Advice provided by OHR

Summary

The requester asked for all correspondence between the Office of Human Resources and Castletown Town Commissioners from May 2025 to October 2025. The Cabinet Office released some information but withheld personal data under an absolute exemption.

Key Facts

• The request was received on 6 October 2025 and responded to on 29 October 2025.
• The authority handling the request was the Cabinet Office.
• Some information was released, but part of the request was exempt.
• The exemption was applied because the withheld information constitutes personal data of individuals other than the requester.
• Disclosure of the personal data would contravene data protection principles under the GDPR as applied in the Isle of Man.

Data Disclosed

• 4978392
• 2025-10-06
• 2025-10-29
• 1st May 2025
• 29 October 2025
• 6 October 2025
• 2018
• 2015
• 2 pages
• 1 document

Exemptions Cited

• Section 25(2)(b)(i)/(ii) of the Freedom of Information Act 2015 (Absolutely exempt personal information)
• Article 5 of the General Data Protection Regulation (Data protection principles)
• Article 6 of the General Data Protection Regulation (Conditions for lawful processing)

Original Request

"Please Please provide copies of all correspondence (including but not limited to emails, letters, meeting notes, or briefing papers) exchanged between the Office of Human Resources and Castletown Town Commissioners, officers of Castletown Town Commissioners or persons acting on its behalf or any of its sitting board members from 1st May 2025 to the present date. For clarity, the scope of this request should include: * Correspondence sent by or on behalf of officers of the Office of Human Resources, including the executive director of HR. * Correspondence sent by Castletown Town Commissioners officers or their board members to the Office of Human Resources. * Any attachments, briefing notes, or other documents provided as part of that correspondence. * Internal cover notes that record or summarise such exchanges. I would be grateful if the information could be provided in electronic form.

Data Tables (1)

Full Response Text

Government Office Douglas Isle of Man IM1 3PN Telephone: (+44) 01624 686244
Website: www.gov.im/co

Our ref: 4978392 29 October 2025

Dear ###

We write further to your request, received 6 October 2025, which states:

Please Please provide copies of all correspondence (including but not limited to emails, letters, meeting notes, or briefing papers) exchanged between the Office of Human Resources and Castletown Town Commissioners, officers of Castletown Town Commissioners or persons acting on its behalf or any of its sitting board members from 1st May 2025 to the present date.

For clarity, the scope of this request should include:

• Correspondence sent by or on behalf of officers of the Office of Human Resources, including the executive director of HR.

• Correspondence sent by Castletown Town Commissioners officers or their board members to the Office of Human Resources.

• Any attachments, briefing notes, or other documents provided as part of that correspondence.

• Internal cover notes that record or summarise such exchanges.

I would be grateful if the information could be provided in electronic form."

I have enclosed copies of the information that is being released to you.

While our aim is to provide information whenever possible, in this instance the Cabinet Office are unable to provide some of the information that you have requested because it is absolutely exempt under section 25(2)(b)[(i)/(ii)] of the Act (absolutely exempt personal information). The reasons why that exemption applies are that:
• The Cabinet Office is satisfied that the information amounts to personal data of which you are not the data subject; and • The Cabinet Office 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 Cabinet

Office 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.
Please quote the reference number 4978392 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.

Yours sincerely