Verification of Occupancy- Ballafesson 'Glamping'

Summary

The requester asked for Manx Utilities' standard occupancy verification procedures and specific documentation regarding the Reayrt Vradda glamping site following a liquidation. The authority disclosed its general application requirements but withheld specific details about the site's internal handling and documentation, citing partial exemptions.

Key Facts

• Manx Utilities requires account holders to apply via an online form or paper application.
• Applicants must provide personal details, date of birth, address, supply takeover date, and meter readings if not smart.
• The account holder is defined as the person or company responsible for payment.
• Specific documentation received for the Reayrt Vradda site was not fully disclosed.
• Internal correspondence and decision notes regarding the site's occupancy verification were withheld.

Data Disclosed

• 2025-11-25
• 2025-12-18
• 5109891
• 6
• 1

Exemptions Cited

• Part exempt

Original Request

This request concerns Manx Utilities' standard process for verifying the occupancy status of a new customer, and how this process was applied to the electricity supply at the Reayrt Vradda / Reayrt Glamping site after the former operator entered liquidation. I am not seeking any personal data. ⸻ 1. Requirements for Verifying Occupancy Please provide: 1.1 A copy of MU's standard requirements or criteria for confirming that a person is the occupier of a property for the purposes of opening or transferring an electricity account. 1.2 A description of the types of documentation MU normally relies upon to confirm that: * a customer has moved into a property; and * they are entitled to request supply in their own name. (This may include tenancy agreements, handover evidence, confirmations from owners or agents, etc.) ⸻ 2. Application Documentation Received for the Reayrt Vradda Site Regarding any private individual(s) now associated with supply at the Reayrt Vradda site, please confirm: 2.1 Whether MU received an Application for Supply Form, online application, or any other documentation indicating a change of occupier. 2.2 The categories of documentation MU received as evidence of occupancy or entitlement to take over supply (with any personal details redacted). 2.3 Whether MU verified that the individual(s) met MU's requirements for being treated as the 'occupier.' ⸻ 3. Internal Handling and Clarification Notes Please provide copies of any internal correspondence, notes, CRM entries, or emails which relate to: 3.1 Staff seeking clarification on who should be recognised as the occupier or responsible party for supply at the site after the operator entered liquidation. 3.2 Internal guidance, support, or decision notes provided to staff about how to handle the account or confirm occupancy in this specific case. (This request is limited to the issue of occupancy, entitlement, and account responsibility.) ⸻ 4. Security Deposit and New Customer Requirements Please confirm: 4.1 Whether a security deposit was requested in connection with any private individual(s) associated with the site. 4.2 Whether the applicant(s) were recorded as new customers, change of occupier, or under any other category.

Data Tables (1)

Data Tables (reformatted)

Full Response Text

18 December 2025 Manx Utilities PO Box 177, Douglas Isle of Man, IM99 1PS

e: enquiries@manxutilities.im t: 01624 687687 www.manxutilities.im

Our ref: 5109891

Dear ###

We write further to your request, received 25 November 2025, which states: "This request concerns Manx Utilities' standard process for verifying the occupancy status of a new customer, and how this process was applied to the electricity supply at the Reayrt Vradda / Reayrt Glamping site after the former operator entered liquidation. I am not seeking any personal data. 1. Requirements for Verifying Occupancy Please provide: 1.1 A copy of MU's standard requirements or criteria for confirming that a person is the occupier of a property for the purposes of opening or transferring an electricity account. 1.2 A description of the types of documentation MU normally relies upon to confirm that: * a customer has moved into a property; and * they are entitled to request supply in their own name. (This may include tenancy agreements, handover evidence, confirmations from owners or agents, etc.) 2. Application Documentation Received for the Reayrt Vradda Site Regarding any private individual(s) now associated with supply at the Reayrt Vradda site, please confirm: 2.1 Whether MU received an Application for Supply Form, online application, or any other documentation indicating a change of occupier. 2.2

The categories of documentation MU received as evidence of occupancy or entitlement to take over supply (with any personal details redacted). 2.3 Whether MU verified that the individual(s) met MU's requirements for being treated as the 'occupier.' 3. Internal Handling and Clarification Notes Please provide copies of any internal correspondence, notes, CRM entries, or emails which relate to: 3.1 Staff seeking clarification on who should be recognised as the occupier or responsible party for supply at the site after the operator entered liquidation. 3.2 Internal guidance, support, or decision notes provided to staff about how to handle the account or confirm occupancy in this specific case. (This request is limited to the issue of occupancy, entitlement, and account responsibility.) 4. Security Deposit and New Customer Requirements Please confirm: 4.1 Whether a security deposit was requested in connection with any private individual(s) associated with the site. 4.2 Whether the applicant(s) were recorded as new customers, change of occupier, or under any other category."

Our response to your request is as follows: I have detailed below the information. 1.1 Manx Utilities requires account holders to apply for electricity via its website using the online form or by a paper application form. Account holders will need to confirm their personal details, name, date of birth, address, date in which they are taking over supply, and a meter reading if the meter is not a smart meter. Together with their personal or company details any preferences with regards to how and where the bills are to be sent, and the method of payment. The account holder is the person or company who is responsible for the payment of the electricity at the property, which could be the owner or the tenant, or a third party.

There are no validation checks regarding residence or property ownership required from a customer who is registering with Manx Utilities. 1.2 Manx Utilities requires a completed and signed application form. Generally, for a tenanted property, a management company provides Manx Utilities with further information which supports the changeover date together with meter readings, at the point of processing the account change.

If there are any potential risks relating to nonpayment based on a payment history check, then Manx utilities may request further documentation regarding the tenancy agreement and a security deposit. 2.1 Manx Utilities received a paper application for the continuation of supply at Reayrt Vradda on 11th November 2025. 2.2 None have been requested or provided at this time. 2.3 There is no requirement for verification of owner or occupier, other than the application form. 3.1 11/11/2025 – Tenants at camping site to sign for supply. Due to be Disconnect 14/11 21/11/2025- New customer in from 14/11/2025. Previous customer out 05/06/2025, Staff arranging reading for 14/11 and bill owner tenant for Interim bit. 24/11/2025- End of Tenancy reading maximum demand supply 5 24/11/25 26/11/2025- Moved owner tenant in for interim from 05/06/2025 – 14/11/2025 east reading Redactedunits per day back from above reading. 3.2 Manx Utilities doesn’t require establishment of the occupant to make payments on the account.

When Manx Utilities receives official notification from a liquidator acting on behalf of a company, it would first register as a creditor. Manx Utilities priority is to establish the requirements for supply of electricity, water and removal of wastewater from the property, which can be either the continuation or disconnection, depending on the merits of the case.

Continuation of supply of electricity, water and wastewater removal can be agreed, providing sufficient detail from the liquidator is formally received, which supports Manx Utilities ability to recover future costs. Generally, the liability transfers to the liquidator from an agreed date so that a connection can be maintained. It may be suitable to disconnect the supply of electricity, water and wastewater removal in some cases.

If no active account exists for a property and the utilities are being used, generic letters will be sent and addressed to “owner/tenant”. This is to prompt for activating a payment account and if required warning of potential to disconnect should there be continued failure of payment.

Disconnections of supply for all properties are considered by one Director and the Chief Executive. While Manx Utilities aim is to provide information whenever possible, under section 20 of the Act, we are not required to provide information in response to a request if it is already reasonably accessible to you, whether free of charge or on payment of a fee. Some of the information that you have requested is available from Manx Utilities website using the following link: https://www.manxutilities.im/media/pjflvw3l/customer-protection-electricity- disconnection-2023.pdf Or www.manxutilities.im > Customers > Your electricity bill explained > I am struggling to pay my accounts, can you help? > a link can be found at the bottom of the section.

*Where it states ‘Electricity’, this relates to electricity, water, and wastewater utilities.

Help navigating the website can be found by contacting the customer billing team on 01624 687687. 4.1 Security Deposits are required when a new customer registers as the bill payer with Manx Utilities. This is required on the basis that no record of payment history for the individual or the business is held. If an existing or returning customer is registering for supply at an address then Manx Utilities would assess the account history, if payments have been made in a timely manner a security deposit may not be required. s25(b)(iii) While our aim is to provide information whenever possible, in this instance Manx Utilities can neither confirm nor deny that it holds some of the information requested. This is because you have requested third party personal data of which you are not the data subject, which, if it was held and was requested by the data subject, would not be disclosed to them under their right to access personal data because of an applicable exemption from, or restriction to, that right disclosure under one or both of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018 or the GDPR and LED the Implementing Regulations 2018. 4.2 While our aim is to provide information whenever possible, in this instance we are unable to provide any of the information 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: • Manx Utilities is satisfied that the information amounts to personal data of which you are not the data subject; and • Manx Utilities 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 Manx Utilities 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 5109891 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 Manx Utilities Authority Data Protection Officer