35 Section 35 Section 35 Section 35 Good afternoon Emily,  Last month, I raised concerns about a 20mph traffic post placed in the middle of a pavement in Onchan. The DOI Minister publicly confirmed that the post was positioned incorrectly and assured me that it would be removed, which was welcome news - particularly for those with disabilities or parents navigating the area with prams etc.  Instead of the post being removed as promised, It would appear that it has been tarmacked over. Can you give me an urgent update on the situation, please? Kind regards Rob Callister CMgr, FCMI, FICA, Dip.(ITM), MHK House of Keys Member for Onchan Legislative Buildings Finch Road Douglas IM1 3PW Office: 01624 Mobile: 07624 Government e-mail: Personal e-mail: Website: Section 25 Section 25 Section 25 Section 25 Section 25

Department of Infrastructure Sea Terminal Building, Douglas, Isle of Man, IM1 2RF

Contact: FOI Response Team Telephone: (01624) 686785 Email: dpo-doi@gov.im

Our ref: 4880833 15 October 2025

Dear ###

We write further to your request, received 18 August 2025, which states:

"I seek the publication of all internal and external communications since July 1 relating to the installation of and issues raised with any poles installed for the proposed 20mph rollout."

Our response to your request is as follows: I have enclosed copies of the information.

While 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(2)(b)(i) of the Act (absolutely exempt personal information).

The reasons why the exemption applies are that:
• The Department of Infrastructure is satisfied that the information amounts to personal data of which you are not the data subject; and • The Department of Infrastructure 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 of Infrastructure 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.

Furthermore, some information is exempt from disclosure under section 30(2)(b) of the Act as disclosure would be likely to prejudice the commercial interests of person, including the Department of Infrastructure.

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

Revealing contract details can enhance trust in the fairness and competitiveness of government procurement processes. - Enables taxpayers and stakeholders to assess whether value for money has been achieved and whether decisions align with public interest Factors in favour of withholding

• Disclosure may reveal pricing strategies or operational details that could harm the competitive position of contractors or deter future bids.
• Contracts may include clauses that guarantee confidentiality, and breaching these could undermine trust and future cooperation.
• Partial or out-of-context information may be misused or misinterpreted, especially in politically sensitive or competitive environments.

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

Finally, information is exempt under section 35(b)(i) & (ii) of the Act, as disclosure would be likely to inhibit the free and frank provision of advice or the free and frank exchange of views for the purposes of deliberation.

As section 35 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

Disclosure would demonstrate how decisions were made and how public officials or Ministers conducted departmental business. - It would increase understanding of government processes and the rationale behind departmental or ministerial actions. - Openness can promote public trust in the integrity of the Department's operations and governance.

Factors in favour of withholding

Releasing internal discussions could inhibit officials and Ministers from providing honest, robust, and candid advice in future, weakening policy development. - Premature or selective disclosure could lead to confusion, misinterpretation, or unnecessary public pressure before decisions are finalised. - The public interest in preserving a 'safe space' for confidential debate outweighs the benefit of disclosure at this stage. - Disclosure may damage trust between officials, Ministers, or third parties, affecting future cooperation and openness.

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

Please quote the reference number 4880833 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.