If not delivered return to PO Box 7820 Canberra BC ACT 2610
14 January 2025
Our reference: LEX 82935
Nosey Rosey (Right to Know)
Only by email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Nosey Rosey
Decision on 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
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.
PAGE 1 OF 9
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 processing, I have separated your request into Part 1 and Part 2.
My decision
I have decided to refuse your request under section 24(1) of the FOI Act because a 'practical
refusal reason' stil exists under section 24AA of the FOI Act. I am satisfied that the work
involved in processing your request would substantially and unreasonably divert the
resources of the Agency from its other operations as specified in section 24AA(1)(a)(i) of the
FOI Act.
The reasons for my decision, including the relevant sections of the FOI Act, are set out in
Attachment A.
You can ask for a review of our decision
If you disagree with the decision you can ask for a review. There are two ways you can do
this. You can ask for an internal review from within the agency, or an external review by the
Office of the Australian Information Commissioner. See
Attachment B for more information
about how to request a review.
PAGE 2 OF 9
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
PAGE 3 OF 9
If not delivered return to PO Box 7820 Canberra BC ACT 2610
Attachment A
REASONS FOR DECISION
What you requested
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
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
PAGE 4 OF 9
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
willing 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.
Request consultation process
On 8 January 2025, I wrote to you providing a notice of intention to refuse your request under
section 24AB(2) of the FOI Act as your request was too big to process. I gave you an
opportunity to consult with the Agency to revise your request so as to remove the practical
refusal reason.
I advised that Part 1 of your request was too much work for the Agency to process, as 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 relation to Part 2 of your request, I provided links to publicly available documents.
Specifically, the CCeS policy, terms and procedural guide for businesses, and two Operational
Blueprint documents. While Part 2 of your request is not considered voluminous in itself; I
asked you to consider the publicly available information provided and revise Part 2 to
documents of interest that are not already covered by the publicly available information.
I also explained that 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.
PAGE 5 OF 9
On 9 January 2025, you advised that you did not wish to revise your request.
What I took into account
In reaching my decision I took into account:
• your request dated 14 December 2024
• your response to the consultation notice received on 9 January 2025
• the information requested and documents that fall within the scope of your request
• consultations with Agency officers about:
o the nature of the documents
o the Agency's operating environment and functions
• guidelines issued by the Australian Information Commissioner under section 93A of
the FOI Act (the Guidelines), and
• the FOI Act.
Reasons for my decisions
I am authorised to make decisions under section 23(1) of the FOI Act.
Following the request consultation process outlined above, in accordance with section 24AB
of the FOI Act, I am satisfied that a practical refusal reason stil exists in that the work
involved in processing your request would substantially and unreasonably divert the
resources of the Agency from its other operations. The reasons for my decision, including
consideration of the factors I am required to take into account in section 24AA(2), are
outlined below.
Practical refusal reason
Section 24AA of the FOI Act provides that a practical refusal reason exists in relation to a
request for a document if the work involved in processing the request would:
'substantially and unreasonably divert the resources of the agency from its other
operations'.
The word 'substantial' has previously been interpreted to mean severe, of some gravity, large
or weighty or of considerable amount, real or of substance and not insubstantial or of
nominal consequence. The use of the word 'unreasonable' has been interpreted to mean
that a weighing of all relevant considerations is needed, including the extent of the resources
needed to meet the request.
In determining whether processing the request would substantially and unreasonably divert
the Agency's resources, section 24AA(2) requires me to have regard to the resources that
would have to be used for the following:
• identifying, locating or col ating the documents within the filing system of the Agency
• deciding whether to grant, refuse or defer access to a document including resources
used for examining the document and consulting with any person or body in relation
to the request
• making a copy or an edited copy of the document, and
• notifying of any decision on the request.
PAGE 6 OF 9
In accordance with section 24AA(3), I did not consider your reasons for requesting access to
the documents.
Why your request is substantial
In making my decision I estimate that Part 1 of your request alone would require more than
2,000 hours of processing time (excluding the time required to review the documents, mark
the documents with redactions (i.e. sensitive material that meets an exemption reason under
the FOI Act) and decision-making. This calculation is based on the time and resources
required to produce a document with the information you requested (500 hours), in addition
to conducting third party consultations with more than 3,000 organisations / businesses
(1,500 hours).
Please note: The names of organisations / businesses who are approved for CCeS are not
publicly available. Given the risk that the Agency's operations may be prejudiced if full and
proper consultations were not undertaken, I am satisfied that consultation is required with all
of those parties prior to releasing material related to them.
Why your request is unreasonable
For the purposes of deciding whether your request would unreasonably divert the resources
of the Agency from its other operations, I considered whether the substantial resource
burden would be unreasonable having regard to the following:
• one individual would be required to spend over 2,000 hours processing your request
(this is a conservative estimate that excludes the time required to process Part 2 of
your request, reviewing all documents, redacting sensitive material and decision-
making), and
• the Agency has provided you with some publicly available information that would
address some aspects of Part 2 of your request.
As discussed above, I have estimated that your request would take approximately 2,000
hours to process. The Agency receives more than 4,500 FOI requests per year, the majority
of which are requests from people seeking their own information. I am satisfied that the
processing of your request would divert Agency resources from the processing of these other
requests, as well as business-as-usual activities providing services to the Australian public.
Conclusion
In summary I am satisfied that the work involved in processing your request would substantially
and unreasonably divert the resources of the Agency from its other operations, namely the
processing of other FOI requests and the delivery of social services to all Australians more
broadly.
I have found that a practical refusal reason exists in relation to your request for access to the
documents. Accordingly, I have decided to refuse your request under section 24(1) of the FOI
Act.
PAGE 7 OF 9
If not delivered return to PO Box 7820 Canberra BC ACT 2610
Attachment B
INFORMATION ON RIGHTS OF REVIEW
FREEDOM OF INFORMATION ACT 1982
Asking for a ful explanation of a freedom of information (FOI) decision
Before you ask for a formal review of a FOI decision, you can contact us to discuss your
request. We wil explain the decision to you. This gives you a chance to correct
misunderstandings.
Asking for a formal review of an FOI decision
If you stil 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
FOI Act, you can apply for a review of an FOI decision by:
1. an Internal Review Of icer in Services Australia (the Agency), and/or
2. the Australian Information Commissioner.
Applying for an internal review by an Internal Review Officer
If you apply for internal review, a dif erent decision maker to the Agency delegate who made
the original decision wil carry out the review. The Internal Review Of icer wil consider all
aspects of the original decision and decide whether it should change. An application for
internal review must be:
• made in writing
• made within 30 days of receiving this letter
• sent to the address at the top of the first page of this letter, or by email to
xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx
Note: You do not need to fil 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 decision or the internal review decision, you can ask the
Australian Information Commissioner to review the decision.
If you do not receive a decision from an Internal Review Of icer in the Agency within 30 days
of applying, you can ask the Australian Information Commissioner for a review of the original
FOI decision.
You wil have 60 days to apply in writing for a review by the Australian Information
Commissioner.
PAGE 8 OF 9
You can lodge your application:
Online:
www.oaic.gov.au
Post:
Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Email:
xxxxx@xxxx.xxx.xx
Note: The Of ice of the Australian Information Commissioner generally prefers FOI
applicants to seek internal review before applying for external review by the Australian
Information Commissioner.
Important:
• If you are applying online, the application form the 'FOI Review Form' is available at
Information Commissioner Review Application form
• If you have one, you should include with your application a copy of the Agency's
decision on your FOI request
• Include your contact details
• Set out your reasons for objecting to the Agency's decision.
Complaints to the Australian Information Commissioner and Commonwealth
Ombudsman
Australian Information Commissioner
You may complain to the Australian 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 Australian Information
Commissioner must be made in writing. The Australian Information Commissioner's contact
details are:
Telephone: 1300 363 992
Website: www.oaic.gov.au
Smart Form: FOI Complaint Form
Commonwealth Ombudsman
You may also complain to the Commonwealth 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 Commonwealth Ombudsman may be
made in person, by telephone or in writing. The Commonwealth Ombudsman's contact
details are:
Phone: 1300 362 072
Website: www.ombudsman.gov.au
The Commonwealth Ombudsman generally prefers applicants to seek review before
complaining about a decision.
PAGE 9 OF 9
