Digital IOM CEO's salary

Summary

A requester sought the CEO's salary maxima, organizational structure, and staff details for Digital IOM, but the Department for Enterprise refused to disclose salary information citing commercial interests while providing an organizational chart.

Key Facts

• The request was made on 20 January 2026 regarding Digital IOM CEO Lyle Wraxall.
• The Department for Enterprise provided an organizational chart listing staff names and roles.
• Salary maxima for the CEO and senior staff were withheld from disclosure.
• The authority claimed salary details are negotiated under individual employment contracts.
• The internal review outcome was 'Not upheld' on 20 March 2026.

Data Disclosed

• 20 January 2026
• 16 February 2026
• 21 February 2026
• 20 March 2026
• 5241757
• 13 pages
• 3 documents
• Section 30(2)(b)
• Freedom of Information Act 2015

Exemptions Cited

• Section 30(2)(b) of the Freedom of Information Act 2015 (prejudice to commercial interests)

Original Request

It was reported in the IOM Examiner on the 20th January 2026 that Lyle Wraxall is the CEO of Digital IOM. The information that I require is - 1. What is Mr Wraxall's salary maxima?; and 2 A "family tree" showing the organisational structure of Digital IOM; and 3. The names and salary maximas of all other senior support staff employed within Digital IOM; and 4. The number of and public service grades of all other staff employed within Digital IOM.

Data Tables (6)

Full Response Text

TEAM CHART ABBY KIMBER Director of Operations Head of Strategic Partnerships Secretariat NATHAN LUNT ANDREW HONOUR CARRIE ALLEN-SNELL Marketing Manager (Maternity Cover) BEN WILSON-WHITE NICK PRESKEY LYLE WRAXALL, CEO ARIANE MONDS Marketing Executive ALEX TRUMAN Infrastructure Manager RICHARD OLIPHANT Director of Telecommunications BETHAN DAVIES Strategic Partnership Managers CHRIS REILLY ADAM HUDGEON Operations & Delivery Manager TAMIKA DU PLESSIS Marketing Executive (Temporary Contract) CHARLOTTE KINNIN Marketing Executive (Temporary Contract) AGA STRANDSKOV Head of Data Strategy KASIA HEGGS Project manager

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: 5241757 20 March 2026

Dear ###

Re: Internal Review – 5241757

I write to you in response to your request for a review of the information supplied to you on the 16th February 2026, in response to the above stated Freedom of Information request.

Summary of Process:

1. Request received:
   20th January 2026
2. Response sent:
   16th February 2026
3. Review requested:
   21st February 2026

Review of Response:

In your communication to the Department for Enterprise dated 20th January 2026, you requested the following information:

Information requested:

‘Digital IOM CEO's salary. It was reported in the IOM Examiner on the 20th January 2026 that Lyle Wraxall is the CEO of Digital IOM.

The information that I require is -

1. What is Mr Wraxall's salary maxima?; and

2 A "family tree" showing the organisational structure of Digital IOM; and

1. The names and salary maximas of all other senior support staff employed within Digital IOM; and

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4. The number of and public service grades of all other staff employed within Digital IOM.’

Reasons for requesting a review:

“I’m requesting an internal review of the Public Authority’s (“PA”) Response to my FOI Request, because it hasn’t provided me with all of the information that I requested.

In particular, the PA hasn’t provided me with items 1, 3 and 4 of the items listed in the second paragraph of the PA’s Response.

In respect of item 1, I asked “What is Mr Lyle Wraxall’s salary maxima? The PA has stated that “The salary for the Chief Executive post, by which I assume it is referring to Mr Lyle Wraxall, in Digital Isle of Man, is negotiated and set under an individual employment contract which is negotiated at the end of each “term” (whatever the word “term” means”) or should the post become vacant.

The PA then states that remuneration details have been “assessed”, but hasn’t stated who did the assessing, as being exempted under section 30(2)b, by which I assume the PA means section 30(2)(b) of Part 4 of the Freedom of Information Act 2015 (“FOIA”), which section doesn’t exempt anything from disclosure.

Section 11 of the FOIA provides –

Grant of requests for information
(1) A public authority must give the applicant the information requested in the applicant’s request for information and must do so in accordance with this Act. (2) However, a public authority may refuse to give the applicant the information requested if — (a) the information is absolutely exempt information or qualified exempt information; And, defines “qualified exempt information” as being information to which both of the following apply —
(a) the information is covered by a provision of Part 4; and
(b) the public interest in maintaining the exemption outweighs the public interest in disclosing the information. Section 30(2)(b) of Part 4 provides –

Information is qualified exempt information if —

its disclosure would, or would be likely to, prejudice the commercial interests of a person (including the public authority holding it).

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The Code of Practice to the FOIA which underpins the FOIA, has to be read with it and has to be followed, provides in pages 10, 11 and 12 –

3.1. (a) The public interest is not defined within the Act but must be something that is of serious concern and benefit to the public at large and not merely something of individual interest.

(b) Where an Authority decides that a qualified exemption has been engaged it must undertake a balancing exercise to consider the public interest in disclosing the information and the public interest in maintaining the exemption.

(c) Where the public interest in maintaining the exemption outweighs the public interest in disclosing the information, then the information can be withheld. If the public interest in disclosing the information is equal to or greater than the public interest in maintaining the exemption, then the information must be disclosed.

“Once an Authority believes that a qualified exemption is engaged it should:

(i) Identify the arguments in favour of maintaining the exemption against the public interest in disclosure of the information requested;
(ii) Attach a weighting to those identified arguments; and
(iii) Balance them against one another.
The Code then devotes two and a half pages or so to procedures which must be followed including in paragraph 3(2) “Identifying arguments in favour of disclosure” –

(a) Factors in favour of disclosure can be generalised across the exemptions and should be construed broadly. (b) What is in the public interest is a flexible concept, dependent on the facts of each case, for example: (i) Promoting public understanding and providing a “full picture”; (ii) Promoting transparency and accountability; (iii) Safeguarding the democratic process;
(iv) Securing good decision making by public bodies, ensuring standards of integrity are upheld and that there is justice and fair treatment for all; (v)Securing the best use of public resources; (vi) Ensuring fair commercial competition in a mixed economy; and (vii) Shedding light on a suspicion of wrongdoing on the part of an Authority.”

The public authority has stated only in respect of all of these considerations under the heading of “Factors in favour of disclosing” –

Disclosure would promote increased transparency and provide a better understanding of the cost of providing a particular public service . And, that’s it. 4 | P a g e

The public authority hasn’t, therefore, followed all of the procedures provided for in the Code, which renders it as being in breach of the FOIA.

In respect of item 3 of my request the PA has named two persons – Richard Oliphant and Nathan Lunt and alongside their names has inserted OS7 NTNSP*PSC CS which means nothing to me and doesn’t provide me with the salary maximas of the two staff that I requested.

In respect of Abby Kimber and Aga Strandskov the “family tree” provided by the PA appears to show that these two employees are of equal standing to Richard Oliphant and Nathan Lunt, in respect of whom the public authority hasn’t engaged a section 30(2)(b) exemption. There can be no justification, therefore, in engaging such an exemption for Abby Kimber and Aga Strandskov. And, even if there was such an exemption, the public interest test considerations would have to be explained individually, without which such exemptions could not apply. It would not be sufficient to simply apply to each of these staff the test which the PA used for Lyle Wraxall.

In respect of item 4 of my request the public authority has listed the numbers of staff which what it describes as HEO NTNSPP and EO NTNSP PSC CS, which means nothing to me. I asked for the salary maximas for the staff concerned not some letters.

The PA concludes by saying that there are a further 3 posts which are employed under individual contracts which are not linked to a public service grade, but it haven’t provided me with the salary maximas for these three persons. Their individual contracts must presumably have an amount of remuneration included in them, which would constitute their salary maximas.

I note that although the PA is keen to restrict disclosure of remuneration information respect of the staff which it employs at taxpayers’ expense, it has no difficulty lauding these people for the world at large to see in full colour, with their job titles, on Digital IOM’s “Meet the Team” website page Meet the Digital Team | Digital Isle of Man

‘Further to my e-mail to you immediately below, I meant to include in my Review Request a reference to a Decision of the Information Commissioner concerning job titles/names/salary maximas, which has relevance to this FOI Request. The IC’s Decision can be found here decision-notice-financial-services-authority- redacted.pdf

The Decision concerned an FOI Request of mine. I can’t recall what stage the Decision is at, but I’ll check with the IC and get back to you.’

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Statutory Considerations:

1. Did the public authority respond to your request within the required timescale?

Yes.

1. Did the public authority provide the information requested?

Partially, there was intentional limited disclosure as relevant exemptions were correctly applied.

1. Did the public authority conduct a reasonable search for the information?

Yes.

1. If the public authority did not provide the information because of the application of a practical reason, was the refusal clear?

Not applicable.

1. If the public authority applied an exemption, was it correct and was it explained?

Yes.

1. Did the public authority offer appropriate advice and assistance?

Yes.

1. Did the public authority advise you of the internal review process and your right of appeal to the Information Commissioner?

Yes.

A response is provided below addressing each of the points raised within your request for a review.

Issue 1:
‘Items 1,3 and 4 have not been provided.’

Response: The information not withheld using section 30(2)(b) has been provided.

Issue 2:
‘In respect of item 1, I asked “What is Mr Lyle Wraxall’s salary maxima? The PA has stated that “The salary for the Chief Executive post, by which I assume it is referring to Mr Lyle Wraxall, in Digital Isle of Man, is negotiated and set under an individual employment contract which is negotiated at the end of 6 | P a g e
each “term” (whatever the word “term” means”) or should the post become vacant.’

Response: The Chief Executive post does refer to Mr Lyle Wraxall in Digital IOM. The Individual Employment Contract lasts for a period of time which is referred to as a ‘term’.

Issue 3:
‘The PA then states that remuneration details have been “assessed”, but hasn’t stated who did the assessing, as being exempted under section 30(2)b, by which I assume the PA means section 30(2)(b) of Part 4 of the Freedom of Information Act 2015 (“FOIA”), which section doesn’t exempt anything from disclosure.’

Response: The Department has assessed that section 30(2)(b) of the Freedom of Information Act 2015 (“FOIA”) has been applied to withhold the release of some information. This is sometimes referred to as an exemption or as exempted information. Section 30 exits under part 4 of the Act which relates to “Qualified Exempt Information”.

Issue 4:
‘The public authority has stated only in respect of all of these considerations under the heading of “Factors in favour of disclosing” –Disclosure would promote increased transparency and provide a better understanding of the cost of providing a particular public service. And, that’s it. The public authority hasn’t, therefore, followed all of the procedures provided for in the Code, which renders it as being in breach of the FOIA.’

Response: A proportionate public interest test has been carried out which is brief and high level which considered transparency and accountability. The code of practice does not require a public authority to consider all points in relation to the public interest test and only those that are relevant to the information concerned.

Issue 5: ‘In respect of item 3 of my request the PA has named two persons – Richard Oliphant and Nathan Lunt and alongside their names has inserted OS7 NTNSP*PSC CS which means nothing to me and doesn’t provide me with the salary maximas of the two staff that I requested.’

Response: Richard Oliphant has a salary maxima of £92,980 and Nathan Lunt has a salary maxima of £68,455.

Issue 6:
‘In respect of Abby Kimber and Aga Strandskov the “family tree” provided by the PA appears to show that these two employees are of equal standing to Richard Oliphant and Nathan Lunt, in respect of whom the public authority hasn’t engaged a section 7 | P a g e
30(2)(b) exemption. There can be no justification, therefore, in engaging such an exemption for Abby Kimber and Aga Strandskov. And, even if there was such an exemption, the public interest test considerations would have to be explained individually, without which such exemptions could not apply. It would not be sufficient to simply apply to each of these staff the test which the PA used for Lyle Wraxall.’

Response: There is a distinct difference between the employment contracts for posts that fall within the Public Service Commission terms and conditions and those employed under a separate negotiated contract. The terms of individually negotiated contracts are not published and constitute commercially confidential information which is why a Section 30(2)(b) exemption was applied. It is reasonable to apply the same assessment for all individually negotiated contracts as the assessment is based on the same principle, that certain elements of an individual employment contract are, by nature, commercially confidential and would, if released, be likely to cause harm to the commercial interests of an individual or the Department.

Issue 7: ‘In respect of item 4 of my request the public authority has listed the numbers of staff which what it describes as HEO NTNSPP and EO NTNSP PSC CS, which means nothing to me. I asked for the salary maximas for the staff concerned not some letters.’

Response: HEO stands for Higher Executive Officer and EO stands for Executive Officer. These grades are published by the Office of Human Resources and you can search for the full description of each post within that site, using this link https://hr.gov.im/. You did not ask for the salary information for these posts as you stated:-

“4. The number of and public service grades of all other staff employed within Digital IOM.’

Issue 8: ‘The PA concludes by saying that there are a further 3 posts which are employed under individual contracts which are not linked to a public service grade, but it haven’t provided me with the salary maximas for these three persons. Their individual contr

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