LEX 32385 decision.pdf

Ref: LEX-32385
Information Requests
Via email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear CR
Decision on your Freedom of Information request
I refer to your revised request, received by the Department of Agriculture, Fisheries and
Forestry (department) on 8 October 2024 for access under the Freedom of Information Act 1982
(Cth) (FOI Act) to the following documents:
‘1. The most recent 30 notices of charges issued to FOI applicants.
For each of these 30 requests, if applicable, please also provide:
2. Any subsequent decisions regarding charges following applicant contention.
3. Any subsequent decisions regarding charges following internal or external review.
The time period for my request is from 1 July 2022 to 1 October 2024.
Please exclude the following information:
i) Personal information of FOI applicants, including supporting evidence or details of
personal circumstances in a financial hardship contention.
ii) Emails that attached the charges notices/decision letters.’
On 18 October 2024, you further revised the scope of your request to exclude personal
information and business information of third parties, as defined by the FOI Act.
My decision
The department holds 37 documents (totalling 135 pages) that relate to your request.
I have decided to grant you part access to 37 documents (documents 1-37) with some of the
content removed.
I have decided that certain parts of documents that you have requested are exempt under the
FOI Act as they contain information which would, or could reasonably be expected to, have a
substantial adverse effect on the proper and efficient conduct of the operations of an agency and
it would be against the public interest to disclose this information (section 47E(d)).
I have decided that certain parts of documents that you have requested are exempt under the
FOI Act as the information is personal information about other people, the disclosure of which
would be contrary to the public interest (section 47F(1)).
On 2 October 2024 the department acknowledged your request and advised you that we would
not include personal details about our staff. You did not contact the department again about this.
Staff details and information that is outside the scope of your request (including, as you have
outlined above, personal information of FOI applicants and any emails that attached charges
T +61 2 6272 3933
Agriculture House
GPO Box 858
agriculture.gov.au
F +61 2 6272 5161
70 Northbourne Avenue
Canberra ACT 2601
ABN 34 190 894 983
Canberra ACT 2601

notices/decision letters, as well as business information of FOI applicants) have therefore been
deleted in accordance with section 22(1) of the FOI Act.
Please see the schedule at Attachment A to this letter for a detailed list of the documents and
the reasons for my decision.
How we will send your documents to you
The documents are attached.
You can ask for a review of my decision
If you wish to seek an internal review, you must apply to the department within 30 days after
the day you are notified of this decision. An application for internal review must be made in
writing by post to the FOI Officer or email to xxx@xxx.xxx.xx.
Alternatively, you may apply directly to the Office of the Australian Information Commissioner
(OAIC) to review my decision. An application for review by the Information Commissioner must
be made in writing within 60 days after the day you are notified of this decision. You may apply
for an OAIC review through the following link. You can also make a complaint to the Information
Commissioner if you have concerns about how the department handled your request.
You can find information about requesting a review, making a complaint, and other information
about FOI on the OAIC website www.oaic.gov.au or phone the OAIC on 1300 363 992.
Further assistance
If you have any questions, please email xxx@xxx.xxx.xx.
Yours sincerely
Annabelle Alexander
General Counsel
Information, Litigation, Employment & Commercial Legal Branch
31 October 2024
2

Attachment A
LIST OF DOCUMENTS FOR RELEASE
LEX-32385
Doc Pages
Date
Description
Decision
Exemption
Comments
No.
1.
1-3
13/09/2024 Charges notice
Release in part
s 47E(d)
Page 1: information in relation to certain
operations of agencies under section
47E(d).
Pages 1 and 3: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
2.
4-7
11/09/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 4: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 7: personal information exempt
under s 47F(1).
Page 4: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).
T +61 2 6272 3933
Agriculture House
GPO Box 858
agriculture.gov.au
F +61 2 6272 5161
70 Northbourne Avenue
Canberra ACT 2601
ABN 34 190 894 983
Canberra ACT 2601

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
3.
8-10
30/08/2024 Charges notice
Release in part
s 47E(d)
Page 8: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 10: personal information exempt
under s 47F(1).
Page 8 : staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).
4.
11-16
20/09/2024 Charges decision
Release in part
s 47E(d)
Pages 11, 13, 14, 15 and 16: information in
relation to certain operations of agencies
under section 47E(d).
Pages 11, 12, and 15: staff details and
material which is out of scope of the
request deleted under s 22(1)(a)(ii) (out
of scope).
5.
17-19
27/08/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 17: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 19: personal information exempt
under s 47F(1).
Page 17: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
6.
20-23
14/08/2024 Charges and consultation notice
Release in part
s 47E(d)
Pages 20 and 21: information in relation to
certain operations of agencies under
section 47E(d).
Pages 20 and 23: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
7.
24-26
05/08/2024 Charges notice
Release in part
s 47E(d)
Page 24: information in relation to certain
operations of agencies under section
47E(d).
Pages 24 and 26: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
8.
27-33
03/09/2024 Charges decision
Release in part
s 47E(d)
Pages 27, 30, 31, 32 and 33: information in
relation to certain operations of agencies
under section 47E(d).
Pages 27 and 29: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
9.
34-36
02/08/2024 Charges notice
Release in part
s 47E(d)
Pages 34: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 36: personal information exempt
under s 47F(1).
Page 34: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
10. 37-41
02/09/2024 Charges decision
Release in part
s 47E(d)
Pages 37, 39, 40 and 41: information in
s 47F(1)
relation to certain operations of agencies
under section 47E(d).
Page 38: personal information exempt
under s 47F(1).
Page 37: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).
11. 42-44
19/07/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 42: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 44: personal information exempt
under s 47F(1).
Page 42: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).
12. 45-47
24/07/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 45: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 47: personal information exempt
under s 47F(1).
Page 45: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
13. 48-53
19/08/2024 Charges decision
Release in part
s 47E(d)
Pages 48, 50, 51, 52 and 53: information in
s 47F(1)
relation to certain operations of agencies
under section 47E(d).
Page 49: personal information exempt
under s 47F(1).
Pages 48 and 52: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
14. 54-56
24/07/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 54: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 56: personal information exempt
under s 47F(1).
Page 54: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).
15. 58-59
19/07/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 57: information in relation to certain
operations of agencies under section
47E(d).
Pages 57 and 59: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
16. 60-62
18/07/2024 Charges notice
Release in part
s 47E(d)
Page 60: information in relation to certain
operations of agencies under section
47E(d).
Pages 60 and 62: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
17. 63-66
05/07/2024 Charges notice
Release in part
s 47E(d)
Page 63: information in relation to certain
operations of agencies under section
47E(d).
Pages 63 and 66: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
18. 67-70
18/06/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 67: information in relation to certain
operations of agencies under section
47E(d).
Pages 67 and 70: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
19. 71-74
04/06/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 71: information in relation to certain
operations of agencies under section
47E(d).
Pages 71 and 74: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
20. 75-78
28/05/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 75: information in relation to certain
operations of agencies under section
47E(d).
Pages 75 and 78: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
21. 79-81
17/05/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 79: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 81: personal information exempt
under s 47F(1).
Page 79: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).
22. 82-87
15/07/2024 Charges decision
Release in part
s 47E(d)
Pages 82, 84, 85 and 86: information in
s 47F(1)
relation to certain operations of agencies
under section 47E(d).
Page 83: personal information exempt
under s 47F(1).
Page 82: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
23. 88-90
15/05/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 88: information in relation to certain
operations of agencies under section
47E(d).
Pages 88 and 90: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
24. 91-93
25/06/2024 FOI decision
Release in part
s 47E(d)
Pages 91 and 92: information in relation to
certain operations of agencies under
section 47E(d).
Pages 91-93: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
25. 94-96
15/05/2024 Charges notice
Release in part
s 47E(d)
Page 94: information in relation to certain
operations of agencies under section
47E(d).
Pages 94 and 96: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
26. 97-99
14/05/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 97: information in relation to certain
s 47F(1)
operations of agencies under section
47E(d).
Page 99: personal information exempt
under s 47F(1).
Page 97: staff details and material which is
out of scope of the request deleted under s
22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
27. 100-102
05/04/2024 Charges notice
Release in part
s 47E(d)
Page 100: information in relation to
s 47F(1)
certain operations of agencies under
section 47E(d).
Page 102: personal information exempt
under s 47F(1).
Page 100: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).
28. 103-106
13/03/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 103: information in relation to
s 47F(1)
certain operations of agencies under
section 47E(d).
Page 106: personal information exempt
under s 47F(1).
Page 103: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).
29. 107-109
05/03/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 107: information in relation to
certain operations of agencies under
section 47E(d).
Pages 107 and 109: staff details and
material which is out of scope of the
request deleted under s 22(1)(a)(ii) (out
of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
30. 110-113
04/03/2024 Charges and consultation notice
Release in part
s 47E(d)
Pages 110 and 111: information in relation
s 47F(1)
to certain operations of agencies under
section 47E(d).
Page 113: personal information exempt
under s 47F(1).
Page 110: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).
31. 114-116
20/02/2024 Charges notice
Release in part
s 47E(d)
Page 114: information in relation to
certain operations of agencies under
section 47E(d).
Pages 114 and 116: staff details and
material which is out of scope of the
request deleted under s 22(1)(a)(ii) (out
of scope).
32. 117-120
19/02/2024 Charges and consultation notice
Release in part
s 47E(d)
Page 117: information in relation to
certain operations of agencies under
section 47E(d).
Pages 117 and 120: staff details and
material which is out of scope of the
request deleted under s 22(1)(a)(ii) (out
of scope).

Doc  Pages
Date
Description
Decision
Exemption
Comments
No.
33. 121-123
01/05/2024 FOI decision
Release in part
s 47E(d)
Page 121: information in relation to
certain operations of agencies under
section 47E(d).
Pages 121-123: staff details and material
which is out of scope of the request
deleted under s 22(1)(a)(ii) (out of scope).
34. 124-126
12/02/2024 Charges notice
Release in part
s 47E(d)
Page 124: information in relation to
s 47F(1)
certain operations of agencies under
section 47E(d).
Page 126: personal information exempt
under s 47F(1).
Page 124: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).
35. 127-129
11/01/2024 Charges notice
Release in part
s 47E(d)
Page 127: information in relation to
s 47F(1)
certain operations of agencies under
section 47E(d).
Page 129: personal information exempt
under s 47F(1).
Page 127: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).

Doc Pages
Date
Description
Decision
Exemption
Comments
No.
36. 130-132
11/12/2023 Charges notice
Release in part
s 47E(d)
Page 130: information in relation to
s 47F(1)
certain operations of agencies under
section 47E(d).
Page 132: personal information exempt
under s 47F(1).
Page 130: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).
37. 133-135
04/12/2023 Charges notice
Release in part
s 47E(d)
Page 133: information in relation to
s 47F(1)
certain operations of agencies under
section 47E(d).
Page 135: personal information exempt
under s 47F(1).
Page 133: staff details and material which
is out of scope of the request deleted
under s 22(1)(a)(ii) (out of scope).

REASONS FOR DECISION
What you requested
On 1 October 2024 you made the following request (original request):
‘I request access to the following documents under the Freedom of Information Act
1982:
1. The most recent 30 notices of charges issued to FOI applicants.
For each of these 30 requests, if applicable, please also provide:
2. Any subsequent decisions regarding charges following applicant contention.
3. Any subsequent decisions regarding charges following internal or external review.
Please exclude the following information:
i) Personal information of FOI applicants.’
Request consultation process
On 2 October 2024, the department acknowledged your original request and advised you that
we would not include personal details about our staff. You did not contact the department again
about this. Staff details have therefore been deleted in accordance with section 22(1) of the FOI
Act.
On 8 October 2024, you revised the scope of your request to be:
‘1. The most recent 30 notices of charges issued to FOI applicants.
For each of these 30 requests, if applicable, please also provide:
2. Any subsequent decisions regarding charges following applicant contention.
3. Any subsequent decisions regarding charges following internal or external review.
The time period for my request is from 1 July 2022 to 1 October 2024.
Please exclude the following information:
i) Personal information of FOI applicants, including supporting evidence or details of
personal circumstances in a financial hardship contention.
ii) Emails that attached the charges notices/decision letters.’
On 18 October 2024, you further revised the scope of your request to exclude personal
information and business information of third parties, as defined by the FOI Act.
On 23 October 2024, you sent further correspondence regarding the scope of your request:
‘If a preliminary charge notice or decision of a charge is sent via the body of an email (as
opposed to an email attachment) I wish to access a copy of that email, as well as the
applicant's contention reasons’.
On 24 October 2024, the department acknowledged this correspondence and confirmed:
‘If the information within scope of your revised request dated 8 October 2024 was sent
via the body of an email as opposed to an email attachment, we will include this email as
within the scope of your request’.
In relation to accessing the ‘applicant’s contention reasons’, I consider this is broader than the
scope of the original request, and therefore do not consider your request to be revised to include
these documents. However, where the applicant’s contention reasons are discussed in a
document that does fall within the scope of your request, for example, a charges decision, this
has been taken to be part of the scope of your request.

In relation to documents 24 and 33, I consider that Attachment A to those decisions relates to
the decision on documents the subject of the original FOI request, rather than to the decision on
charges. This is why Attachment A to those documents has not been included.
What I took into account
In reaching my decision, I took into account:
 your original request dated 1 October 2024, your revised request of 8 October 2024, and
your further revision of the request received on 18 October 2024;
 correspondence between you and the department on 23 and 24 October 2024;
 the documents that fall within the scope of your request;
 consultation with third parties about documents which contain information concerning
them;
 information about:
o
the nature of the documents; and
o
the department’s operating environment and functions;
 guidelines issued by the Australian Information Commissioner under section 93A of the
FOI Act (Guidelines);
 the FOI Act.
Reasons for my decision
I am authorised to make decisions under section 23(1) of the FOI Act.
I have decided that certain parts of documents that you requested are exempt under the FOI Act.
My findings of fact and reasons for deciding that an exemption applies to those documents are
discussed below.
Section 47E(d) of the FOI Act – certain operations of agencies
I have applied the conditional exemption in section 47E(d) to parts of documents 1 to 37.
Section 47E(d) of the FOI Act relevantly provides:
A document is conditionally exempt if its disclosure under this Act would, or could
reasonably be expected to, do any of the following:
…
(d) have a substantial adverse effect on the proper and efficient conduct of the
operations of an agency.
Paragraph 6.115 of the Guidelines provides, in relation to section 47E(d) of the FOI Act, that:

The predicted effect must bear on the agency’s ‘proper and efficient’ operations, that is,
the agency is undertaking its expected activities in an expected manner. Where disclosure
of the documents reveals unlawful activities or inefficiencies, this element of the
conditional exemption will not be met and the conditional exemption will not apply.
The documents are charges notifications, charges decisions, and FOI decisions.  Parts of the
documents contain a description of the scope of the request made by the applicant under the FOI
Act. Some of the documents also contain a discussion of the submissions made by an applicant in
challenging charges issued by the department. I am satisfied that the material in the documents
relates to the department’s function of processing FOI requests consistent with the FOI Act.
I consider that the disclosure of this information would, or could reasonably be expected to have
a substantial adverse effect on the proper and efficient conduct of this function. Specifically, in
relation to the scope of the request, the disclosure would be inconsistent with the framework
established by the FOI Act that allows applicants to make a request to an agency on a
confidential basis. The name of the applicant and scope of the request made by the applicant is
to be kept confidential. While the disclosure log provisions provide for the publication of
documents released subject to exceptions (s 11C), only a short description of the documents is
required on the disclosure log and not the full scope of the request itself. If the full scope of
requests were made publicly available this may have a freezing effect on applicants being willing
to use the freedom of information process to obtain government documents and would frustrate
the purposes of the FOI Act, being to facilitate public access to information.
In relation to the applicant’s reasons for challenging a charges contention decision, the FOI Act
provides a confidential framework in which an applicant may challenge a charge issued by an
agency. If an applicant’s reasons for contesting a charge were made publicly available this may
have a freezing effect on applicants being willing to put forward certain arguments and
challenge the charges issued by agencies under the freedom of information process.
On this basis, I have decided that the information included in the documents referred to in the
Schedule is conditionally exempt under section 47E(d) of the FOI Act.
Public interest considerations
Section 11A(5) of the FOI Act provides:
'The agency or Minister must give the person access to the document if it is conditionally
exempt at a particular time unless (in the circumstances) access to the document at that
time would, on balance, be contrary to the public interest.'
When weighing up the public interest for and against disclosure under section 11A(5) of the FOI
Act, I have taken into account relevant factors in favour of disclosure.  In particular, I have
considered the extent to which disclosure would promote the objects of the FOI Act.
I have also considered the relevant factors weighing against disclosure, indicating that access
would be contrary to the public interest. In particular, I have considered the extent to which
disclosure could reasonably be expected to:
 prejudice the department’s ability to process FOI requests consistent with the FOI Act;
 prejudice third parties’ willingness to make FOI requests; and
 prejudice third parties’ willingness to contend charges decisions.

Based on the above factors, I have decided that in this instance, the disclosure of parts of the
documents would, on balance, be contrary to the public interest.
I have not taken into account any of the irrelevant factors set out in section 11B(4) of the FOI Act
in making this decision.
In summary, I am satisfied that parts of documents as set out in the Schedule, are conditionally
exempt under section 47E(d) of the FOI Act. Furthermore I have decided that on balance it
would be contrary to the public interest to release this information. Accordingly I have decided
not to release the documents in full to you.
Section 47F of the FOI Act - unreasonable disclosure of personal information
I have applied the conditional exemption in section 47F(1) to parts of documents 2, 3, 5, 9, 10,
11, 12, 13, 14, 21, 22, 26, 27, 28, 30, 34, 35, 36, and 37.
Section 47F of the FOI Act relevantly provides:
'(1)  A document is conditionally exempt if its disclosure under this Act would involve the
unreasonable disclosure of personal information about any person (including a
deceased person).
(2)  In determining whether the disclosure of the document would involve the
unreasonable disclosure of personal information, an agency or Minister must have
regard to the following matters:
(a)  the extent to which the information is well known;
(b)  whether the person to whom the information relates is known to be (or to have
been) associated with the matters dealt with in the document;
(c)  the availability of the information from publicly accessible sources;
(d)  any other matters that the agency or Minister considers relevant.'
Personal Information
The term 'personal information' is defined as follows:
'...information or an opinion about an identified individual, or an individual who is
reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.'
Paragraph 6.125 of the Guidelines provides:
'Personal information can include a person's name, address, telephone number, date of
birth, medical records, bank account details, taxation information and signature.'
I find that documents 2, 3, 5, 9, 10, 11, 12, 13, 14, 21, 22, 26, 27, 28, 30, 34, 35, 36, and 37 contain
personal information of other people. This includes their signatures.
Whether disclosure is 'unreasonable'

In addition to the factors specified in section 47F(2) of the FOI Act, paragraph 6.133 of the
Guidelines provides:
'The personal privacy exemption is designed to prevent the unreasonable invasion of
third parties' privacy.  The test of 'unreasonableness' implies a need to balance the public
interest in disclosure of government-held information and the private interest in the
privacy of individuals.'
I am satisfied that the disclosure of the third party personal information would be unreasonable
for the following reasons:
 you do not have the consent from this individual for the release of their personal
information;
 the information is private and not available in full or in part from publicly-accessible
sources; and
 the identity of the individual concerned is readily apparent or could be easily
ascertained.
On this basis, I have decided that the personal information included in the documents as
referred to in the Schedule is conditionally exempt under section 47F(1) of the FOI Act.
Public interest considerations
Section 11A(5) of the FOI Act provides:
'The agency or Minister must give the person access to the document if it is conditionally
exempt at a particular time unless (in the circumstances) access to the document at that
time would, on balance, be contrary to the public interest.'
When weighing up the public interest for and against disclosure under section 11A(5) of the FOI
Act, I have taken into account relevant factors in favour of disclosure.  In particular, I have
considered the extent to which disclosure would:
 promote the objects of the FOI Act.
I have also considered the relevant factors weighing against disclosure, indicating that access
would be contrary to the public interest. In particular, I have considered the extent to which
disclosure could reasonably be expected to:
 prejudice an individual's right to privacy.
 adversely affect or harm the interests of an individual, specifically that the release of a
person’s signature may increase the risk of the person being subjected to fraud including
identity fraud.
Based on the above factors, I have decided that in this instance, the disclosure of the documents
would, on balance, be contrary to the public interest.
I have not taken into account any of the irrelevant factors set out in section 11B(4) of the FOI Act
in making this decision.
As identified in the Schedule, I have deleted the exempt information in the documents and
released the remaining material in accordance with section 22(1) of the FOI Act.

Summary of my decision
In conclusion, I have decided to:
 grant you part access to 37 documents.
I have decided that:
 documents 1 to 37 are conditionally exempt, in part, under section 47E(d) of the FOI Act,
and disclosure would be contrary to the public interest for the purposes of section
11A(5).
 Documents 2, 3, 5, 9, 10, 11, 12, 13, 14, 21, 22, 26, 27, 28, 30, 34, 35, 36, and 37 are
conditionally exempt, in part, under section 47F(1) of the FOI Act, and disclosure would
be contrary to the public interest for the purposes of section 11A(5).