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Glenn Hamiltonshire
By email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Our Reference :2024/04
Dear Glenn
Freedom of Information (FOI) Request - 2024/05
I refer to your email dated 13 December 2024 seeking access to documents and information
held by the Workplace Gender Equality Agency (the Agency/WGEA) under the
Freedom of
Information Act 1982 (FOI Act).
You have requested access to the following:
This is a Freedom of Information Request for the purposes of the Freedom of
Information Act 1982.
I request access to the Style Guides/Brand Guides/Writing Guides currently used for the
Workplace Gender Equality Agency,
On 8 January 2025, you agreed to a 30-day extension, meaning our decision is due by 12
February 2025.
My decision and reasons for my decision
I am an officer authorised under subsection 23(1) of the FOI Act to make decisions in relation to
FOI requests. This letter sets out the reasons for my decision.
I have identified 2 documents directly within the scope of your request.
Document 1 – WGEA Glossary and Style Guide.
Document 2 – WGEA Visual Brand Guidelines.
After considering the relevant identified documentation, I have decided:
to grant access in part to Document 1 and 2 with relevant exempt matter deleted under
section 47E(d).
I have decided that Document 1 and 2 contains information that is exempt from disclosure
under section 47E(d) of the FOI Act as disclosure would have a substantial adverse effect on
the proper and efficient conduct of the operations of an agency. The section prescribes that:
Conditional exemption
Section 47E – operations of agencies
• Section 47E(d) conditionally exempts a document where disclosure would, or could
reasonably be expected to, prejudice or have a substantial adverse effect on certain identified
agency operations.
• According to paragraph 6.101 of the FOI Guidelines, a reasonable expectation must be more
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than merely an assumption or allegation that damage may occur if the document were to be
released.
Document 1 the Glossary and Style Guide document falls into 4 sections:
• Overview and Style Guide sections (pages 3 and 4) – contains information to create
consistent content. The Agency follows the Australian Government style manu
al Home | Style
Manual that is readily available online.
• Other guidance section (pages 5 to 7) - contains detailed information about specific treatment
and internal decision making on logo use.
Release of the
Other Guidance section could be reasonably expected to provide
information that could compromise the workplace data information and /or undermine
trust in the Agency’s genuine operations.
Document 2 the Visual Brand Guidelines document falls into 4 sections:
• WGEA logo, Typography, Colour palette and Visual Assets sections (pages 3 to 16) –
contains detailed information
about the positioning, spacing, and sizing of the WGEA’s logo, and
other Agency products, graphic devices, and iconography as well as the typeface and colour
palette to be used when creating official documents.
• As the operator of the WGEA Gender Equality reporting platform, security is at the
centre of our operations.
Release of
WGEA Logo Typography, Colour palette and Visual Assets sections could be
reasonably expected to provide information that could allow and individual or organisation to
impersonate the Agency or its products and/or compromise the security of the workplace
employee information and/or undermine trust in the Agency’s genuine operations.
Public interest test Where a document is conditionally exempt, access must be given unless in the
circumstances giving access would, on balance, be contrary to the public interest (s11A(5)
of the FOI Act) and part 6 of the FOI guidelines. One factor in favour of access is that disclosure
could promote the object of the FOI Act.
With regard to the public interest factors set out in the FOI Guidelines, I consider the relevant
factors against disclosure are that disclosure could reasonably be expected to:
- provide information that could allow an individual or organisation to impersonate the
Agency or its products and/or compromise the security of Agency information and/or undermine
trust in the Agency’s genuine operations.
Based on the scope of the request, which is access to the Style Guides/Brand Guides/Writing
Guides currently used for WGEA the factors against disclosure of the conditionally exempt
material,
Other Guidance section, WGEA logo, Typography, Colour palette and Visual
Assets sections outweigh the factor in favour of disclosure.
This is because the public benefit that lies in disclosure is outweighed by the adverse effects
that may occur on workplace employee data collected and the Workplace Gender Equality
Agency’s operational and regulatory responsibilities.
In making my decision, I have had regard to the following:
the terms of your FOI request
the content of the documents that fall within the scope of your request
the relevant provisions of the FOI Act,
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the FOI Guidelines by the Office of the Australian Information Commissioner (OAIC
Guidelines)
Publicly available documents In addition to the internal WGEA documents, WGEA also uses the following publicly
available guides which are intended for all Australian Government departments:
• Australian Government Style Manual
: Australian Government Style Manual
• Australian Government Branding Guidelin
es: Australian Government Branding Guidelines |
PM&C
• Government Writing Handboo
k: Government writing handbook [PDF]
Rights of Review
If you are dissatisfied with this decision, you are entitled to seek a review. Your rights are set out
at
Attachment A to this letter.
If you require clarification of any of the matters discussed in this decision, please contact the
Agency by email at
xxx@xxxx.xxx.xx .
Yours sincerely
Anne Beath
Operations Executive Manager and FOI Officer
12 February 2025
Schedule of documents:
Document 1 – FOI Request 2024.05 (WGEA Glossary and Style Guide)
Document 2 - FOI Request 2024.05 (WGEA Visual Brand Guidelines).
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Attachment A
Rights of Review
Asking for a full explanation of a Freedom of Information decision
If you are dissatisfied with this decision, you may seek review. Before you seek review of an FOI
decision, you may contact us to discuss your request and we will explain the decision to you.
Seeking review of a Freedom of Information decision
If you still believe a decision is incorrect, the
Freedom of Information Act 1982 (FOI Act) gives
you the right to apply for a review of the decision. Under sections 54 and 54L of the Act, you
can apply review of an FOI decision by seeking:
1. an internal review by an different officer of the Australian Public Service Commission,
and/or
2. a external review by the Australian Information Commissioner.
There are no fees applied to either review option.
Applying for a review by an Internal Review Officer
If you apply for internal review, a different decision maker to the Agency delegate who made the
original decision will carry out the review. The Internal Review Officer will consider all aspects of
the original decision and decide whether it should change. An application for internal review
must be made in writing within 30 days of receiving this letter to:
Email:
xxx@xxxx.xxx.xx
Post:
The FOI Officer
Workplace Gender Equality Agency
GPO Box 4917
SYDNEY NSW 2001
You do not need to fill in a form. However, it is a good idea to set out any relevant submissions
you would like the Internal Review Officer to further consider, and your reasons for disagreeing
with the decision.
Applying for external review by the Australian Information Commissioner
If you do not agree with the original FOI decision or the internal review decision, you can ask
the Australian Information Commissioner to review the decision. You have 60 days to apply in
writing for a review by the Office of the Australian Information Commissioner from the date you
received this letter or any subsequent internal review decision.
You can lodge your application:
Online:
www.oaic.gov.au
Post:
Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Email:
xxxxxxxxx@xxxx.xxx.xx
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The OAIC encourage applicants to apply online. Where possible, to assist the OAIC you should
include your contact information, a copy of the related FOI decision and provide details of your
reasons for objecting to the decision.
Complaints to the Information Commissioner and Ombudsman
Information Commissioner
You may complain to the Information Commissioner concerning action taken by an agency in
the exercise of powers or the performance of functions under the FOI Act. There is no fee for
making a complaint. A complaint to the Information Commissioner must be made in writing. The
Information Commissioner's details are:
Telephone:
1300 363 992
Website:
www.oaic.gov.au
Commonwealth Ombudsman
You may complain to the Ombudsman concerning action taken by an agency in the exercise of
powers or the performance of functions under the FOI Act. There is no fee for making a
complaint. A complaint to the Ombudsman may be made in person, by telephone or in writing.
The Ombudsman's contact details are:
Telephone:
1300 362 072
Website:
www.ombudsman.gov.au
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