Three islands, three legal systems, and on each of them a finance industry that asks its suppliers for evidence. For a fund administrator in St Helier, an insurer in St Peter Port or a corporate services provider in Douglas, the hard part of a new app is rarely the screens. It is showing a regulated client, or your own compliance function, how the supplier handles data, access and change.
Data protection, island by island
Jersey
The Data Protection (Jersey) Law 2018 is supervised by the Jersey Office of the Information Commissioner. Transfers of personal data out of Jersey are governed by Articles 66 and 67 and Schedule 3 of that law.
Guernsey
In Guernsey the Data Protection (Bailiwick of Guernsey) Law, 2017 applies, supervised by the Office of the Data Protection Authority.
Isle of Man
The Isle of Man has its Data Protection Act 2018 together with the GDPR and LED Implementing Regulations 2018, and its supervisory authority is the Information Commissioner.
All three hold an adequacy decision from the European Commission, so personal data can flow to them from the EU without extra safeguards. For data flowing the other way, the hosting region of your project is agreed before the build and named in the contract. Your adviser can then test the transfer against the island's own rules, such as Articles 66 and 67 in Jersey, before any client record is stored.
When the client is regulated
Your firm, or your client, may be supervised by the JFSC, the GFSC or the Isle of Man Financial Services Authority. When a compliance team asks for evidence of how a supplier controls access, ships changes and deals with incidents, the vendor security review is built for that moment. For an app you already run, the App Check at $2,000 shows who holds which account and key; in ongoing operation with a technical lead, up to four supplier questionnaires a year are answered as part of the monthly fee.
Apps that fit the islands' industries
- an investor portal for a fund administrator: documents, capital call notices and statements, with access by role
- a client onboarding app for a trust or corporate services provider that collects identity documents once and keeps them out of email
- a claims or policy app for an insurer, including captive insurance, with an audit trail of every decision
Some of these exist already and have lost their developer. In that case the work starts with an App Check, then a takeover from $10,500 or a rescue of the stalled project.
Firms with and without IT staff
A smaller firm often has no developer of its own. It gets one architect who turns the requirement into a written scope, builds the app and hands everything over. If you have an IT team, I can build a specific app, review the architecture or prepare documentation for a supplier assessment, such as a data flow diagram, an access matrix and a documented handover.
Price, currency and tax
A First Version (MVP) from $27,800 in two to four weeks, a market-ready app from $83,300, fixed in US dollars. The islands use sterling; on the Isle of Man the Manx pound is equivalent in value to it. Tax differs by island, so all prices are net and the tax treatment is clarified before contract and stated in the offer.