Response 458574409

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Introduction

Are you responding on behalf of an organisation?

Organisation name
Isle of Man Chamber of Commerce

May we publish your response?

Please select one item
Yes, you can publish my response in full
Yes, you may publish my response anonymously
No, please do not publish my response

Child consent age

1. Do you agree with this decision?

Please select one item
Yes – the age should be in line with the UK approach of 13 years
No – the age should be in line with the EU GDPR article of 16 years

Certification

2. Should the Isle of Man recognise accreditation bodies outside the Island?

Please select one item
Yes – open to non-Island bodies
No – restrict to national, Island-based bodies

Binding corporate rules

4. Do you support this approach to binding corporate rules?

Please select one item
Yes – I support this approach
No – I do not support this approach

Expanded Information Commissioner powers

5. Do you agree that the powers afforded to the Information Commissioner are proportionate?

Please select one item
Yes – I agree, the expanded powers are proportionate
No – I disagree, I don't think the powers are proportionate

9. Do you support a tiered fee structure based on the size of an organisation and the amount of records processed?

Please select one item
Yes – different amounts should be charged
No – all businesses should pay the same amount

10. Do you have any additional comments about the role of the Information Commissioner?

Type your response.
As noted above, we are concerned about the lack of resources given to the Information Commissioner’s Office.

Criminal offences

12. Do you agree with the decision to retain the sanctions for Criminal offences from the Data Protection Act?

Please select one item
Yes – retain the sanctions
Yes – but add more sanctions
No – remove the sanctions
If you think there should be more sanctions, for what level of offence/breach?
Yes, however such offences have been set out in regulations whilst the draft Bill does not provide for regulations creating offences, meaning that any attempted prosecution could be challenged on grounds of vires. Amendment to the Bill is required.

13. Should there be any transitional provisions to help make sure organisations are ready for compliance with the new legislative provisions in GDPR?

What transitional provisions should the Isle of Man Government consider?
See our comments at paragraph 3.28 above. Whilst this is a nice sentiment, does it really have any effect? Guidance is required as soon as possible.

Exemptions

14. Are these exemptions sufficient and are any other additional exemptions required?

Please select one item
Yes – exemptions are sufficient
No – we need additional exemptions