PO Box 7820, Canberra BC ACT 2610
8 January 2025
Our reference: LEX 82935
Nosey Rosey (Right to Know)
Only by email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Nosey Rosey
Your Freedom of Information Request
I refer to your request, received by Services Australia (the Agency) on 14 December 2024 for
access under the
Freedom of Information Act 1982 (the FOI Act) to the following documents:
Part 1
I seek access to records held by Services Australia that detail who has been granted
access to the Verification of Entitlement (VoE) system within the last ten years, the
reasons such access was permit ed, the date on which each instance of access was
granted, and the scheduled date for any subsequent review or re-approval of that
access. I refer specifically to the VoE functionality administered by Services Australia,
as described on the Centrelink Confirmation eServices (CCeS) page found at:
https:/ aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.servicesa
ustralia.gov.au%2Fcentrelink-confirmation-eservices-
cces&data=05%7C02%7Cfreedomofinformation%40servicesaustralia.gov.au%7C625
c8c9399bf4e48231508dd1bebb000%7C627250e63e294861a084aad68ccfcccc%7C0
%7C0%7C638697421416048358%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1h
cGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyf
Q%3D%3D%7C80000%7C%7C%7C&sdata=ma42%2FcOhyEwdpWW5%2B0fgvJXt
shY%2B0E02C2WZjUebGPA%3D&reserved=0.
I request documents that identify any company or organisation granted access to the
VoE system, along with the name of that company or entity, the reason why access
was granted, the initial date on which that access was approved, and the date when
the approval for that access is next scheduled to be reviewed. Where an individual
has been granted access in their own right, rather than as part of a company or
organisation, I request disclosure of the individual’s name. If this would cause
unreasonable disclosure of personal information, I ask that you consider whether
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PO Box 7820, Canberra BC ACT 2610
identifying the individual by a first name and a role description, or a similar method,
would be feasible while stil satisfying the public interest in understanding who is
permit ed to use the VoE system. I am not seeking any personal contact details or
sensitive personal information about these individuals beyond their names as they
appear in the context of approved users of the VoE system.
Part 2
I also request copies of any documents that outline the policies, procedures, criteria,
or internal guidelines governing how access to the VoE system is approved,
managed, and periodically reviewed. This includes any instructions to staff,
procedural manuals, or policy statements that describe the processes by which
certain entities or individuals become authorised users, the factors considered in
approving or denying access requests, the review mechanisms that are in place, and
the intervals at which access privileges are re-evaluated.
If the requested information is stored in a database or can be readily extracted from
electronic records, I request that you provide it in a machine-readable format, such as
CSV or Excel, where that is reasonably practicable. If the records are contained in
written documents, I ask that you provide scanned copies or PDFs. I understand that
some documents may contain information that is not relevant to my request, and I am
wil ing to receive redacted versions of documents if it assists in processing this
request in a timely manner. Should you consider that identifying details of individuals
require redaction to comply with the FOI Act, I ask that you consult with me under
section 24AB before making a decision, so that we may discuss whether a refinement
of the request is possible.
I believe that the disclosure of these documents serves the public interest, as it wil
enable greater transparency and accountability regarding how access to the VoE
system is managed. This system affects a wide range of stakeholders, and
understanding who has been granted permission to use it, as well as the reasons for
doing so, contributes to the public’s confidence that personal information managed by
Services Australia is properly safeguarded and that access is granted for legitimate
purposes only.
Note: For ease of consulting with you, I have separated your request into Part 1 and Part 2.
Your request involves too much work for the Agency
Your Freedom of Information (FOI) request covers a wide range of documents. We are
asking you to revise your request to give us more specific details about the information you
are after because of the amount of work involved for the Agency.
If you decide not to make any revisions, I will have to refuse your FOI request as a 'practical
refusal reason' exists.
For a more detailed explanation of what this means see
Attachment A.
How to send us a 'revised request'
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PO Box 7820, Canberra BC ACT 2610
Before I make a final decision on your request, you can narrow the size of your original
request and submit a revised request.
Within the next 14 days you must do one of the following, in writing:
• withdraw the request
• make a revised request, or
• tell us you do not want to revise your request.
Your response wil be expected by
22 January 2025. If you do not contact us during the 14
day consultation period, your matter wil be taken as withdrawn by operation of the FOI Act.
See
Attachment A for relevant sections of the FOI Act.
If you decide to make a revised request, you should be specific about the documents you
want. This could help the Agency find the documents in less time and use fewer resources to
process them.
We have 30 days to give you a decision about your request, however the time taken to
consult with you now is not included in this 30 day time period.
Contact officer
I am the contact officer for your request. During the consultation period you are welcome to
ask for my help in revising your request. You can contact me:
• via email to arrange a phone call, by providing a contact number and advising of a
suitable time
• in writing to the address at the top of this letter, or
• via email to xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx
Note: When you contact us, please quote the reference number
FOI LEX 82935.
Further assistance
If you have any questions, please email xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx.
Yours sincerely
Cherie
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Reviews Branch | Legal Services Division
Services Australia
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PO Box 7820, Canberra BC ACT 2610
Attachment A
What I took into account
You requested access under the FOI Act to the documents outlined on Page 1 and 2 of this
letter.
Because of the amount of work involved for the Agency, under sections 24AA(1)(a)(i), 24 and
24AA(2) of the FOI Act I intend to refuse your FOI request as a 'practical refusal reason'
exists. Under the FOI Act, the practical refusal reason is that processing your request 'would
substantially and unreasonably divert the resources' of the Agency.
To assist you, I liaised with the relevant business area of the Agency that would hold the types
of documents and information you are seeking. I am advised the following:
Part 1 of your request
I seek access to records held by Services Australia that detail who has been granted access
to the Verification of Entitlement (VoE) system within the last ten years, the reasons such
access was permitted, the date on which each instance of access was granted, and the
scheduled date for any subsequent review or re-approval of that access.
I am advised the information you requested is not captured in an existing document or able
to be produced via an automated process. Therefore, manual interrogation of each business
/ organisation record would be required to review, analyse, extract and collate this
information.
As there are over 3,000 businesses / organisations, with an estimated time of 10 minutes to
interrogate each record, we estimate it would take more than 500 hours to produce a
document.
Additionally, the Agency would need to consider formally consulting with each third party
under section 27 of the FOI Act, about the potential release of their information (i.e. their
name). Based on a conservative estimate of 30 minutes to prepare and send individual
consultation notices and to consider responses from each of the 3,000 third parties, we
estimate the consultation process alone would take in excess of 1,500 hours.
In conclusion, Part 1 of your request is too much work for the Agency to process and a
'practical refusal reason' exists.
Part 2 of your request
I also request copies of any documents that outline the policies, procedures, criteria, or
internal guidelines governing how access to the VoE system is approved, managed, and
periodically reviewed. This includes any instructions to staff, procedural manuals, or policy
statements that describe the processes by which certain entities or individuals become
authorised users, the factors considered in approving or denying access requests, the review
mechanisms that are in place, and the intervals at which access privileges are re-evaluated.
I am advised that some documents pertaining to this part of your request are already publicly
available. These documents can be accessed at the following links:
• CCeS policy, terms and procedural guide for businesses
https:/ www.servicesaustralia.gov.au/centrelink-confirmation-eservices-policy-terms-
and-procedural-guide?context=23236
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PO Box 7820, Canberra BC ACT 2610
You can access these documents via the link above or by visiting the Agency’s
website at www.servicesaustralia.gov.au and navigating to
Businesses > Top
payments > Centrelink Confirmation eServices (CCes) for businesses > How to apply
> Policy, terms and guides
• Operational Blueprint Centrelink Confirmation eServices 101-09010000
https:/ operational.servicesaustralia.gov.au/public/Pages/additional-products-and-
services/101-09010000-05.html
• Operational Blueprint Registration for Income Management deductions, Electronic
Verification of Rent (EVoR) or Centrelink Confirmation eServices (CCeS) 101-
09010040
https:/ operational.servicesaustralia.gov.au/public/Pages/additional-products-and-
services/101-09010040-01.html
Should you wish to revise your request, we ask that you review the publicly available material
first and revise your request to only be for any additional documents you require.
Additional Information
The Agency does not have a ‘Verification of Entitlement’ system. However, we have
interpreted your FOI request to be in relation to Centrelink Confirmation eServices (CCeS),
noting the link provided in your request relates to CCeS information on the Agency’s website.
Assistance with your request
To assist you in revising your request, and with the view of removing the practical refusal
reason, please consider the following:
• Removing Part 1 from your request (as this part would require an unreasonable
diversion of resources to process), and
• Reviewing the publicly available material for Part 2 and revising your request to only
be for any additional documents of interest. Please be specific about the subject matter
or content of the documents. For example, the specific aspects of the CCeS program /
process that are of interest.
If you do not revise your request, I intend to refuse your FOI request as a 'practical refusal
reason' exists under sections 24AA(1)(a)(i), 24 and 24AA(2) of the FOI Act. The practical
refusal reason is that processing your request would substantially and unreasonably divert the
resources of the agency from its other operations.
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PO Box 7820, Canberra BC ACT 2610
Relevant sections of the Freedom of Information Act 1982
Section 24AA(1)(a)(i) of the FOI Act provides a practical refusal reason exists in relation to a
FOI request if the work involved in processing the request would substantially and
unreasonably divert the resources of the Agency from its other operations.
Section 24AA(2) of the FOI Act sets out certain factors which the Agency must consider
when determining whether providing access in relation to a request would substantially and
unreasonably divert the Agency's resources. The Agency must specifically have regard to the
resources which would have to be used for:
• identifying, locating or col ating the documents within Services Australia's filing
system
• deciding whether to grant, refuse or defer access to a document to which the request
relates, or to grant access to an edited copy of such a document, including resources
that would have to be used for examining the document or consulting in relation to the
request
• making a copy, or an edited copy, of the document, and
• notifying any interim or final decision on the request.
Section 24AB(6) of the FOI provides the applicant must, before the end of the consultation
period, do one of the following, by written notice to the Agency a or the Minister:
• withdraw the request,
• make a revised request, or
• indicate that the applicant does not wish to revise the request.
Section 24AB(7) of the FOI Act provides the request is taken to have been withdrawn at the
end of the consultation period if:
• the applicant does not consult the contact person during the consultation period in
accordance with the notice, or
• the applicant does not do one of the things mentioned in subsection (6) before the end
of the consultation period.
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