Data proposition strategic review - Isle of Man Government€¦ · · 2018-02-21 Data proposition strategic review Strictly private and confidential 20 January 2017 Isle of Man

www.pwc.com/im

Data proposition strategic review

Strictly private and confidential

20 January 2017

Isle of Man

PwC

20 January 2017Strictly private and confidential

Ian ClaguePartnerT: +44 (0) 1624 [email protected]

Steve BillinghurstDirectorT: +44 (0) 1624 [email protected]

Steven CravenSenior ManagerT: +44 (0) 1624 [email protected]

PricewaterhouseCoopers LLC3rd Floor, Sixty Circular Road, Douglas, Isle of Man, IM1 1SAT: +44 (0)1624 689689

Department of Economic DevelopmentSt Georges CourtUpper Church StDouglasIsle of Man

20 January 2017

Dear Sir/Madam,

Report in connection with the Isle of Man’s data proposition strategic review

We report on the strategic review in accordance with our agreement dated 12 December 2016.

Save as described in the contract or as expressly agreed by us in writing, we accept no liability (including for negligence) to anyone else or for any other purpose in connection with this report, and it may not be provided to anyone else.

Yours faithfully

PricewaterhouseCoopers LLC

PricewaterhouseCoopers LLC is a member of PricewaterhouseCoopers International Limited, a company limited by guarantee

registered in England and Wales. The principal place of business of PricewaterhouseCoopers LLC is at the given address.

Incorporation number 00934L. Members: I G Clague, K M Cowley, P C Craig, A D Dunn, N M Halsall, N J Shepstone,

M Simpson.

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Government Technology ServicesCabinet Office1st Floor, St Andrew’s HouseDouglasIsle of Man

GlossaryAppendicesDetailed reportExecutive summaryContents

mailto:[email protected]



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Transmittal letter 2

Our scope 4

Executive summary 6

Detailed report 12

1 Background to the report 13

2 Infrastructure 15

3 Financial infrastructure 25

4 Data capabilities 30

5 Government support 37

6 Legislation and regulation 44

7 Strategic recommendations 56

8 Other recommendations 62

Appendices 67

0.1 Engagement letter 68

0.2 Sources of information 84

0.3 Scoring methodology 86

0.4 Glossary 87

Contents

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Note to reader – Navigation

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Our scope

Scope Process

Scope of work You have asked us to perform a strategic review of the Isle of Man’s proposition in relation to data and cyber security. This included the following topic areas:

• Infrastructure: financial, data and utilities;• Internet, broadband and digital penetration;• Tax, legislation and government grants; and• Stability and international reputation.

We undertook a number of interviews with various stakeholders to understand their views on some of the matters above.

We have also undertaken comparison to other jurisdictions, primarily focusing on the UK, Jersey, Guernsey, Ireland and Luxembourg although some consideration of other jurisdictions was also performed.

Finally, we have included a number of recommendations which, in our view, should be considered in order to take the Isle of Man’s data proposition forward.

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Executive summary

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Executive summary

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Isle of Man summary

To present the overall view of the Isle of Man in a concise way, we have developed a scoring model to assign a value to each of the pillars on which a data proposition should be built. These are:

Our view is that there is no single USP that usurps all others in any jurisdiction. Every country competing in the data marketplace has areas of strength and areas of weakness. The Isle of Man has consistency across all of these key pillars - rather than one “silver bullet” part of its proposition.

The Isle of Man has good telecoms, good datacentres, good power, space to be built upon and a stated appetite from the Government to grow and support the working population which combine to make a compelling offering.

• Infrastructure• Financial infrastructure• Data capabilities• Government support• Legislation and regulation

Source: PwC analysis, Isle of Man Government (photo)


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Executive summary (cont.)

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Significant work has already been undertaken to make the Isle of Man “digital” and a place well suited to data businesses. This can be seen in the detailed overview on this page.

However we have identified a number of areas in which we believe recommendations are required to improve the Isle of Man’s data proposition, to make sure the Island is able to take advantage of this opportunity. The methodology behind the “scores” is explained in appendix 0.3.

Source: PwC analysis


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Infrastructure

The Isle of Man has a very stable, well-established and resilient infrastructure in place which is already in active use by industries which share many characteristics with the data proposition. This includes huge network capacity, resilient telecoms and power, and a good “backbone” of datacentres already located here. Home broadband speeds are however below the European average.

A number of recommendations have been made to maintain this area of particular strength, and explore the areas where potential improvements could help to enhance the Island’s data proposition.

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Recommendations

• Continue to explore “Active Cyber Defence” concept with the UK and other international parties

• Develop an IPv6 adoption plan

• Explore “Ultra broadband” options other than FTTH

• Investigate “Smart City” concept

Recommendations

• Encourage greater collaboration and information / asset sharing

• Encourage the “Innovation Isle” concept again

• Explore company legislation specific to a “data company”

Financial infrastructure

The financial infrastructure is reasonably strong, although in the press in particular the Isle of Man is still trying to fight off its perception as a “tax haven”. The message to the international community is also not as clear and direct as some of our competitors in relation to the data proposition. The economy is more diverse than many of our competitors, although there is increasing weight in e-Business and ICT.

This diversity is supported by a strong professional services sector which is experienced in a wide variety of types of work and has an ability to adapt quickly. However, this means the Island does not have some of the niche specialists that our larger competitors might have.


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Data capabilities

The Island has effective supporting bodies in place which are equipped to enable the data proposition. This includes a very good working relationship between the Chamber of Commerce and the Isle of Man Government.

Because of the overlap in activity between data and the Island’s existing sectors of e-Business, ICT and financial services there is a strong existing skillset which can be used in this proposition. However, the Island is currently lacking an innovation hub or an informal collaborative working environment which many of the Island’s competitors already have in place.

Low levels of unemployment may however be a cause for concern to some new businesses if there is a perception that it will be difficult to employ staff at reasonable wage levels and there may be a skills gap.

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Government support

The Isle of Man has a very stable political environment and there is a close relationship between the Government and businesses on the Island. Furthermore, the Island is actively seeking economic growth and the expansion of the workforce. However, there is no clear strategic direction from the Government and no dedicated “digital tsar”, unlike some of the Island’s competitors.

The incentive schemes available are unique and compelling in their composition as they are able to offer loans, grants and equity which will help to attract new businesses, combined with the scale of the £50m EDS.

Recommendations

• Set a vision / strategy for the Island in relation to data

• Assign a “digital tsar” responsibility for the proposition

• Consider Government resources

• Develop a “priority sector” framework

• Define “guiding principles” for the data proposition activity

Recommendations

• Assign a “responsible body” for the Island’s data proposition

• Promote the Island’s benefits more widely / louder

• Explore the innovation hub concept further (including “hyperconnected” hubs and/or FTTB)

• Consider a centralised information “landing page” for the data proposition


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Legislation and regulation

The Isle of Man has a simple and effective regulatory structure and is able to pass new laws quickly as a consequence. Many of its laws and regulations follow UK common law practice, such as in data protection where GDPR adequacy is being sought and in the Island’s IP law.

However, there are some areas where the Isle of Man could seek to innovate and move away from the UK model to support its data proposition.

The telecoms interception regime is fair and straightforward, with a much more limited basis than in the UK. Some of the legislation, whilst recently updated, does not fully reflect the nature of business that a data proposition may encourage.

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Recommendations

• Undertake and publish a risk appetite review

• Create clear, data / digital ready legislation

• Draft framework legislation for new sectors / technologies to encourage early stage adoption on the Island


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Detailed report

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Detailed report

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Detailed report 12

1 Background to the report 13

2 Infrastructure 15

3 Financial infrastructure 25

4 Data capabilities 30

5 Government support 37

6 Legislation and regulation 44


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Background

The rise of data

Philip K. Dick’s futuristic novel “The Minority Report” published in 1956 portrays a future where crime can be predicted before it happens -and prevented. A major contributor toward this is technological advancements and a huge increase in the volume of available data.

Technology and cybersecurity progress over the past decade has been astonishingly swift and sweeping. Only 10 years ago, Amazon launched AWS to deliver IT to businesses. Today, in a recent PwC survey, the majority of organizations around the world (63% of respondents) say they run IT services in the cloud.

The digital business model was an enigma to many companies a decade ago. In 2007, most organisations simply did not understand advantages of a digital model, much less how to implement one. Some mistrusted the idea altogether: after all, the $350 billion merger of AOL and TimeWarner in 2000 did not generate the promised benefits.

Enough has been written about the exponential growth of data, the speed of recent technological advancement, and the opportunities and threats created as a result to fill entire libraries. The Isle of Man is not immune from these changes, which has prompted the Government to re-assess its position and offering. We believe this is a critical time as the quantity of available data and the potential value it holds is growing exponentially, but a strategy or approach needs to be developed.

Creating such huge volumes of data also comes with an enhanced responsibility to protect it, particularly for those entities, such as the Government, to whom it has been entrusted.

We see in the news every week more and more stories about data being stolen, exploited, manipulated and/or destroyed. Advancements in cyber defences have not kept pace with our use of data and technology, which is now ubiquitous.

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1 Background to the report GlossaryAppendicesDetailed reportExecutive summaryContents

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Background (cont.)

Businesses are starting to optimize for the digital era by implementing foundational elements—cloud computing, sophisticated data monitoring and analytics, and open-source technologies, to name but a few – and to integrate digitalisation with cybersecurity and privacy.

Verizon’s “State of the Market: Internet of Things 2016” report estimates that the installed base of IoT endpoints will grow from 9.7 billion in 2014 to more than 25.6 billion in 2019, hitting 30 billion in 2020 (c. 20% growth per year). The implication is there may be more than twice as many IoT devices talking to each other as there will be smartphones, tablets and PCs. What was still a futurist’s dream just a few years ago is now infiltrating every part of business.

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1 Background to the report

Advances in Robotics, Machine Learning and AI are also taking place rapidly and business and consumers are now starting to embrace these technologies at work and in the home.

But taking a step back – what factors link all of these growth points? Firstly – all of these advancements either rely on, or will generate via their usage, significant amounts of data. Secondly - will be the need to secure, protect, and maintain this data via cybersecurity. This report therefore focuses on these two areas for the Isle of Man.

Current economic and business commentators have described data as the “new oil” fuelling the digital economy, but it is likely to be far more significant than that. Data increasingly determines economic value and is reshaping our societies fundamentally: its about who collects, owns, and uses data. We are moving away from an era of financial capitalism to one of data capitalism.


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Infrastructure

Executive Summary

The Isle of Man has a very stable, well-established and resilient infrastructure in place which is already in active use by industries that share many characteristics with data. This includes huge network capacity, resilient telecoms and power, and a good backbone of datacentres already located here. Home broadband speeds are however below the European average.

• Enormous network capacity

• More than adequate power capacity

• Resilient power and communications infrastructure

• Low natural disaster risk

• Good datacentre provision with capacity

• Continue to explore “Active Cyber Defence” concept with the UK and other international parties

• Develop an IPv6 adoption plan

• Explore “Ultra broadband” options other than FTTH

• Investigate “Smart City” concept

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Key strengths

Recommendations

A number of recommendations have been made to maintain this area of particular strength, and explore the areas where potential improvements could help to enhance the Island’s data proposition.


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Infrastructure (cont.)

Why does it matter?

It is clear that in the battle to attract individuals and businesses to come to the Isle of Man (or to its competitors), the quality of infrastructure plays a part in this. In particular with a data proposition, whether that is to attract data-rich or data-intensive businesses here, or to attract the data itself in order for value to be added in the Isle of Man, the resilience and speed of the infrastructure is critical.

In order to understand the Isle of Man’s current position and how this compares against some of its competitors, we have undertaken research focusing on the relevant factors for data-focused businesses.

Components of infrastructure

From our research and discussions around PwC’s Global network, we identified the following infrastructure components as being important:

• Power capacity and resilience• Telecoms capacity and resilience• Datacentre provision

Some other elements of data and financial infrastructure are covered in later sections of this report.

Overview

The following is taken from the Isle of Man’s “Infrastructure” factsheet:

In its marketing literature, Jersey claims:

Other jurisdictions have words to the same effect. Everyone claims to have world-class infrastructure with “unparalleled” speed. But what is the truth of these claims? In November 2016, Jersey suffered a cut in all 3 of its internet cable links as a result of a ship’s anchor dragging across the seabed, leading temporarily to slow speeds and connection issues and with a rectification cost of c. £0.75m.

We undertook some research to understand the Isle of Man in context, highlight the areas the Isle of Man is strong, and explore the areas where its offering is either weak in comparison to its competitors, or does not support a data proposition.

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The Isle of Man has an excellent telecoms and power infrastructure which has benefited from hundreds of millions of pounds worth of public and private sector investment in recent years.

“

World-class, resilient, high-speed and high-bandwidth communication links with both the UK and France allow the Island to operate beyond its geography and fully integrate with the global market economy. Jersey is leading the world with the deployment of fibre to every home and business.

“


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The Isle of Man’s natural beauty is often stated in our marketing literature as one of, if not it’s most, compelling features. The physical location has both positive and negative factors – there are often complaints about the cost of getting on and off the island, but its physical isolation makes it one of the safest countries with one of the lowest crime rates in Europe. It is also harder to physically access, potentially making it a safer place to store sensitive commercial or personal data and has a very low natural disaster risk, particularly when compared with some of the competitor jurisdictions.

Power capacity and resilience

→ Power generation

Electricity generation is provided by the following installed capacity:

• an 84 MW combined cycle gas turbine power station;• a 60 MW interconnector subsea cable;• 86 MW of diesel generators; and• a 2 MW hydroelectric power plant.

The interconnector is an AC submarine power cable connecting the transmission system of the MUA to that of Great Britain. The interconnector carries power as well as a fibre optic communications cable. It was installed in September 2000 and was designed to allow power to be transferred both to and from the Isle of Man and the UK, depending on need. There is also an EfW plant in Douglas which has some power generation capacity, although this is not managed by MUA.

Power generation is therefore not reliant on one single source of fuel or one asset and the mix of power generation can be varied depending on market conditions. A significant strategic fuel stock is also held for the diesel generators.

Power generation is controlled and managed almost solely by MUA (formerly the MEA). This avoids a number of different private and / or public bodies trying to co-operate in the same space with potentially conflicting ideas, technologies and needs which is the case in many other countries. This more unified control is common amongst other islands including Jersey, which is controlled and managed by Jersey Electricity Company (a public limited company).

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Source: Isle of Man Government (photo)


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Jersey has a far lower power generation and the majority of their power is imported (94% of power was imported for 2014-15). Jersey also experienced some issues in 2012 and in 2016. By comparison, the Isle of Man has 232 MW of power capacity with only 60 MW of this being the interconnector, which generally operates on a net export basis.

The Isle of Man generated 367 million units of electricity in 2015/2016 and sold 87 million of these to the UK, generating £3.2m of export profit.

→ Power resilience

The latest power resiliency statistics for Manx Utilities are 17.16 customer minutes lost for 2015/2016 (of which over 70% relates to planned maintenance work) versus a UK average of 50.71 for 2014/15 which is the latest available period from Ofgem.

In addition, there is no reliance on a single source of fuel. “Peak load” in winter for the Isle of Man is around 80 to 85 MW, therefore even if there is an issue with the Island’s power generating assets, the Island still has a significant margin of firm capacity above the peak load requirements, providing a significant level of resilience.

Telecoms capacity and resilience

The key aspects of a telecoms infrastructure, particularly for data-hungry businesses, are resilience, capacity and speed. Network speed is a complex factor because it is about so many more factors than just the speed of the local telecoms infrastructure, but this does play a part.

Broadband penetration on the Island is high as very few properties have no access to broadband. The Government also has a “Digital Inclusion Strategy” as part of its “DigitaIsland” project.

→ Network resilience

The Isle of Man has the following network connections:

• Isle of Man to England interconnector (Manx Electricity Authority, lit in 2007 - UK)

• BT-MT1 (BT/Manx Telecom, 1990 - UK)• BT-MT1-NI (BT/Manx Telecom, 2000 - Northern Ireland)• LANIS-1 (Cable & Wireless, 1992 - UK)• LANIS-2 (Cable & Wireless, 1992 - Northern Ireland)

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Source: Manx Utilities annual report 2015 /2016, PwC analysis


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This provides 5 different links between the Isle of Man, the UK and Ireland which significantly reduces the chances of a complete network failure to the Island. In addition, given that an estimated 95%-97% of all internet traffic is carried by submarine cable, this risk exists everywhere, not just for an island. Having fewer connections does place the Island at a slightly higher risk of disruption due to an anchor snagging or fishing activity causing cable damage. There are a number of entities monitoring this for movement and damage including AWJ Marine, KIS-ORCA, and the Isle of Man Government (via e-llanCommunications Limited). However, as Jersey’s example shows, even geographically dispersed cables can suffer outages, particularly if there is no unified responsibility for the end-to-end infrastructure.

There are a number of prominent e-gaming companies based on the Isle of Man whose business models rely on almost 100% uptime. Many of these operators have been based on the Island for more than a decade and we are not aware of any significant network disruptions being experienced with any frequency.

This provides credibility to the Isle of Man’s claims that its telecoms infrastructure is resilient as it is backed up by, in telecoms terms, a long track record. Manx Telecom’s Douglas North datacentre, although it is “only” Tier III rated, has achieved 100% uptime since it was opened in 2005.

→Network capacity

The transmission capacity available to the Island can be numbered in terabytes, which the Government believes is future-proofing the Island’s telecommunications needs. Repairs and the laying of new fibre can be an expensive process as they are located undersea, although the

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Source: e-llan Communications Limited

transmission equipment is principally onshore at the landing stations. In addition, almost all internet traffic now travels via subsea cable and as a consequence this additional repair and maintenance cost exists in every jurisdiction - not just on the Isle of Man.

The Isle of Man has enormous network capacity due to upgrades made to the transmission equipment. The interconnector alone has a current working capacity of tens of TB/s and it is likely it can be upgraded further as technological advancement are made, such as the recent upgrades for DWDM. The older fibres have also been upgraded to higher capacities than their original designs.

To give a sense of how significant the Island’s capacity is, Google recently invested c. $300m in its “FASTER” project to install a new subsea cable to provide a peak bandwidth of 60 TB/s to and from Asia. We also compared this capacity versus streaming a film on Netflix in 4K resolution. According to Netflix, this requires a connection of 25 MB/s. The interconnector alone would allow more than 500,000 households to simultaneously stream a 4K resolution film.


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As there are only 35,559 households on the Isle of Man according to the 2011 census, this is unlikely to be an issue anytime soon and the speed of an end user’s network connection is determined by the slowest link so the ability to stream at 25 MB/s is limited at present. The glass that makes up the fibre has an almost infinite life, and the equipment which provides the speed can be, and is being, updated frequently to take advantage of new technologies ensuring it is very well future-proofed.

The design life of the interconnector when installed was 45 years (guaranteed) and recent testing has indicated there is no degradation in light amplification or signal loss. Furthermore, the interconnector has been buried 2m deep into the seabed (rather than lying on top, which is common for subsea cables) and the network fibre is laid alongside (not inside) the power core, easier to haul up for repairs if needed.

The core asset of the glass fibre can operate indefinitely – it is only the transmission kit which has a finite life. Fourth and fifth generation fibre-optic communication systems have been developed using optical amplification to reduce the need for repeaters and adding wavelength-division multiplexing to increase data capacity. This transmission kit is being regularly upgraded by e-llan, BT and Vodafone to continue to enhance the performance of the networking infrastructure.

→ Network location

The Isle of Man is geographically close to Europe in particular. In some industries, particularly financial markets using HFT, a few milliseconds can make a large difference in the profit a trade makes. The Island is therefore in a good place geographically to serve Europe and the UK. However, it is not geographically close to many of the “emerging” markets whose growth is greatest, including Africa, China, and South America, but this is common across the comparative jurisdictions.

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Distance in miles to major cities from the Isle of Man



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→ Network speed

End-user speed is a much more difficult figure to try and analyse. The Analysys Mason report puts the Isle of Man either mid-table or 3rd

quartile in terms of speed, particularly upload speeds. These are stated as being c. 20% and 35% below the average for download and upload speeds respectively against Western Europe based on Cisco data.

We independently looked at sources such as testmy.net and Ookla, and obtained the weighted average upload and download speeds noted in the graphic above based on actual test results.

For many reasons, these test results are never completely reliable or representative, but they do give some sense of actual user experiences. However, the results support the Analysys Mason report and indicate our network speeds are somewhere between average and below average. However, they are not dissimilar to other Island jurisdictions such as Jersey and Guernsey.

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Source: testmy.net, Ookla.com, PwC analysis

Number of testsMB/s


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Jersey, under the name “Gigabit Jersey”, is currently attempting to roll out FTTH (one of the fastest connections currently available) which is also being trialled in York in the UK by TalkTalk and Sky. From the interviews undertaken, it is unclear how well this is progressing and at what cost, although numbers in the region of £50m - £80m have circulated online. Some costs quoted for York were £500 per premises connected, although this does not include the “final bit” to connect to the actual house, which we understand is the most expensive and difficult aspect of an FTTH deployment.

→ Network future developments

The Island also has a history of telecoms “firsts”. In December 2001, Manx Telecom became the first operator in Europe to launch a live 3G network, as at this time the company was used by its parent (then O2) to develop and test new services in a controlled area prior to wider roll-out. In November 2005, Manx Telecom also became the first company in Europe to offer its customers an HSDPA (3.5G) service.

As the Island has a limited number of cables, it may be feasible to scan the information being transmitted along these channels. A similar concept is being explored in the UK called “Active Cyber Defence”.

Could this be used to scan for malware signatures for every piece of data coming on or off the island to reduce the incidence of virus and malware attacks? Can we make the Isle of Man a “cyber safe” jurisdiction? We understand that the Island’s Cyber Security Working Group is working with the NCSC in the UK to ensure the Island is able to take advantage of the UK’s initiatives in this area.

The following diagram shows the UK’s “Active Cyber Defence” concept in more detail:

Source: UK National Cyber Security Centre

A local satellite company, SES, also announced in 2016 that they intend to create a new teleport which will have a number of earth stations on the Isle of Man. According to the press release, this will “… include satellite telemetry, tracking and commanding (TT&C) facilities and capacity management, together with a wide range of teleport services such as uplink, downlink, and contribution services for broadcasters and data centres.” This is still in the process of finalisation.

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Datacentre provision

Datacentres are facilities used to house computer systems and associated components, such as telecommunications and storage systems. They usually include redundant or backup power supplies, redundant data communications connections, environmental controls (e.g., air conditioning, fire suppression) and various security devices.

→ Datacentre reliability

The most common metrics used to rank datacentres are the tier systems used by both:

1. Telecommunications Industry Association 9422. Uptime Institute

It is important to understand that these tiers are focused on system uptime and redundancy rather than information security or speed. A Tier IV is not necessarily "better" than a Tier III, but it is more robust and provides greater redundancy.

However, there is a cost to implementing the measures (and getting and maintaining the certification as well). One source estimates that the cost of a Tier IV datacentre is roughly double that of a Tier III (with a Tier III being double a Tier II, and so on).

The Isle of Man has the following datacentres:

• Douglas North, Douglas (Manx Telecom)• Greenhill, Douglas (Manx Telecom)• Heywood House, Douglas (Wi-Manx)• Contintent8, Douglas (Continent8)• The Dataport, Ballasalla (Netcetera)• Isle of Man Datacentre, Ronaldsway (Domicilium)

The highest of these is rated Tier III. There are also no UK, Channel Island or Irish Tier IV datacentres, although there are 3 Tier IV datacentres in Luxembourg. 2 of these are owned by EBRC, a major Luxembourg data asset with state backing.

Switzerland as another competitor jurisdiction also has a single Tier IV datacentre, which is owned by Swisscom. Switzerland is also marketing in this area given the changes which that are likely to be coming on banking secrecy, which is being eroded. However, data secrecy / security appears a natural progression and Switzerland has some of the strictest data privacy and data protection laws to facilitate this.

Consideration would need to be given to whether commissioning a Tier IV datacentre on the Isle of Man would make commercial sense, although this could represent a point of differentiation versus our competitor jurisdictions as only Luxembourg and Switzerland have this at present. It is important to stress that the Tier rating only applies to uptime, not to security, and that there is a significant cost of complying with this and obtaining the certification. A number of prominent, well-respected datacentres in various countries have chosen other certification routes or ones more focused on security. Depending on the objective, this may make more sense on the Island.

→ Datacentre capacity

Although figures are not publically available, we understand from the interviews we undertook and a number of online articles quoting Isle of Man Government sources that the Isle of Man has spare datacentre capacity. There is no available information to derive spare datacentre capacity; but it appears there is capacity to support further growth without a new datacentre.

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The Isle of Man has an area of 221 square miles and a much lower population density of 383 per square mile versus Jersey which is only 46 square miles with a population density of 2,121 per square mile. Guernsey, Greater London and Luxembourg are respectively 25, 607 and 998 square miles with population densities of 2,499, 14,290 and 577 per square mile. Ireland is larger at 33,000 square miles with a lower population density of 190 per square mile.

The cost of land and limited availability is prohibitive for many of the comparative jurisdictions in terms of increasing capacity. The Isle of Man Government is also a significant landowner which, if supported by government policy to help facilitate a data proposition, may make the acquisition of land at a reasonable cost easier than other jurisdictions.

In Ireland, which has attracted a large number of key datacentre tenants recently, an average land price of €8,914 per acre was calculated for 2016 based on 846 competed sales (equivalent to c. £7,700 at current rates). It is difficult to obtain Isle of Man land prices for non-residential land without planning consent, but based on the limited information available, this appears to be in the range of £5,000 to £25,000 per acre.

Infrastructure: Summary

The Isle of Man has a proven, resilient infrastructure in terms of power and networking. The Island is also well served by a range of datacentres which are comparable with those in our competitor jurisdictions with the exception of Luxembourg and Switzerland, which have both invested heavily in this area and have Tier IV datacentres. There also appears to be land available at moderate cost in order to build further datacentres should they be required, although cheaper locations such as Ireland do exist.

Our power uptime statistics indicate that uptime is very good compared to other jurisdictions and there is no reliance on a single source of power generation, with significant redundancy capacity built into the power network.

Our network infrastructure and capacity is also vast and very well future-proofed. The total capacity of the Island is well over 10 TB/s, and we understand that only a fraction of this is currently in active daily use. In addition, due to the nature of the fibre optic cables, the transmission equipment can be enhanced to extract even greater performance from the cables as the technology continues to develop.

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Source: Wikipedia, PwC analysis


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Financial infrastructure

Executive Summary

This diversity is supported by a strong professional services sector which is experienced in a wide variety of types of work and has an ability to adapt quickly, although this means the Island does not have some of the niche specialists that our larger competitors might have.

• Existing international finance centre

• Strong links with the UK and London

• Strong professional services sector

• Well diversified economy

• Encourage greater collaboration and information / asset sharing

• Encourage the “Innovation Isle” concept again

• Explore company legislation specific to a “data company”

• Support the digitisation of banking facilities

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Key strengths

Recommendations

The financial infrastructure is reasonably strong, although in the press in particular the Isle of Man is still trying to fight off its perception as a “tax haven”. The message to the international community is also not as clear and direct as some of our competitors in relation to the data proposition. The economy is more diverse than many of our competitors, although there is a current weight in e-Business and ICT.


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Financial infrastructure (cont.)

Why does it matter?

The Isle of Man has established itself in the last 30 to 40 years as a key international financial centre. The financial infrastructure is important to a successful data proposition, such as the support of the professional services on the Island and the stability and diversity of the economy.

Components of financial infrastructure

From our research and discussions around PwC’s Global network, we identified the following financial infrastructure elements as being important:

• Financial centre status• Economic diversity• Professional services

Overview

The Isle of Man is relatively well-established as an “international business centre”, a reputation which it has cultivated since the start of its unbroken run of economic growth for the past 32 years. A key part of this is the strong financial infrastructure which exists on the Isle of Man which is able to support not just the financial services industry but newer industries such as e-Business.

The Island’s currency is also pegged to Sterling, which minimises the exchange rate risk – although due to Brexit uncertainties, Sterling is currently subject to some fluctuation in value.

However, the Island has seen that all sectors and industries follow a lifecycle, experienced locally with the recent contraction in the number of people employed in banking, for example.

The Island is currently seeking to understand what could be the next big sector which plays to our strengths, and part of the purpose of this report is to understand whether a data proposition could fit that brief.

Financial centre status

→ Current status

The Island’s National Income report highlights how much of the Island’s economic activity relates to its role as an offshore finance centre. 40.4% of 2014/15’s National Income had its source in either Banking, Insurance, or related professional services such as Legal and Accountancy Services and Corporate Service Providers.

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Source: Isle of Man National Income Accounts 2014/15, PwC analysis


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Government marketing literature describes the Island as

The CIA World Factbook has this entry on the Isle of Man:

→ Competitors

By comparison, Jersey has the following entry:

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… a leading international business centre renowned for its innovation, professionalism and longstanding policy of positive engagement with international initiatives and standards.

“

Financial services, manufacturing, and tourism are key sectors of the economy. The government offers low taxes and other incentives to high-technology companies and financial institutions to locate on the island; this has paid off in expanding employment opportunities in high-income industries. As a result, agriculture and fishing, once the mainstays of the economy, have declined in their contributions to GDP. The Isle of Man also attracts online gambling sites and the film industry. Online gambling sites provided about 10% of the islands income in 2014. The Isle of Man enjoys free access to EU markets and trade is mostly with the UK. In October 2014, the Isle of Man signed an OECD agreement to automatically exchange some financial account information to limit tax avoidance and evasion.

“

“Jersey's economy is based on international financial services, agriculture, and tourism. In 2010, the financial services sector accounted for about 50% of the island's output. Potatoes, cauliflower, tomatoes, and especially flowers are important export crops, shipped mostly to the UK. The Jersey breed of dairy cattle is known worldwide and represents an important export income earner. Tourism accounts for one-quarter of GDP. Living standards come close to those of the UK. In recent years, the government has encouraged light industry to locate in Jersey with the result that an electronics industry has developed, displacing more traditional industries. All raw material and energy requirements are imported as well as a large share of Jersey's food needs. Light taxes and death duties make the island a popular tax haven. In October 2014, Jersey signed an OECD agreement to automatically exchange some financial account information to limit tax avoidance and evasion.

“


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However, it is important to recognise that the Isle of Man (and Jersey) are both competing in what is an increasingly competitive “international financial centre” environment. Territories such as Ireland, Luxembourg, Monaco, Lichtenstein, and the Cayman Islands are all attempting to attract similar types of business.

Due to geography and shared history, the Isle of Man is intrinsically linked to the UK. A decline in the UK’s fortunes will therefore almost always result in a decline in the Isle of Man’s fortunes, although there is some ability for us to “limit the damage” as during the recent financial crisis. The UK is currently working out how to undertake its “Brexit” from the European Union, and we understand from discussions with the Chief Minister that this is a key focus for the Government at the moment.

This represents a factor to a large degree outside of the Island’s control as to whether the UK is successful in its negotiations and is able to prosper once this has taken place. This uncertainty is no doubt a threat which could materialise as increased competition from the UK free of EU control, but it could also be an opportunity if the UK flourishes.

Economic diversity

The Island’s economy is home to a wide range of sectors including:

• Financial Services• e-Business• e-Gaming• Manufacturing• Aviation Services• Ship/Superyacht management

These make up a relatively diversified percentage of activity, with e-Gaming being the largest single sector (and which is also one of the fastest growing sectors). In order to keep our economic diversity, it is important therefore to ensure e-Gaming can be supported by another high growth sector. If 25%+ of national income is provided by one industry that could be easily moved to another jurisdiction (although at a cost), the Island may be at risk of a serious crash.

Professional services

The Isle of Man has a large professional services sector, which supports a whole range of industries, including those which already exist, and new and emerging sectors such as BioMed, Fintech, AI, and Robotics.

The Island has diversified in recent years away from core banking and insurance and because of its small nature, the professional services community collectively has had to be agile and able to adapt quickly to learn new skills and be able to work in new sectors. The sector is therefore well positioned to be able to support new initiatives, such as a data proposition, by having this agile footing.

However, the disadvantage of being good “generalists” is that it is more difficult both to attract, and to retain, deep subject matter specialists, particularly in professional services, due to an inability to provide guaranteed work on one specific subject matter all year. This is a similar challenge to the strategy for the employment of health consultants on the Isle of Man.

In some areas therefore, the skill level of the most experienced Isle of Man practitioner will not be equal to a more specialised individual from a larger jurisdiction such as the UK.

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This concept is explored more fully in the recommendations section, but a more focused strategy may help to develop a concept similar to a “centre of excellence” in certain sectors on the Isle of Man, potentially including data or perhaps a specific sub-section of data, in order to make this compelling. This would then help to attract and retain these specialists.

There is also a need for the businesses attracted by the data position to have access to banking facilities on the Island, as without this the businesses are likely to go elsewhere. The proposition will not be successful unless the banks are aligned to the proposal and can make the process of opening and operating bank accounts low friction.

Financial infrastructure: Summary

The Isle of Man has a strong existing financial infrastructure which has operated for a number of years. This provides a very solid base from which to expand into a data proposition that will require many of these same services in order to grow and thrive.

However, the Island is competing with a number of other jurisdictions to attract businesses like this, and it can be difficult to articulate why a business or entrepreneur should move to the Island when many of the offerings from other jurisdictions look similar. By having a specific, targeted strategy it will be easier to write the marketing message as it will be clear how the benefits the Island offers ties in to those specific types of business, some of which may be quite niche.

The Island also has a strong professional services base developed over many years to support the financial services sector. The Island also has a relatively well diversified economy for its size, but with a growing dependence on e-Gaming and e-Business which is one of the highest growth sectors and already represents the largest share of national income contributions (exacerbated by the fact the salaries in this industry are above average).

The professional services sector also lacks some of the more detailed specialists that territories such as the UK may be able to support because to some degree everyone working on the Island has to be able to cover a number of different bases. This in itself is a useful and versatile skill, however.

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Data capabilities

Executive Summary

The Island has good supporting bodies in place which are equipped to help support this data proposition. This includes a very good working relationship between the Chamber of Commerce and the Isle of Man Government.

Because of the overlap in activity between data and the Island’s existing sectors of e-Business, ICT and financial services there is a strong existing skillset which can be used in this proposition. However, the Island is currently lacking an innovation hub or an informal collaborative working environment which many of the Island’s competitors already have in place.

• Strong public / private sector collaboration

• Existing skills which overlap with data activity

• Training groundwork in place at UCM / Nunnery

• Apprenticeship schemes for ICT already in place

• Assign a “responsible body” for the Island’s data proposition

• Promote the Island’s benefits more widely / louder

• Explore the innovation hub concept further (including “hyperconnected” hubs and/or FTTB)

• Consider a centralised information “landing page” for the data proposition

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4 Data capabilities

Key strengths

Recommendations

Low levels of unemployment may however be a cause for concern to some new businesses if there is a perception that it may be difficult to employ staff at reasonable wage levels.


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Data capabilities (cont.)

Why does it matter?

For the Island to be successful with this proposition, there are a number of factors which need to be present. These could be considered “hygiene factors” if one used Herzberg’s “two factor theory” as a model; essential building blocks that will be expected by entrepreneurs, investors, businesses and workers alike.

In this section, we explore the factors relating to data capabilities including supporting organisations which exist, and the skills available.

Components of data capabilities

From our research and discussions around PwC’s Global network, we identified the following data capability elements as being important:

• Supporting bodies• Skills• Working environment

Infrastructure matters are covered in other sections of the report.

Overview

The Isle of Man already has a range of activities in the ICT and e-Gaming sectors, which have a natural harmony with data-rich companies and working with data. The ICT work supports the key infrastructure requirements for a data proposition, including datacentres and IT implementation, support and maintenance. These sectors represent a significant proportion of the Island’s National Income:

• Information and Communication Technology 8.8%• e-Gaming 19.5%

Whilst this is not a direct proxy for the percentage or number of people employed in these industries (due to salary and tax variations), a reasonable proportion of the population already work in roles which have a natural “fit” with data.

Supporting bodies

The Isle of Man has a number of trade, professional and non-profit bodies which support the ICT and e-Gaming industries. We have investigated some of these bodies to understand their status and impact, with some comparison against activities in other jurisdictions.

→ MICTA and the MDSA

The Manx ICT Association is described as an “…inclusive organisation which represents, supports, promotes and grows the Island’s ICT Sector.” In turn, MICTA has developed the concept of a Manx Digital Standards Agency which was a research document produced by MICTA to investigate the Isle of Man’s "data opportunity".

Some of the initiatives within the MDSA are being considered but there is no publicly available "response" document yet showing which priorities the Government has chosen to undertake, although the Government has set out its own Digital Strategy, as depicted over the page. This is an "inward looking" Digital Strategy about how Government will interact with residents, similar to the UK scheme.

Jersey also developed a full consultation, looking at all elements of Digital including “inward” and “outward” facing from Government. This is a wide-ranging report which sets out a number of targets, including a resilient digital infrastructure, building digital skills for all islanders, a Government digital transformation program, a robust cyber security framework and a responsive regulatory environment.

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Source: Isle of Man Government

Luxembourg also has a clearly documented Digital Strategy, with the stated aim of prioritising ICT as “the new vector for economic development of Luxembourg”.

The MDSA's aims are broadly similar to Digital Jersey's "outward" elements, albeit the MDSA is an idea rather than a reality at the moment, as a project of MICTA. MICTA's other current projects are listed as being:

• Innovation spaces• Bridging the skills gap• Supporting the advancement of education at all levels

MICTA has a part time paid CEO and Director, and 9 unpaid volunteer board members, a full time researcher/ administrator and 1 part time educational liaison. Digital Jersey has a full time CEO and a paid board of 5 further directors, 2 special advisors and a team of 8 staff. Digital Jersey also operate the Digital Hub (see “Working environment” section).

The staff assigned to the project is less clear for Luxembourg, but it appears there is a team of 13, structured in a similar way to Jersey.

→ Chamber of Commerce

The Isle of Man Chamber of Commerce (“Chamber”) is a locally based business network, representing key sectors of the Isle of Man economy. It has been established for more than 60 years. Chamber is “the Island's leading advocate and champion for business” with a focus on creating a climate of growth and success. Chamber has a total membership at 31 March 2015 of 278 businesses, representing circa 15,000 employees.

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Source: Isle of Man Chamber of Commerce (photo)


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Chamber has a voice in Isle of Man society and is given time with the Government to express the views of its members. The UK, Jersey, Luxembourg, Sweden all have similar Chamber organisations, although their structures are less “focused” than either the Isle of Man or Jersey, which are more targeted / specific and are the only Chambers which have organised sector-specific committees.

We believe this is a better, more focused model although this is unlikely to be a feasible model in other territories due to their size and diversity of economic activity.

Jersey has recently established a "Digital Business" Committee, although this has no current details and does not appear to be fully active yet. The Isle of Man’s ICT and e-Business Committee would pick up any digital / data work which we believe is appropriate and is the right structure for the Isle of Man. We do not believe at the moment there is a need to have a separate Data / Digital Committee. However, as activity grows, it may be worthwhile to form a permanent Data / Digital subcommittee if such an arrangement can be enacted.

This would help to provide a voice for the “data” sub-community in a similar way to the current arrangement for other sectors, which appears to be a successful way of operating. Chamber’s role in lobbying Government, particularly on topics which are contentious, is challenging but the current arrangement is successful on a small island where access to key Ministers and senior civil servants is more freely available.

We have seen active evidence of this including at a recent event hosted by Chamber, where the Chief Minister, Treasury Minister and Economic Development Minister all attended and spoke, positively re-affirming this collaborative working relationship. Other examples include the recent Vision 2020 initiative, which demonstrates the Government is seeking to work in collaboration with business to develop “Isle of Man plc”.

Skills

→ Current employment benefits

As explained above, 28.3% of the national income is derived from e-Gaming or ICT. This is not the same as the number of people employed, but provides a very broad approximation (average salaries and hence income contributions are higher in ICT and e-Gaming than in many other sectors). These are fields that are linked to data and cybersecurity, and so those skills are likely to be both transferable and relatively readily available on the Isle of Man, particularly when compared with other jurisdictions.

→ Training and education

We understand from private discussions with the University College Isle of Man ("UCM") that they are intending to offer a BSc in Cybersecurity, partnered with the University of Chester. This is intended to be offered from September 2017 subject to UCM being able to secure the right personnel to provide the tuition and support. It will be offered at the Nunnery site which is being developed as a future ICT centre with the ambition to become an ICT science park / hub.

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In addition to this, there are c. 250 students taking IT-relevant courses and 45 in the process of taking the Computer Science BSc undergraduate degree which represents a significant take-up for an Island of this size.

The Jersey International Business School has a number of CPD courses in related fields but the longest of these is 6 hours long, therefore they are not degrees or other professional qualifications. It appears it is not possible to obtain a cybersecurity or data qualification on Jersey.

As would be expected from a larger country, the UK offers a number of cybersecurity degrees at various universities. The UK also offers data analytics, data science, and other related degrees at a reasonable number of academic institutions.

→ Employment

Unemployment levels are low on the Island (normally in the range of 1-2%) although there has been, for a number of years, a shortage in ICT-skilled staff. This could pose a problem for a data proposition as this may create further pressure on a sector which is already facing a shortage of available workers. In order to attract new businesses or provide a compelling data offering, we will also need to attract new workers as well.

→ Work permits

We understand from a recent speech by the Chief Minister that the relaxation of work permits for specific ICT roles for a defined period was felt by the Government to be a successful scheme, and we understand that further consideration will be given to extending this based on the needs of the business community.

→ Apprenticeships

There is also an ICT apprenticeship scheme which has been launched and is supported by MICTA, which aims to help young apprentices find employment with ICT (and potentially e-Business) companies on the Island. This is a further positive step toward encouraging local skills to be developed in the ICT sector. At this stage, a “data apprenticeship” would be in our view too niche.

Working environment

Currently, much of the working environment on the Isle of Man is centred in Douglas or surrounding areas (including the BallacottierBusiness Park), particularly for ICT and e-Gaming. Most employees physically attend office premises at their place of work, although there are some instances of home working being more widely deployed.

→ Competitors

In other jurisdictions, the concept of “co-working” is becoming increasingly popular and there are a number of successful ventures of this type. These include the Sharp Project in Manchester, home to over 60 digital entrepreneurs and production companies specialising in digital content production, digital media and TV and film production in a 200,000 ft² converted factory building, and the Digital Hub in Jersey, a physical space which is "the centre of Jersey’s tech community focusing on grass-roots support, skills and local innovation.” The Digital Hub has an events calendar and a community base and contains a hot desking area for members to drop-in and work, meeting rooms, dedicated desk spaces for start-ups and event facilities. The Hub is also equipped with free Gigabit Wi-Fi.

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Source: www.digital.je (photo)

This is a well equipped and dynamic space with rooms available to rent for very low rates (or free for members of the Hub for non-commercial use - small charge for commercial use). The concept is to develop something similar to an "incubator" for like-minded people to socialise and potentially work together, but aiming largely at smaller companies in their formative stage.

Similarly, Guernsey has the "Digital Greenhouse" which focuses on Coding, Fintech, Innovation, Data and KYC. This also includes a dedicated IP feed providing download speeds up to 100mb. This is a synchronised solution which also allows upload speeds up to 100mb.

Luxembourg also has a Luxembourg Cluster, including a specific Luxembourg ICT cluster, which seeks to bring together public and private enterprises in Luxembourg in the ICT space. This is alongside 5 other such "priority sectors" targeted by Luxembourg, which are:

• Space;• Automotive Components;• BioHealth;• EcoInnovation; and• Material and Production Technology

This initiative is supported by the EU Regional Development Fund, therefore has significant financial backing. It is also supported by and complemented by the physical space of the Technoport which is a combined incubator / co-working environment / fab lab. It focuses particularly on interdisciplinary research topics that can be used by a range of sectors (and especially those in the priority list above).

The Isle of Man does not currently have a project like this, either a private one or a public/private partnership which is the model that other jurisdictions work on. We understand that some developments occurring at the Nunnery in relation to ICT are imminent but this has not yet got a tangible output. We also note that investigating "innovation spaces" is a current project for MICTA, and we understand that the Isle of Man Government’s Department of Economic Development and Cabinet Office are exploring opportunities in this area as a key priority.

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http://www.digital.je/

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Data capabilities: Summary

The Isle of Man has a good skills base for a data proposition. The sector with the largest contribution to national income, e-Gaming, is a data-rich sector and requires the help and support of a significant number of ICT businesses, another large sector. Together, they make up almost a third of the Island’s national income contributions which represents a strong existing skills base to build on.

A number of supporting bodies already exist, although we note that MICTA has a much smaller staff than any of the similar organisations in other jurisdictions. Allocating the data proposition to a responsible body is a decision that needs to be made as, without this, we believe the proposition will not receive the strategic direction and accountability it needs in order to succeed. We feel that the broad structure of the MDSA is correct (a public/private partnership), but we would explore a model similar to the “Cyber Working Group” which was recently created.

Together with the financial infrastructure discussed in this report, this is a compelling start position to provide a digital offering. Unemployment levels are, however, low and the current resource scarcity in this sector likely implies that in order to create or grow a data proposition, it should be assumed that new workers will need to be found and incentivised to move to the Isle of Man, as it is unlikely the current labour market could easily absorb this demand.

In building the data proposition, we have set out elsewhere in this report how a strategy needs to be set out to give clear, focused, direction. In setting a clear strategy, new business propositions or marketing initiatives that don’t support the strategy should either not go ahead, receive no funding, or should be given a lower priority.

Given its current skills shortage in ICT as whole, the Island will also need to focus on elements that create the highest value on the Island but are resource light. This is similar to the approach being taken in other sectors such as precision engineering where the most successful ventures have been those that follow a format of low volume, high value, largely bespoke work. This could, for example, be in developing bespoke data analytics models for particular niche industries rather than just attempting to create a broad “data everything” proposition, which we do not feel would be as compelling or persuasive.

The MDSA paper also talks about the strategy of aiming to “complement and enhance the Isle of Mans’ existing and developing sectors”. Joe Hughes, its author, also spoke on this topic at the Government’s Vision 2020 session recently as a “Fusion” concept, where advances in one industry are made to have a multiplier effect.

Because of the Isle of Man’s small size and therefore the proximity of its business, we believe there is a significant opportunity in this idea. The most common way of this being implemented at the moment is via “innovation hubs” or similar, as explored in this section of the report. We believe developing this idea, potentially through the Government (or a PPP) applying to the Enterprise Development Scheme for funding, to deploy such a concept locally should be a priority. They have proven to be very successful in other jurisdictions, particularly where the goal is innovative ideas being shared in high tech or emerging sectors.

We understand from our interviews that some similar research and thinking is taking place in both BioMed and Engineering, and it may be worth these three sectors coming together to investigate this potential opportunity as we believe the Fusion concept would apply well in these industries, with data analysis and data processing at the heart.

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Government support

Executive Summary

The Isle of Man has a very stable political environment and there is a good relationship between the Government and businesses on the Island. Furthermore, the Island is actively seeking economic growth and the expansion of the workforce. However, there is no clear strategic direction from the Government and no dedicated “data” or “digital” tsar, unlike some of the Island’s competitors.

• Stable political environment

• Pro-business Government

• Good business and Government links already in place

• Unique and compelling package of incentives available

• £50m EDS commitment already in place

• Set a vision / strategy for the Island in relation to data

• Assign a “data” or “digital” tsar responsibility for the proposition

• Consider Government resources

• Develop a “priority sector” framework

• Define “guiding principles” for the data proposition activity

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5 Government support

Key strengths

Recommendations

The incentive schemes available are unique and compelling in their composition as they are able to offer loans, grants and equity which will help to attract new businesses, combined with the scale of the £50m EDS.


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Government support (cont.)

Why does it matter?

Any data proposition needs to be persuasive in order to attract business to either setup or move here, funds from investors to make those businesses successful, and workers to be employed here and provide the skilled resource needed to make these businesses a success.

In addition, we feel that government backing or support for the proposition is a required factor in order for it to succeed. This provides validation to the external parties that the Government supports this initiative and gives clarity and certainty around the Government’s position. If this isn’t in place, externally there may be a fear the Government may not support a certain course of action or may introduce legislation in future which might harm this sector.

Components of Government

From our research and discussions around PwC’s Global network, we identified the following Government elements as being important:

• Political stability• Government structure• Government incentives

Legislative and Regulatory matters are covered in another section of the report.

Overview

The Isle of Man is a Crown Dependency, together with Jersey and Guernsey, enjoying a unique status politically. The government of the Isle of Man is a parliamentary representative democracy and is not subordinate to the government of the United Kingdom. The UK government is responsible for the Island’s defence and external affairs.

The structure and support of the Government is a consideration, particularly for investors and entrepreneurs who are in the process of considering where best to place their business interests or where to provide financial support.

Political stability

One of the Isle of Man’s “claims to fame” is that Tynwald, our legislative parliament, is the world’s oldest continually running parliament. This therefore stakes a strong claim for political stability. In reality, particularly since the 1970s onward when the finance sector started to really develop, the Island has been a stable and largely prosperous place to live and work.

The United States is about to finish a Presidency complicated by the fact it had a Democratic President but a Republican majority in the US Senate. This made passing laws and regulation very difficult, even those that were logical for both parties, due to the politicking involved.

Source: CNN (photo)

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There is a growing consensus that the recent success of President-elect Donald Trump in the US, will likely cause a tidal wave in world politics.

Based on all of this, many advantages can be seen of a system of such political stability as the one enjoyed on the Isle of Man. On the Isle of Man, this long established system makes the chances of wholesale policy U-turns far less likely, which is perceived as a threat to many entrepreneurs and investors. As an example of this, Donald Trump has publically stated that on day one of his presidency, he will cancel payments to the UN Climate Change Program, end the “war on coal”, and repeal “Obamacare”.

Any businesses which were in America (or working with America) on renewable fuels, climate change, or implementation of Obamacare are now suddenly facing a change in policy which could potentially undo all of their work and make their investment worthless. The impact of sudden policy change can therefore be significant, both financially and in terms of reputation.

We have also seen from the newly elected House of Keys that they have publically committed to a strategy of being “business friendly” and “working together” with the business community, which are encouraging signs for the Island, mentioned at a recent speech by the Chief Minister.

Government structure

Tynwald consists of the directly elected House of Keys and the indirectly elected Legislative Council. With 24 members, this ensures there are appropriate checks and balances to avoid harmful legislation being passed, but not so many approvals to obtain that no decisions end up being taken. Regulation and legislation has been explored more fully in another section of the report.

Source: Peter Killey / BBC (photo)

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The Manx political system is not based on party politics of independent members and the House of Keys is largely made up of independent members. Although some party affiliations do exist, their membership is limited compared to the system in the UK and other countries. The advantage of this system is that there are always new ideas and thoughts coming to the fore, not driven by party politics. If there is a downside, it would be that sometimes asking 24 individuals with different ideas and philosophies to agree to one idea can be difficult.

In the Isle of Man, the Government’s own Digital Strategy is overseen by the "Minister for Policy and Reform".

Compared to the comparative jurisdictions below, this is arguably the least relevant-sounding title of the person responsible for this sector. In Jersey, this was led by Senator Philip Ozouf, the "Assistant Chief Minister for financial services, competition, innovation and digital“, although he resigned in January 2017 due to issues relating to the Jersey Innovation Fund.

We suggest that the Isle of Man explores the appointment of a “digital tsar”, with an appropriate title and remit, to lead the data proposition. Jersey’s title (above) formerly assigned to Senator Philip Ozouf, whilst a mouthful, does sound compelling in marketing literature.

We believe this level of oversight and accountability is needed in order for the proposition to succeed and to demonstrate externally that there is Government support for this initiative, and it would be a very strong and bold statement to assign this to a “digital tsar” with direct access to the Council of Ministers, the House of Keys, the Legislative Council and the private sector.

From other projects we have been involved in and discussions with various stakeholders on the Island, we also understand that similar projects are being undertaken in various industries. For example, the Engineering and Manufacturing Committee have also launched an apprenticeship scheme and an Awareness of Careers in Engineering program to help build awareness of this. It would be advantageous to share the synergies of this project as widely as possible – and specifically for the data or digital proposition strategy, to ensure this is part of an overarching strategic plan for the Island as a whole.

Government incentives

→ Grants for datacentres

The Grants which are available to a business wishing to setup a new datacentre are:

• #2 - Small Business Grant Scheme• #3 - Business Support Scheme • #6 - 0% Green Business Loans (potentially)• #9 - Financial Assistance Scheme• #10 - Enterprise Development Scheme

Specifically in relation to a new datacentre, the cost of such an endeavour is unlikely to be materially changed by grants #2, #3 or #6. Some of these also have a turnover limit (£150,000 for #2) or a size or activity limit. #9 and #10 are likely to be the most useful grant schemes in relation to new datacentres. These are not dissimilar to the offerings from other comparative jurisdictions.

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→ Small business start-up scheme

This scheme is available to Isle of Man based entrepreneurs and business owners and is designed to encourage job creation on Island through increased exports and/or reduced imports and to accelerate growth in small businesses. The cutoff criteria is 10 employees and annual turnover of £150,000. The scheme provides a grant with a cap of £25,000 of up to 40% of a prospective capital spend.

The UK and Ireland both have similar schemes in place, whilst Jersey does not have anything equivalent. The UK scheme is a loan rather than a grant, is capped at £25,000, and has an interest rate of 6% fixed p.a. Ireland also has a loan with interest at 6% - 10% p.a.

The schemes are all broadly comparable, offering to support fledgling business as they seek to grow. The "cut off" point differs under each scheme (given the differences in scale of the countries) and some are loans rather than grants, but the fundamental principles and target businesses are broadly comparable. The Isle of Man offering is more favourable as it is a grant rather than a loan, with similar acceptance criteria.

→ Enterprise Development Scheme

The Isle of Man Enterprise Development Scheme is a £50m fund designed to “help you start and grow your business". The investment period is over five-years and the funds are to be used in businesses that seek to create jobs on the Island. The fund can invest as equity, venture debt or loan. Broadly, the assistance available is subdivided into the following:

• Expanding your business (small to medium businesses)• Relocating your business (medium to large businesses

relocating)

Depending on which category you fall into, a range of either grants or loans are available, up to a maximum of £1m.

We are not aware that any news has been announced from the scheme since it was formally launched in June 2016 and no investments have been publically declared. We understand that a large number of applications have been made. Our interviewees also expressed the view that it was surprising that no investments had been made yet and no deals signed.

→ Competitors

The idea of the EDS is positive, although similar incentives exist in a number of our comparator jurisdictions. Jersey's "Jersey Innovation Fund" states it is "currently under review and it’s unlikely any new applications will be considered in 2016” which was also a loan facility. £5m was allocated to the fund by the States when it was originally setup in November 2013. However, it appears that only 6 advances of funds were ever made - details of the amounts are not readily available (this information was blocked in the FOI requests) but some information is listed in news sources. These state:

"Since January 2014, when the board first began to meet on a monthly basis, about 40 applications have been considered, but only four applications have negotiated through the process to obtain their request. To date, £900,000 has been loaned to three businesses, with a £500,000 loan to another about to be finalised."

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A further news story states that £400,000 was loaned to LogfillerLimited but the company appears to have since vanished. It is clear therefore that managing such an innovation / development fund is difficult and that although the Isle of Man's "pot" is much larger at 10x that of Jersey, the idea was actioned in Jersey first.

In addition, Senator Ozouf’s resignation was accepted by Jersey’s Chief Minster on 17 January 2017 as a result of a “catalogue of failings” published in Comptroller and Auditor General Karen McConnell's report into the activities of the Jersey Innovation Fund, with a conclusion that only 26% of the scheduled repayments had actually been made.

In the UK, there is nothing similar to the EDS although there are a number of loan / finance facilities available some of which are government provided and others which are "government advertised". According to the UK Government website, there are 319 total schemes (excluding advice and recognition awards) of various descriptions to all business types, with no specific filter for digital or data businesses. Filtering by science and technology returns 232 such schemes.

Luxembourg has an initiative called "Luxinnovation" which is run by the National Agency for Innovation and Research. Its stated aim is "to improve the start-up conditions for young innovative enterprises in the ICT sector". This also provides some early stage funding under the "Fit for Start" label - a grant of up to €50,000 is available as part of this.

This is however a selective and limited program, with two editions of Fit for Start organised every year. The best candidates are invited to pitch their projects to a jury composed of experienced entrepreneurs who select the 5 most promising start-ups for participation in each edition (therefore a maximum of 10 companies per year are selected).

When compared to its comparator jurisdictions, the Isle of Man’s offering in relation to business support stands out as being fairly unique in the combination of support it is able to provide. Whilst individually some of these components are offered elsewhere, none have the same key combination of loans, grants and equity funding, tailored toward new and existing businesses, that the Island has.

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5 Government support

Source: www.bailiwickexpress.com


http://www.bailiwickexpress.com/

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Government support: Summary

The Isle of Man has a very stable political structure, which is suited to the size and purposes of the Isle of Man. The Island currently does well in supporting business activity on the Island and we understand from our own personal meetings with them that the newly elected administration is “business focused”.

There are some areas where better synergy could be achieved by the Island working more co-operatively together which we believe Government can help to facilitate. Setting out that the Island should be the custodian of sensitive and important data is to an extent painting a target on the Island – we need to be ready to identify and defend against incoming threats to a much greater degree than we can currently, for example by implementing a national Security Operations Centre to improve the posture of the whole island in relation to Cyber Security.

We believe the EDS is a positive step, although if not already done, we should seek to understand what went wrong with the Jersey Innovation Fund to try and avoid the same problem occurring here. In particular, given the types of business which will be supported, we believe that better communication to the public about the % of businesses that are expected to fail might help so that when this inevitably does happen, the message can be managed.

The particular combination of financial support offered by the Isle of Man Government, which offers grants, loans, and equity funding to new and growing businesses, is a mix that no other jurisdiction has in the same combination, which appears very compelling.

We also believe that it is important for the Government to be completely transparent about the process – this could start, for example, by publishing the number of cases which have been assessed and turned down (and hopefully in future, accepted) unless there is a commercial reason not to do so.

Assigning responsibility for the data proposition to a “digital tsar” would be a bold but necessary move in order to give this sufficient power and purpose, and to make someone accountable to making sure the project is a success.

Whilst this has been stated elsewhere, we believe that setting a clear Government strategy for the data proposition is also an essential first step, to provide clarity of purpose and to provide a definition of what the project seeks to do. Because of the Isle of Man’s size and resources available, this needs to be appropriately targeted and limited as trying to achieve a general “data proposition” is impossible.

However, setting out a specific, targeted data strategy will make this goal more accountable and focus the activities of Government and the business community. It will also provide clarity to entrepreneurs, investors and businesses about what the Isle of Man data proposition clearly stands for and what its goals are.

The fact this report has been commissioned demonstrates that the Isle of Man Government, including the Department of Economic Development and the Cabinet Office, is committed to working with industry to develop a “Digital Island” strategy. Our interviews highlighted that whilst there may be challenges, there is a significant level of private sector support for this initiative as well.

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Legislation and regulation

Executive Summary

The Isle of Man has a good regulatory structure and is able to pass new laws quickly as a consequence. Many of its laws and regulations follow UK custom, such as in data protection where GDPR adequacy is being sought and in the Island’s IP law.

However, there are some areas where the Isle of Man could seek to innovate and move away from the UK model to support its data proposition.

• Quick law-making process

• Compliance with UK legislation on IP

• Seeking GDPR adequacy

• Fair telecoms interception regime

• Undertake and publish a risk appetite review

• Create clear, data / digital ready legislation

• Draft framework legislation for new sectors / technologies to encourage early stage adoption on the Island

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6 Legislation and regulation

Key strengths

Recommendations

The telecoms interception regime is fair and straightforward, with a much more limited basis than in the UK.

Some of the legislation, whilst recently updated, does not fully reflect the nature of business that a data proposition may encourage.


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Legislation and regulation (cont.)

Why does it matter?

From our own discussions, general Isle of Man marketing materials, and from our interviews, we identified that one of the key weapons in the Isle of Man arsenal, because of our legal and political status, is the ability to pass legislation. Therefore, our ability and desire to legislate and regulate (and potentially de-legislate and de-regulate if needed) will be one of the key factors in determining whether the data proposition can be a success.

Components of legislation and regulation

From our research and discussions around PwC’s Global network, we identified the following elements as being important:

• Common Law basis• Regulatory structure• Data protection• Intellectual property• Telecoms interception regime

Overview

The global perception of the Isle of Man has, for a number of years, been shaped around the fact it is considered to be a “tax haven”. This was based on the low corporate (and personal) tax rates which were enacted via legislation on the Island in order to attract businesses and workers here.

The global landscape of taxation is going through a seismic shift and attitudes to “tax minimisation” are hardening. The OECD BEPS initiative, and specifically the application to the digital economy, is key to the attractiveness of the Island’s data proposition.

Common law basis

The Isle of Man has a common law basis, which means it is developed by judges (Deemsters) and Courts, based on decisions that nominally decide individual cases but that in addition have the effect of precedence on future cases. Where a case is considered to be the “first time”, this is referred to as a “matter of first impression” and the outcome of that case sets the precedent for future cases with a similar nature.

The common law system is primarily used in the UK and a number of former British Empire territories, including Australia, Canada, the United States of America, India, Pakistan and Bangladesh. This therefore offers a different approach to most of the rest of Europe, which generally uses a civil law system (which is more codified and based less on past precedence of judicial decisions).

Because the Isle of Man is small and only has two Deemsters, this could create a situation where a legal case is often the “matter of first impression” because the specific point of law has not been heard before in the Manx Courts. This can make the legal process costly and protracted. However, in reality precedents in the English legal system, when relevant and applicable, are persuasive upon the Manx courts as well.

The common law basis is not intrinsically better or worse than the civil law system, but it is different and to some businesses and entrepreneurs, it is a preferable system.

We also performed some analysis to understand if the speed of passage for new legislation on the Island was quicker than the UK as a point of comparison. Our analysis had the following outcome:

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6 Legislation and regulation GlossaryAppendicesDetailed reportExecutive summaryContents

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This demonstrates that on average, since 2013, the Isle of Man has passed its laws from first reading to Royal Assent in 199 days, whereas in the UK the average has been 269 days. This means the Island can potentially pass legislation to help data businesses more quickly, although if a “priority sector” framework is put in place as discussed elsewhere in this report, this could be fast-tracked.

Regulatory structure

The Isle of Man has recently unified its regulatory structure in the finance sector, such that this is now all under the Financial Services Authority. A number of activities, such as banking, investment services, fiduciary services, insurance activities, crowdfunding and money transfer services are all regulated and a licence must be applied for before these activities can be undertaken.

The Isle of Man Communication Commission regulates the Telecoms sector. Separately, the Isle of Man Gambling Supervision Commission, which is an independent statutory board established in 1962, oversees land-based and online gambling activities on the Isle of Man.

The Island has also set a number of “firsts” in relation to regulation, such as recently in relation to crypto currency where it introduced the world’s first regulatory framework, including coverage under Anti-Money Laundering legislation and being regulated as a non-financial business.

Transparency and information exchange

The Island is committed to fully complying with all of the recent changes in legislation and policy on transparency and information exchange. A number of official international organisations have devoted much time to the assessment of offshore centre’s practices against global standards.

During 2013 the Isle of Man signed Intergovernmental Agreements with the UK and the USA. These IGAs improve international tax compliance through automatic exchange of information, and in the case of the USA to facilitate the implementation of the Foreign Account Tax Compliance Act.

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The Isle of Man is one of more than 90 countries which have committed to automatic exchange of information under the Common Reporting Standard on Automatic Exchange of Information. The Island is due to make its first exchanges under the CRS in 2017.

From 1 July 2011 the Island moved to automatic exchange of information with EU member states under the European Union Savings Directive.

The Isle of Man’s continued improvement in its compliance with international standards for countering money laundering and terrorist financing was confirmed by MONEYVAL in 2013. Following the Progress Report prepared by the MONEYVAL Secretariat, the Plenary expressed itself “satisfied with the information provided and the progress being undertaken and thus approved the progress report and the analysis of the progress on the core Recommendations”.

Also in 2011 the Global Forum on Transparency and Exchange of Information for Tax Purposes published its Peer Review Report of the Isle of Man. The report set out the Isle of Man’s implementation of the international standards of transparency and exchange of information for tax purposes. On 3 August 2015 the Global Forum published its latest ratings which confirmed the Isle of Man is one of 21 jurisdictions (from 81 rated) to be given the top ‘compliant’ rating.

All of the above demonstrate that the Island is committed to transparency and compliance with the ever-changing regulations of the world, and also that the Island can move quickly and decisively to implement such measures when required.

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Data protection

The Isle of Man is currently recognised by the EU as providing “adequate protection” for data privacy, as a result of which personal data can be flow between the EU and the Isle of Man without any further safeguard being necessary. It is one of only eleven territories to have achieved this, and was one of the earliest as shown in the timeline overleaf.

It is important to note that most of the Isle of Man's "competitor" jurisdictions have also achieved data adequacy (Channel Islands, Switzerland). The United Kingdom (including Gibraltar but excluding most of the other UK Territories), Luxembourg and Ireland are all members of the EU and hence, covered by the existing Directive (and have their own local laws such as the DPA in the UK which mean they are compliant). This simplifies the ability at the moment to undertake data transfers in particular to/from the Isle of Man. This is a key aspect in ensuring that dealing with the Isle of Man is a "low friction" experience.

The Isle of Man Information Commissioner has recommended that:

It is likely that the UK will still be part of the EU in May 2018, and if that is the case then the GDPR will automatically apply within the UK at that time.

All businesses that process personal data in the Island should start to consider compliance with the GDPR.

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After Brexit, if the UK wants to continue to be able to exchange data on EU citizens with organisations based in the EU, it will need to ensure that its domestic legislation is in line with the GDPR. It is not yet been made clear how the mechanics of this will work, but the message from the UK is very clear – there is a firm commitment to the highest standard of data privacy, as set out in the GDPR.

In relation to the incoming EU General Data Protection Regulation, the intention of Government is to introduce “equivalent legislation” to the GDPR here by mid-2018, which would apply to all Manx organisations, irrespective of where the individuals whose personal data they process reside.

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Switzerland has its own privacy regulations called the Swiss Federal Act on Data Protection, which has some overlap with GDPR, but is not an exact replica. For example, although the majority of definitions, principles and concepts discussed in the revision process of Convention 108 are compatible with the EU GDRP, a risk-based approach to the processing of sensitive data will remain, as opposed to the EU concept of explicit consent and it is unlikely, in comparison to the new GDPR that there will be introduction of the right to be forgotten. It has been concluded in the meeting of the data protection expert group that it is not necessary, given that the FADP already provides for "the right to be forgotten" under "the right of objection or correction of data.“



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The other competitor jurisdictions intend to remain in the EU and hence, will have to apply the EU GDPR as it is a regulation with the exception of Switzerland, Jersey and Guernsey.

Broadly, the CI are intending to adopt the same approach as the Isle of Man as they have seen the fact this is unavoidable in order to continue to do business internationally. The Isle of Man and CI regulators are in discussions about how best to approach this challenge as islands.

The Isle of Man is therefore consistent with its competitor jurisdictions. Anecdotally, from both our own conversations around GDPR and also with our colleagues in the UK, we believe that a number of firms are not currently complying with the existing DPA but are not being "found out" because at the moment the Regulators' powers both in the UK and on the Isle of Man are relatively limited and the Regulators only have limited resources. Therefore, entities are only being found out when they have a breach and someone is affected. We believe the true gap between current practice and compliance with the GDPR is actually greater than the gap between the current DPA and GDPR.

Intellectual property

It is the Government’s policy to largely follow the EU and UK legislation to ensure that intellectual property protection in the Island is to the same standard as that in the EU and the UK. The registration of patents, trade marks and designs in the Isle of Man is covered by UK legislation, which applies to the UK and the Island as a single unit.

The Island does not have its own registry for patents, trade marks or designs; instead, any patent, trade mark or design registered with the UK Intellectual Property Office automatically receives protection here.

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The Isle of Man has its own copyright, design right, database right and performers’ rights legislation. However the legislation is kept in line with UK and EU standards. So, for example, the term of copyright protection on the Isle of Man is 70 years from the death of the author, and, in the area of database rights, there is a right of the maker of a database to control for 15 years the extraction and use of information in the database, similar to that in operation across the EU.

The Isle of Man is also, through the UK, party to the key international intellectual property treaties such as the Berne, Paris and Rome Conventions, the Patent Cooperation Treaty and the Madrid Protocol. A wide-scale consultation on IP was undertaken in 2011, leading to 76 different proposals being taken forward with the goal to align Isle of Man IP rights to the UK and EU best practice, and ensure modernity of the legislation.

The outcome of this, broadly, was to seek to keep IP rights in line with the UK / EU unless there was some key reason not to. A number of respondents questioned whether the Isle of Man should seek to "innovate" and offer something better / different than the UK and EU as otherwise the Island is simply constantly playing catch up.

However, that has not yet been undertaken and no specific provision has been made for "digital" rights in particular, which was a finding of the UK's Prof Ian Hargreaves report in 2011, "Digital opportunity: review of intellectual property and growth". As the Isle of Man consultation was launched before the Hargreaves report the findings of the report were not included within it, and there is no evidence they have been considered since.


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The findings of the Hargreaves Report was that the UK, likewise, was not keeping pace with technological changes and needed to move much more quickly in order to make this happen.

Jersey and Guernsey are not party to some agreements such as the Patent Cooperation Treaty, the Madrid Protocol and the Paris Convention. UK registered rights do not extend automatically to Jersey in the way that they do in the Isle of Man. This gives the Isle of Man another key strength in relation to IP.

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The Jersey Patents, Trade Marks and Designs Registries are what are known as dependent registries. This means that registration of any intellectual property right in Jersey is dependent upon registration first being obtained in the UK.

Most of the EU states follow the EU regulations and therefore, do not differ significantly from the UK. Luxembourg's "angle" is really a tax play, as commonly written about in the news, for tax structuring using Intellectual Property holding companies to shift profits around. Pursuing a strategy like this is unlikely to be in the Isle of Man's interests given it is trying to stimulate genuine economic activity and move away from its "tax haven" label - whereas this would be a reversion of form.

Telecoms interception regime

The Isle of Man has 3 relevant regulations in relation to interception:

• The Interception of Communications Act 1988• The Interception of Communications act 2001• The Regulation of Surveillance Etc Act 2006

Interception of telecommunications / data is mainly covered by the ICA 1998 and ICA 2001. Broadly, the acts set out the legal basis for the ability to intercept telecommunications and other forms of communication.

These must be individually signed by the Chief Minister (or the Minister of Home Affairs in the absence of the Chief Minister) and also provides for the creation of the Tribunal and the IoCC. The warrants also have a limited life of 3 months and limited ability to renew. There is no ability, unlike in the UK, to request “bulk interceptions”.


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Broadly, the Isle of Man legislation is designed to only allow interception for either i) the prevention of "serious crime" or ii) "national security". The so-called "Snoopers Charter" in the UK now allows for a third case - iii) the "economic well-being of the country". We note that this is already included within the UK's Data Retention and Investigatory Powers Act 2014 but is maintained in the Snoopers Charter. The IoCC on the Isle of Man has expressed concerns about this additional justification and why this may be necessary, therefore there does not appear to be a desire to adopt this on the Isle of Man.

The IoCC report does however note that some of the legislation in the Isle of Man is out of date but that this is not a priority for the relevant department in updating the legislation to reflect developments in technology and scale. There is therefore potentially a case to say that the Isle of Man’s regime cannot adequately defend the Island from genuine threats from serious crime and/or national security as a result of the legislation not being fit for modern digital life. The Government, as part of this Digital Strategy, may wish to consider whether this could receive an enhanced priority.

The IoCC report for 2015 notes that there were in total 29 warrants issued in 2015 (down from 49 in 2014 and 64 in 2013). This equates to approx. 0.00034 per head of population. By comparison, the UK had 761,702 items of data (data requests) which is the most comparable statistic available, which is equivalent to 0.01188 per head of population. This is a factor of 35 greater. The numbers are broadly comparable as the UK equivalent to Isle of Man warrants is "data requests“, defined as “[a]n item of data is a request for data on a single identifier or other descriptor, for example, 30 days of incoming and outgoing call data in relation to a mobile telephone would be counted as one item of data."

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In addition with the UK's new DRIPA Bill, all outstanding issues on the Bill were resolved on 16 November 2016 and will soon come into force as a Law (Act), including Provision 273(7) which states that:

In practice, UK legislation is not extended to the Isle of Man without Tynwald’s prior consent although it has been held by the Judicial Committee of the Privy Council that Acts of Parliament can also automatically apply to the Isle of Man by 'necessary implication‘.

MHK Chris Thomas has stated to Tynwald in January 2017 that there is no intention to apply DRIPA on the Island. The UK Snoopers Charter has been widely condemned in the press, and a number of stories were generated about how “quietly” it passed through despite its potentially huge ramifications in the post-Snowden age of communication interception, particularly on the grounds of “economic well-being”. Given its evident importance to the UK Government, this could be a strategic differentiator for high value data businesses between the Isle of Man and the UK.

Whilst we understand some companies have considered a data proposition whereby the Isle of Man aims to “market data privacy as a service to overseas governments and multi-national corporations around the world”, we would have some caution around adopting this approach.

Her Majesty may by Order in Council provide for any provisions of this Act to extend, with or without modification, to the Isle of Man or any of the other British overseas territories.

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As described elsewhere in this report, the Isle of Man is still trying to escape its image as a “tax haven”. There is a potential that this offering could be seen as a ploy to attract unsavoury data to the Island; for example, stolen intellectual property, chemical weapons test data, terrorist information exchange, child pornography - all safe in the knowledge that it cannot be ‘snooped’ upon.

This could also potentially paint an enormous target for the Isle of Man to be attacked by cyber adversaries, including highly sophisticated ATPs, and it is unlikely that our current cyber security infrastructure could defend against this. A serious breach would significantly undermine the data proposition as set out above, probably fatally.

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To resolve this, as part of the overall data strategy the Island needs to collectively decide if it wants to pursue this option. It is clear there are a number of perfectly legitimate reasons why countries, companies and individuals may wish to prevent their data from being intercepted (particularly with DRIPA’s 3rd provision). However, some strong anti-abuse mechanisms will need to be built into any such process.

MHK Chris Thomas stated to Tynwald in January 2017 that the UK legislation could be extended to the Island if needed, but there were no plans to do so and current surveillance laws would be updated instead. We would also recommend setting some clear guidelines and procedures to ensure that the types of data highlighted above are not attracted here, and the Island may also need to consider its level of cyber defence if part of the proposition involves attracting high value data to be held here.

Source: edwardsnowden.com (photo)


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Legislation and regulation: Summary

The ability to legislate and regulate both independently and quickly is a key weapon in the Isle of Man’s arsenal. We therefore need to use this as a way to develop the data proposition, as in a large number of the factors relevant to a data proposition, the Isle of Man does not, and potentially cannot, create a single unique selling point.

A successful strategy is therefore to focus on the factors where the Isle of Man has an ability to differentiate itself; its size means it should be easier to achieve close collaboration, its ability to pass legislation quickly means we can legislate for emerging technologies and industries to provide investors and entrepreneurs with clarity which is key for investment confidence, paired with a clear and focused strategy to support and encourage certain niche types of business, whether in data or another sector which can support the data proposition.

The common law basis provides a point of difference to most of the rest of Europe, although it is not intrinsically better or worse than civil law or other systems of law.

The Isle of Man is fully committed to transparency and international co-operation and we believe this is the only strategy which can ultimately be successful, given the direction the world is moving in. Whilst possible to introduce something of an even higher standard than the new “global norms” like GDPR, we cannot see that this makes sense as it will be perceived by the business world as an additional cost with no immediately obvious benefit.

We understand from our interviews that a new Communications Bill is being reviewed which may replace the ICA 1988 which is recognised as needing revision in order to be fit for the digital age.

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Whilst our IP law is broadly equivalent to the UK at present, consideration should be given to updating the IP Law to reflect the findings of the Hargreaves Report in order to provide a competitive advantage, particularly in relation to making the legislation more “digital age friendly”.

The recent Vision 2020 event also highlighted the rise of the millennial. Some of the key traits attributed to millennials was the need for speed, clarity, and transparency. The millennials are often the leaders of the digital businesses the Island may be seeking to attract, so clarity on points of law (such as IP) is key. In many ways, the content of the law is less important than just setting out the Island’s stance on the point of law – any stance taken will be beneficial to some business models, but not to others. By providing clarity and guidance we can better attract businesses whose profile fits the stance the Isle of Man has taken.

Finally, having clarified in Tynwald the intention not to extend the DRIPA to the Isle of Man, a decision should be taken as to whether the proposition should include marketing “data secrecy” - to obtain and safely store trade secrets, intellectual property, and other digital assets -in a similar vein to Switzerland as part of the overall data strategy. Doing so is likely to paint a “target” on the Isle of Man for a wave of cyber attacks and this needs to be factored in to the strategic decision, as the data is likely to be valuable. Given the global public’s perception of the Isle of Man, this may also invite an unwanted assumption that these data assets are in some way illegal, in a similar manner to the way money stored in Swiss bank accounts is generally perceived.


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Recommendations

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Recommendations

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7 Strategic recommendations 56

8 Other recommendations 62


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… to give a clear message to entrepreneurs,

businesses, investors and workers, provide clarity of purpose and to guide

key decisions.

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7 Strategic recommendations

Strategic recommendationsBased on the research performed for this project, we make the following strategic recommendations in order for the Isle of Man to achieve a data and digital strategy and develop its proposition to the outside world.

01

Strategic recommendations


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Strategic recommendations (cont.)

Government responsibility

Assigning the role of a “Digital Tsar” will go a long way toward demonstrating that the Island, including the Government, are committed to the proposition. This will help attract entrepreneurs, businesses, investors and workers to chose to locate here and provide confidence in choosing the Island as a place to base your business. It will also demonstrate purpose and give a focal person for activity, as well as providing the right level of information back to Tynwald. This individual should have strong links to the Council of Ministers, the House of Keys, the Legislative Council and the private sector.

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01 A clear vision / strategy

In order for any data or digital proposition to succeed, the Island needs to define a clear vision and strategy. What are we trying to achieve? How will we achieve it? What is important? Without knowing this, it will be difficult to make any important decisions because it is unclear what goal the Island is trying to achieve.

This will also provide key stakeholders with a clear sense of purpose about what the Island stands for. This provides clarity about whether a business looking to move here will “fit in”; whether as a worker that person will find employment that suits their skills; and whether as an investor, the types of businesses we have suit their investment profile.

Without a defined vision or strategy resources will not be used in an optimal way, our proposition will be unclear (and therefore unsuccessful) and the Island will not be able to make decisions quickly and with a sense of purpose. A clear vision will help the Island to take decisive action because it allows potential options to be ruled out quickly if they do not contribute to the vision, and those which most closely align can be given priority.


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Promote the benefits more

There are a lot of things the Isle of Man is doing well. Because there is no “silver bullet” or single critical USP, we need to promote the benefits the Island does have more widely and with greater confidence. In this report, we have tried to quantify some of the factors which are often quoted about the Island to allow us to be more confident in emphasising these. Some areas were identified where the “marketing” stance cannot be substantiated by the facts as well so we need to be realistic andtransparent about these. The overall “package” the Isle of Man has is compelling, however.

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03 A responsible body

Together with recommendation #2, allocating a body to be responsible for the development and execution of the data proposition is a key step. Without this, there will be no ability to make quick decisions and take meaningful action.

The proposition is designed to encourage economic growth on the Island therefore we don’t believe it will have sufficient credibility if it comes solely from the private sector, as it will be dismissed as marketing.

Some form of Government backing or sponsorship is required in order to make this succeed. We recommend a public/private partnership take on this role. The proposed MDSA structure is broadly correct, although we believe the scope and activity needs to be more tightly focused than that currently proposed. We believe the responsible body should be more like a “working group” responsible for the strategy and execution of the proposition, rather than a membership society.

In its current structure, MICTA is unlikely to be the right vehicle for this as at its heart it is a trade association to represent its membership but it could potentially be repurposed if so desired.


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Clear, digitised legislation

During the interviews we heard different views on legislation – some support for older / more vague legislation as it allows flexibility, and some against on the basis this uncertainty puts off investors and entrepreneurs and adds the likelihood of legal costs. We believe that to create a compelling proposition, clear, digital-ready legislation, for example in IP, direct and indirect taxation, and data ownership is the best approach. For an emerging technology or sector, the creation of framework legislation to set out the Island’s views would help (for example, on Robotics, AI and drones).

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05 Risk appetite review

In order for any proposition to succeed, a certain amount of risk needs to be accepted, both by Government and by the private sector. We recommend that the Government undertakes a risk appetite review to explore the limits of the risk it is prepared to accept, if it has not already done so.

This will enable quicker decision-making as the Government will know in advance what risks it is prepared to accept from business looking to locate here, and the types of business they might want to undertake. As an example, if a data business wanted to move here to add value to data relating to (legal) pornography – would we want to accept this? What “severity” of pornography would be allowed? Would we accept data on (not from) criminals to have value added to them? What about data relating to euthanasia?

The analogy we used at the recent Vision 2020 day was that the Government should define the “field” in which businesses will play and having a clear understanding of risk appetite is a key part of defining this.

From the interviews we undertook and our own observations, there is a fear of failure but for this to succeed, we need to get to a point where measured risks can be taken and failures accepted.


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07 Government resource

As discussed under other recommendations in this report, at the moment there is no clear responsible party for this proposition. Once this is resolved, and the risk appetite exercise undertaken, the Government will need to decide what level of resources to commit.

The architect of this project is Mark Lewin who is also directly responsible for the running of the Government’s IT infrastructure as well as the delivery of the Government’s own Digital Strategy (which focuses on how Government can provide a digital offering to the public). Mark’s role is Director at GTS and during the course of this report being written, Mark was also appointed as interim CEO of the Department of Economic Development.

As mentioned in recommendation #3, some form of Government “approval” is needed to persuade external parties that this is a focused, targeted and legitimate offering. The Government is therefore likely to need to commit some resource to this, whether in the form of staff, the “digital tsar” mentioned in recommendation #2, initiatives to attract businesses, matching private sector funding for certain initiatives, or some other method of support.


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Summary of strategic recommendations

To summarise our strategic recommendations, we believe they will create an environment where the data (or digital) offering is understood, articulated, and the “limits” of what will be permissible, whether via risk tolerance or regulation, is clear.

Digital-ready, framework legislation will provide a steer where there is uncertainty, and this clarified legislation will remove ambiguity and uncertainty. This will provide entrepreneurs, businesses, investors and workers with certainty and clarity, which is key in order to persuade them to move to the Island.

If we can achieve this, people both on and off the Island will understand what the Isle of Man is trying to achieve and whether their business fits into this model. We believe this will reduce the number of failed business development discussions. From review of the Isle of Man’s competitor jurisdictions, the most compelling offerings were those (such as Luxembourg) which had a very clear, transparent and direct offering.

We heard from a number of interviews concerns about the speed of internet provision on the island, lack of suitable working spaces and homes, and lack of skilled resource for certain aspects of ICT. We have discussed some of these in the “other recommendations” section, however, without a clearly defined strategy it is difficult to assess how much of a priority these recommendations should have. For example, if the strategic decision is made to focus solely on AI for example, then using valuable resources to try to foster skilled workers may end up being a waste of resources.

We have considered over the course of this report whether there is a “unique USP” which the Island, or any competitor jurisdictions, possess which makes them the “go to” place for data and digital businesses. The reality is that all of these decisions are made for an enormous, complex number of factors but one of the most important was clarity of purpose. We have also seen there is a “poster child” effect when a key anchor tenant can be attracted.

Whilst anecdotal, the following picture (shared widely on LinkedIn) illustrates this about Dublin:

Source: IDA Ireland (photo - adapted)

We believe the PPP, once formed, should consider if this approach is possible to achieve in relation to the data proposition. We understand from our interviews that the presence of Microgaming moving to the Isle of Man played a key role in encouraging the e-Gaming sector when it first gathered momentum a decade or so ago.


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8 Other recommendations

Other recommendations

Other recommendations

These recommendations are at a more tactical or detailed level because they are reliant on the overarching strategy. Some of these recommendations may not achieve the vision and strategic goal which we believe needs to be defined in order for this proposition to succeed, but they are examples of what other jurisdictions have done in order to develop their own data and / or digital offering.

Innovation Hubs

Our research highlighted that a number of other jurisdictions have already setup innovation hubs, often based on specialised co-working locations. We understand that MICTA and the Isle of Man Government are already actively looking into this idea. The most common model appears to be public/private partnership, which we support, potentially including an application for EDS funds. This could also involve exploring networking solutions as set out under “ultra broadband” below.

Create the concept of a “Data/Digital Company”

Legislation is one of our key weapons, and the Isle of Man could use this to create a type of company which is tailored for a data / digital company – for example, by making it digitally enabled as possible and relaxing company rules in some areas but strengthening them in others, such as minimum cybersecurity requirements. We have not seen a specific company vehicle for data anywhere else in the world. Luxembourg has something, but this is more of a tax play on moving profits around by using IP, which we believe is something the Island should distance itself from.

Framework agreements or legislation

We believe it can give clarity and therefore confidence if the Government could set out its plans for particular sectors using framework legislation (i.e. a set of principles / guidelines for an emerging sector). An example would be Robotics or AI –will this be regulated? Will it be supported? Will it be taxed? Will it be banned? The EU parliament has recently passed a motion on civil laws for robots. If Government can set out its position on some of these areas with the use of framework legislation or framework agreements, it may give people confidence to invest. The key is in being transparent with our policies and our plans as this is highly valued by the Millennials in particular.

Increased information sharing and collaboration

This was also mentioned in the Analysys Mason report in terms of sharing network infrastructure. Essentially, this is “wearing an Isle of Man plc” hat more, as opposed to companies working as private organisations. We believe there is a role for Government here to act as the “trusted party” as otherwise, encouraging private companies to collaborate can be difficult. This is also relevant to cybersecurity, where there is potential to facilitate a national SOC to enhance the whole of the Isle of Man’s cybersecurity posture.

The city of Hull has used this concept to bring together all its “tech people” by setting up the Hull Digital community to try and encourage collaboration and innovation. Hull Digital was founded in a coffee shop and first attended by 12 people, it has since grown to more than 1,000 members and attracted national attention through its conference, Hull Digital Live. Hull has also now been appointed the UK’s “Capital of Culture” for 2017 and is experiencing a boom as a result.


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Other recommendations (cont.)

“Innovation Isle”

A number of interviewees commented that the Island hasn’t been used anytime recently for trailing new technologies or as a sandbox/testbed for new technology types. The key factors which might help this are enabling legislation and by more aggressive pursuit of these technologies and tests. This may help to generate critical mass for the “innovation hubs” and get the Isle of Man significantly on the map for data and tech, although the cost of doing so could outweigh the benefits.

Development of a “priority sector” framework

This is a concept which Luxembourg (via “Luxinnovation”) has, whereby 6 priority sectors are called out as being key sectors. These have been deliberately targeted as having a degree of “fusion” or interdependence, and play to Luxembourg’s existing strengths. The potential disadvantage of this is that it could alienate other sectors – we note that the Isle of Man on www.whereyoucan.com lists 13 “key sectors”. 13 is arguably too many to be able to support effectively, and a more targeted solution like Luxembourg’s may work better and give a clearer message.

This principle could also be applied to the EDS, which does not have a specific focus for data businesses (although they are not specifically excluded). In addition, the EDS has a focus on existing medium size companies or larger companies looking to relocate, rather than start-up data businesses. We recommend that consideration is given to allocating a portion of the EDS funds to this project if the Isle of Man Government decides to support the data proposition.

Define “guiding principles”

As part of setting the strategy, it may help to define some “guiding principles” to focus efforts on the opportunities and areas which are of most value to the Island. For example, those which are resource or labour intensive might be given a lower priority (or not investigated) on the basis the Island already has a shortage of skills in the ICT sector, and this is likely to be a barrier to an opportunity which requires this.

Develop a plan for IPv6

Whilst IPv6 is not directly related to speed, our research highlighted that there are security improvements coded into IPv6 which would be beneficial. There is also some evidence to support the fact it works faster on mobile devices. We understand that essentially the technology is available, but is not yet widely supported (or turned on) by customers’ home routers and by other parts of the network infrastructure.

As the world is increasingly moving to smart devices, particularly amongst the Millennials, this could end up being important. Very few territories have moved with any purpose toward IPv6 yet – according to the Akamai report, the highest adopter is Belgium at c. 50% (albeit with some connection difficulties when using IPv6). Jersey, Guernsey and the Isle of Man are all listed as being 0%.

There are a number of “transition mechanisms” between IPv4 and IPv6, but if the rest of the world moves onto IPv6 and the Isle of Man does not, this will no doubt cause problems because there will be fewer and fewer countries using these transition mechanisms.


http://www.whereyoucan.com/

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There may be an opportunity for the Isle of Man to enhance the adoption of IPv6 either via consumer education, or some other form of active encouragement – possibly linked to the “Active Cyber Defence” concept and their work on Border Gateway Protocols.

Centralised information point for data / digital business

This is an effective technique in Jersey’s Digital strategy. A specific landing page has been developed which signposts an investor or entrepreneur where to go next – we believe it would be useful (and inexpensive) to have a similar “microsite” for data and/or digital businesses, possibly as an addition to www.whereyoucan.com.

Ultra broadband

This point was also highlighted in the Analysys Mason report, and we concur that it should be investigated. However, progress and the anticipated spend on Jersey’s FTTH project highlights that problems can arise and these same issues are likely to exist on the Island as well.

York is currently undergoing trials from TalkTalk and Sky to provide 940MB/s connections to the home, with estimated costs of £500 per premises passed. However, this does not include “the last mile” which is where the majority of the costs are expected to be incurred. Other technologies than FTTH do exist and given the Isle of Man’s relatively small size, these are worth investigating further. We do not believe that FTTH is likely to be cost effective in its current state.

However, other solutions exist on the spectrum between FTTH and FTTC (which is what is currently being rolled out). The speed is greater the closer to FTTH this becomes, but the cost also increases as more and more “last mile” cabling is needed. This can be illustrated by the

graphic below. This could be explored to provide some “hyper connected” hubs in certain places, those where data businesses may congregate, and possibly in conjunction with the “innovation hub” idea discussed above.

Source: User:Riick, Wikipedia


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This could also include the implementation of 5G as some strategic consideration needs to be given to this, given the number of network transmitters we understand are required (which is significantly higher than 4G). The consideration will also need to address issues such as the wayleave and landlord agreements in concluding whether this can be made commercially viable or whether an alternative solution can be envisaged.

The “Smart City” concept

This is unlikely to be economically feasible in the near or medium future, but we recommend considering whether such a concept should be planned for long-term on the Island, as doing so needs years of planning and implementation and also needs to be done to a specific strategy, rather than in an ad-hoc manner. However, as a note of caution, many cities have embarked on this “concept” but very few have achieved anything other than very small scale pilot schemes as yet. The Isle of Man’s physical size may give it an advantage in that it may restrict the space over which the concept needs to be rolled out, as this is one of the major obstacles being experienced elsewhere.


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Appendices 67

0.1 Engagement letter 68

0.2 Sources of information 84

0.3 Scoring methodology 86

0.4 Glossary 87


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0.1 Engagement letter GlossaryAppendicesDetailed reportExecutive summaryContents

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Engagement letter (cont.)

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Sources of information

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0.2 Sources of information

Over the course of this project we consulted with representatives in the technology, regulatory, financial services and professional industries on the Island. We would like to thank everybody who took time to contribute their knowledge and views which helped us enormously to form our own opinions as set out in this report. A number of individuals also contributed anonymously, and we would like to extend our thanks to them as well. A number of key stakeholders met with us, including but not limited to:

Adrian Dobbins Manx Utilities Authority

Carmel McLaughlin Isle of Man Communications Commission

Graham Shimmin Manx Telecom

Iain McDonald Isle of Man Information Commissioner

Joe Hughes Manx Technology Group

Jonathan Mills Isle of Man Government


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0.2 Sources of information

Kevin Paige Manx Telecom

Kristan McDonald ServiceTech / Manx Technology Group

Kurt Roosen MICTA

Ludovic Raymond PwC Luxembourg

Mark Lewin Isle of Man Government

Micky Swindale Isle of Man Chamber of Commerce / KPMG

Phil Adcock Domicilium

Robert Metcalfe PwC Switzerland

Sue Strang Isle of Man Communications Commission


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Scoring methodology

The scoring methodology is a simple benchmark to assess the Isle of Man’s current position against what we have determined as being either “best in class” for a particular pillar, or the “ideal current state” which is to say the best that can be realistically achieved with today’s technology and climate. The “ideal state” has a maximum score of 10.0.

We have then considered the Isle of Man, and made deductions where the “ideal state” has something that the Isle of Man does not have. The deduction ranges between -0.5 and -3.0 depending on the importance and severity of the missing factor.

As an example, the Isle of Man is the only jurisdiction within the comparative list that does not have a physical “innovation hub” or similar. Because the Island is the only place without one, a high deduction has been applied. A lower deduction was applied for the fact there is no Tier IV datacentre because few of the comparative jurisdictions have one and we believe it is less critical.

As a consequence, the scoring has an element of judgement and subjectivity. However, we believe it is appropriate as a tool for presenting a simplified visualisation of where the Island stands against its competitors on the pillars discussed in this report.

Benchmarking is comparing one's processes and performance metrics to best practices from other people, companies, industries or countries.

In the process of best practice benchmarking, one identifies the best practices and compares the results and processes of those studied to one's own results and processes.

This then allows one to develop plans on how to make improvements or adapt specific best practices, usually with the aim of increasing a particular aspect of performance.

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Glossary of terms and abbreviations

Term Definition

4K A screen resolution of 4,000 pixels horizontal and 2,000 pixels vertical (sometimes called Ultra High Definition)

ACE Awareness of Careers in Engineering – a campaign on the Isle of Man to increase the presence of manufacturing on the Island

AI Artificial Intelligence

AOL America Online or AOL Inc., an American multinational mass media corporation based in New York

AWJ Marine A UK company founded in 2006 to provide specialist advice on fisheries and environmental issues

AWS Amazon Web Services, a collection of remote computing services provided by Amazon

CERN European Organization for Nuclear Research (French origin: Conseil Européen pour la Recherche Nucléaire)

CI Channel Islands – (mainly referring to Jersey and Guernsey)

CIA Central Intelligence Agency, a civilian foreign intelligence service of the United States federal government

CPD Continuing Professional Development - continuing education to maintain knowledge and skills, required in many professions

CRS Common Reporting Standard - an information standard for the automatic exchange of information similar to FATCA

D/L Abbreviation of “download” - to receive data from a remote system

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Glossary of terms and abbreviations (cont’d)

Term Definition

DPA Data Protection Act

DRIPA UK’s Data Retention and Investigatory Powers Act

EBRC European Business Reliance Centre – a government-backed data business solution based in Luxembourg

EDS Enterprise Development Scheme – a £50m scheme on the Isle of Man to generate economic development

EfW Energy From Waste - the process of generating energy in the form of electricity and/or heat from the primary treatment of waste

EU European Union

EUSD EU Savings Directive – a tax to ensure that citizens of one member state do not evade taxation by depositing funds outside the jurisdiction of residence and so distort the single market

FADP Swiss Federal Act on Data Protection

FATCA Foreign Account Tax Compliance Act – a US act aimed at curtailing tax evasion

FOI Freedom of Information

FSA Isle of Man Financial Services Authority

FTTB Fibre To The Business - where the fibre cable goes to a point on a shared property and the other cabling provides the connection to single homes, offices or other spaces.

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Term Definition

FTTH Fibre To The Home - the delivery of a communications signal over optical fibre from the operator's switching equipment all the way to a home

GB/s Gigabytes per second, data transfer rate used in Telecommunications

GDP Gross domestic product - an indicator used to gauge the health of a country's economy

GDPR European General Data Protection Regulation which goes into force on 25 May 2018

GSC Isle of Man Gambling Supervision Commission

GTS The ‘Government Technology Services’ division of the Cabinet Office on the Isle of Man

HFT High frequency trading - algorithmic trading characterized by high speeds, high turnover rates, and high order-to-trade ratios

IBS Jersey’s International Business School

ICA Isle of Man Interception of Communications Act 1998 and/or 2001, as the case requires

ICT Information and communications technology - an extended term for information technology

IGA Intergovernmental Agreement - an international accord or treaty between countries in which each country outlines its role and function under the agreements

IoCC Isle of Man Interception of Communications Commissioner

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Term Definition

IoT Internet of Things - the internetworking of connected or smart devices, vehicles, buildings and other items

IP Intellectual Property - creations of the mind: inventions; literary and artistic works; and symbols, names and images used in commerce

IPv4 Fourth version of the Internet Protocol which still routes most Internet traffic today

IPv6 Most recent version of the Internet Protocol that provides an identification and location system for computers on networks and routes traffic across the Internet

IT Information Technology

KIS-ORCA Kingfisher Information Service - Offshore Renewable & Cable Awareness project is a joint initiative between the European Subsea Cables Association (ESCA), Renewable UK and the Kingfisher Information Service of Seafish

kV Kilovolt - a unit of electric potential

KW Kilowatt – a unit of power

KYC Know Your Customer – the process of identifying and verifying the identity of customers or clients

MB/s Megabytes per second, data transfer rate used in Telecommunications

MDSA Manx Digital Standards Agency – a concept published in a discussion paper in 2015 by MICTA

MEA Manx Electricity Authority, merged with the Isle of Man Water & Sewerage Authority into Manx Utilities Authority from 1 April 2014

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Term Definition

MICTA Manx ICT Association

MONEYVAL Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism - a monitoring body of the Council of Europe

MW Megawatt - a unit of power

OECD Organisation for Economic Co-operation and Development - an intergovernmental economic organisation with 35 member countries, founded in 1960 to stimulate economic progress and world trade

PPP Public–private partnership - a cooperative arrangement between one or more public and private sectors, typically of a long term nature

PwC PricewaterhouseCoopers LLC Isle of Man or, as the context requires, the PricewaterhouseCoopers global network or other memberfirms of the network

ROSE Isle of Man Regulation of Surveillance Etc Act 2006

SOC Security Operations Centre - a centralised unit that deals with security issues on an organizational and technical level

TB/s Terabytes per second, data transfer rate used in Telecommunications

TIA Telecommunications Industry Association

U/L Abbreviation of “upload” - to send data from a remote system

UCM University College Isle of Man

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Term Definition

UK United Kingdom of Great Britain and Northern Ireland

USA United States of America

USP Unique selling point - a factor that an enterprise has that makes it different and or better than other similar enterprises

MUA Manx Utilities Authority – a Statutory Board of the Isle of Man Government sponsored by the Department of Infrastructure

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© 2017 PricewaterhouseCoopers LLC. All rights reserved. “PricewaterhouseCoopers” and “PwC” refers to PricewaterhouseCoopers LLC (a limited liability company in the Isle of Man) or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Please see www.pwc.com/structure for further details.

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Documents

Data proposition strategic review - Isle of Man Government€¦ · · 2018-02-21 Data proposition strategic review Strictly private and confidential 20 January 2017 Isle of Man