Collection and use of air miles (FOI)

Request

Can you please confirm the amount of air miles earnt on all Government of Jersey (GoJ) flights since January 2018 and confirm that individual staff, either permanent or contract, or interim contract, are not benefiting personally from air miles earnt from GoJ expenditure.

Response

The Government of Jersey collect loyalty points from British Airways (BA) flights via a scheme called BA On Business.

For every BA flight booked by the Government Travel Management Company, air miles loyalty points are accrued. This is a scheme for corporate entities only.

From 1 January 2018 to 30 June 2019 473,239 BA on Business points were accrued and 556,600 utilised, to reduce expenditure on long haul flights.

The Government does not collect loyalty point information from other airlines or travel providers.

Information relating to individual staff benefitting from loyalty points is not held in a reportable format for the purposes of the Freedom of Information (Jersey) Law 2011. However, employees must follow the Financial Direction relating to travel, including declarations are required for frequent travellers, as follows:

Financial Direction 2 –

Personal loyalty points

4.10. Where officers accrue personal loyalty points from business travel they will be expected to make these available for future business travel where there are sufficient points to pay for a business trip. These bookings will need to be made outside of HRG but authorisation must still be sought in accordance with paragraph 4.1. Taxes and charges (which cannot be paid for using points) can be reclaimed as expenses.

Officers who travel more than 12 times in a financial year (or more than two international or business-class trips) must include any personal points accrued in the gift and hospitality register for their department.

The Government has not sought to prevent the use of loyalty points being collected, as:

• this can reduce expenditure for the government eg Officers can sometimes access loyalty air fares / lower hotel rates if a member of a loyalty scheme

• additional benefits can be achieved including upgrades to hotel rooms (eg including free wifi), access to lounges where Officers can work, reduction in risk of losing seats on over booked flights, and so on

• compliance is difficult to monitor as information is held within personal accounts and are subject to Data Protections laws

Transactions below the reportable threshold are not recorded and would be deemed as personal information under Article 25 of the Freedom of Information (Jersey) Law 2011.

Article applied

Article 25 Personal information

(1) Information is absolutely exempt information if it constitutes personal data of which the applicant is the data subject as defined in the Data Protection (Jersey) Law 2018.

(2) Information is absolutely exempt information if –

(a) it constitutes personal data of which the applicant is not the data subject as defined in the Data Protection (Jersey) Law 2018; and

(b) its supply to a member of the public would contravene any of the data protection principles, as defined in that Law.

(3) In determining for the purposes of this Article whether the lawfulness principle in Article 8(1)(a) of the Data Protection (Jersey) Law 2018 would be contravened by the disclosure of information, paragraph 5(1) of Schedule 2 to that Law (legitimate interests) is to be read as if sub-paragraph (b) (which disapplies the provision where the controller is a public authority) were omitted.