If not delivered return to PO Box 7820 Canberra BC ACT 2610
4 April 2025
Our reference: LEX 83550
Mr Squiggle
Only by email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Mr Squiggle,
Decision on your Freedom of Information request
I refer to your request, received by Services Australia (the Agency) on 3 February 2025 and
revised on 27 February 2025, for access under the
Freedom of Information Act 1982 (the FOI
Act) to the following documents:
1. Any documents that detail any assessments made as to the 'estimated value' of
these memberships (including those made by the individuals, or Services
Australia).
2. Any documents that detail any reasons for accepting (or declining) invitations to
these exclusive airline lounges.
3. Any documents that are requests for advice from these individuals, or advice
given to these individuals, that touch on whether the memberships are in
accordance with applicable policies in relation to conflict of interest, gifts, etc.
My decision
The Agency holds 3 documents (totalling 108 pages) that relate to your request.
I have decided to grant you
part access to the documents (Documents 1-3), with some of
the content removed.
I have decided that parts of the documents are exempt under the FOI Act, as the documents
include:
• personal information of other people, the disclosure of which would be unreasonable
and contrary to the public interest (section 47F(1) of the FOI Act), and
• information, the disclosure of 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 (section 47E(d) 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, including the relevant sections of the FOI Act.
How we will send the documents to you
The documents are attached.
PAGE 1 OF 10
You can ask for a review of our decision
If you disagree with any part of 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.
Further assistance
If you have any questions, please email xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx.
Yours sincerely,
Alexander
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Reviews Branch | Legal Services Division
Services Australia
PAGE 2 OF 10
• Gift/Benefit - Jonathon Thorpe
3. 81 -108 Documents related to Point 3 of your request:
Release in part s47E(d)
Information that would have a substantial adverse effect
Emails and documents related to conflict-of-interest
on the proper and efficient conduct of the operations of
declarations
the Agency redacted under s47E(d).
s47F(1)
Personal information of a third party redacted under
section 47F(1).
PAGE 4 OF 10
If not delivered return to PO Box 7820 Canberra BC ACT 2610
REASONS FOR DECISION
What you requested
On 3 February 2025, you requested the following:
1. For each of the named individuals, their total number of flights and total expenditure,
by airline, for the most recent available 12 month period.
2. Any documents that detail any assessments made as to the 'estimated value' of these
memberships (including those made by the individuals, or Services Australia).
3. Any documents that detail any reasons for accepting (or declining) invitations to these
exclusive airline lounges.
4. Any documents that are requests for advice from these individuals, or advice given to
these individuals, that touch on whether the memberships are in accordance with
applicable policies in relation to conflict of interest, gifts, etc.
On the same date, we acknowledged your FOI request via an automated email reply.
On 25 February 2025, the Agency sought a 30-day extension of time under section 15AB of
the FOI Act from the OAIC. The OAIC granted the extension on 7 March 2025, making the
new due date 4 April 2025.
On 27 February 2025, we emailed you advising that the data you requested in Point 1 of your
original request was not held by the Agency in existing documents. However, searches could
be conducted by the Agency’s External Information Release team to obtain the statistical data
requested.
On this basis, Point 1 of your request did not meet the requirements for the Agency to release
documents to you through the FOI Act, as a person is not entitled to obtain access to a
document if it is available elsewhere (section 12(1)(c)). You were advised that you could submit
a request for statistical data by contacting the External Information Release team. Therefore,
Point 1 was removed from your FOI request and your request was revised to the following
(noting that we renumbered the points of your request):
1. Any documents that detail any assessments made as to the 'estimated value' of these
memberships (including those made by the individuals, or Services Australia).
2. Any documents that detail any reasons for accepting (or declining) invitations to these
exclusive airline lounges.
3. Any documents that are requests for advice from these individuals, or advice given to
these individuals, that touch on whether the memberships are in accordance with
applicable policies in relation to conflict of interest, gifts, etc.
What I took into account
In reaching my decision I took into account:
• your original request dated 3 February 2025
• your revised request dated 27 February 2025
• the documents which fall within the scope of your request
• searches conducted for the documents requested
PAGE 5 OF 10
• whether the release of the requested document is in the public interest
• consultation with Agency officers about:
o the nature of the document
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.
I have decided that certain parts of documents you requested are exempt under the FOI Act.
My findings of fact and reasons for deciding that the exemption applies to the documents are
discussed below.
Section 47E(d) of the FOI Act – Operations of the Agency
I have applied the conditional exemption in section 47E(d) of the FOI Act to parts of the
documents.
Section 47E(d) of the FOI Act provides a document is conditionally exempt if it would have a
substantial adverse effect on the Agency’s ability to conduct its operations efficiently and
properly.
Logon identifiers
Document 2 contains Agency staff member logon identifiers.
To provide services to the Australian public, staff members are provided access to information
held by the Agency. To protect the information held by the Agency, unique staff logon identifiers
are established and maintained. Every staff member of the Agency is assigned a unique logon
identifier. Staff logon identifiers are alphanumeric codes unrelated to the staff member’s name
or position. They cannot be easily guessed from the staff members name or role at the Agency.
The Agency’s computer systems are critical to the proper and efficient delivery of its core
business. Unauthorised access would have a substantial adverse effect on the Agency’s
operations by compromising computer system availability and integrity, as well as the
confidentiality of customers’ information. Staff log-on information also forms part of the
procedures for authenticating Agency staff who call the Agency’s telephone lines. Disclosing
this information could allow individuals to pose as Agency staff, and request access to
protected personal information of the Agency’s customers.
Internal Agency email addresses
Documents 1, 2 and 3 contain internal positional mailbox details. The Agency’s purpose is to
provide high-quality government services and payments to Australians. It is a large, public
facing, government organisation with many points of contact designed to facilitate its purpose.
The Agency has established channels of communication for customers and members of the
public, which have been put in place to ensure the effective management of the significant
volume of communication received. Such channels include dedicated and externally published
positional mailboxes and contact numbers of different business areas within the Agency.
PAGE 6 OF 10
These have been established to ensure correspondence is directed to the correct area and
actioned accordingly.
If internal positional mailbox details were to be made publicly available, correspondence
received and directed could be mishandled, lost, duplicated or double-handled on account of
it not being directed to the most appropriate teams through the publicly available
communication channels. Noting the Agency’s interactions with the public number in the
hundreds of mil ions, diverting people from correct channels cannot be appropriately
categorised as insubstantial or nominal.
For the reasons outlined above, I am satisfied the positional mailboxes are conditionally
exempt under section 47E(d) of the FOI Act.
Public interest considerations
Access to conditionally exempt material must be given unless I am satisfied it would not be in
the public interest to do so.
I consider the disclosure of the material would generally promote the objects of the FOI Act,
which is in the public interest. However, I have also considered the extent to which disclosure
of Internal Agency email addresses could reasonably be expected to prejudice the Agency’s
ability to effectively and efficiently manage contact with the public. I have also considered the
extent to which disclosure of Agency Logon identifiers could reasonably be expected to
negatively impact the security of the Agency’s computer systems.
Based on the factors identified, I have decided in this instance the public interest in disclosing
the information in the document is outweighed by the public interest against disclosure.
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.
Section 47F(1) of the FOI Act - Unreasonable disclosure of personal information
I have applied the exemption in section 47F(1) of the FOI Act to parts of Documents 2 and 3.
This section of the FOI Act allows the Agency to exempt material from a document if its release
would involve the unreasonable disclosure of personal information about any person.
Personal information is information or an opinion about an identified individual, or an individual
who is reasonably identifiable. It can include a person's name, address, telephone number,
date of birth, medical records, bank account details, taxation information and signature. I am
satisfied Documents 2 and 3 contain personal information of junior Agency staff and third
parties, including their names and contact details.
I am satisfied the disclosure of the personal information would be unreasonable, as you do not
have consent from these individuals for the release of their personal information. Further, I am
satisfied the information is private, not available publicly, and is not well known to you. I also
consider that revealing this information could reasonably be expected to expose the identified
staff members and third parties to contact outside reasonable working hours and may result in
harassment and/or threats from members of the public. I am not suggesting that you would
misuse the information in the document, however the FOI Act does not control or restrict use
or dissemination of the information once released in response to an FOI request.
On this basis, I am satisfied the personal information included in the documents, referred to in
the Schedule, are conditionally exempt under section 47F(1) of the FOI Act.
PAGE 7 OF 10
Public interest considerations
Access to conditionally exempt material must be given unless I am satisfied it would not be in
the public interest to do so. I find there is little public interest in the disclosure of the third
parties’ personal information, beyond allowing you to access information contained that may
be relevant to your request. I do not see that there would be any public purpose achieved
through release, and release of this personal information would not advance the public interest
in government transparency and integrity.
Based on these factors, I am satisfied in this instance, the public interest in disclosing the
information in the above-mentioned documents is outweighed by the public interest against
disclosure.
I have not taken into account any of the irrelevant factors set out in section 11B(4) of the FOI
Act in forming this view.
Conclusion
In summary, I am satisfied parts of the Documents, as set out in the Schedule, are exempt
under sections 47E(d) and 47F(1) of the FOI Act. Furthermore, I have decided 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.
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If not delivered return to PO Box 7820 Canberra BC ACT 2610
Attachment B
INFORMATION ON RIGHTS OF REVIEW
FREEDOM OF INFORMATION ACT 1982
Requesting a full 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 allows you to correct any
misunderstandings.
Requesting a formal review of a FOI decision
If you consider the decision is incorrect, you have the right to apply for a review under
sections 54 and 54L of the
Freedom of Information Act 1982 (the FOI Act).
You can apply for:
1. an
internal review by an Internal Review Officer of Services Australia (the agency),
and/or
2. an
external review by the Australian Information Commissioner.
Applying for an internal review by an Internal Review Officer
In an internal review, a different decision maker to the Agency delegate who made the
original decision wil carry out the review. The Internal Review Officer wil make a fresh
decision on your request and wil consider all aspects of the original decision and identify any
relevant additional factors.
An application for an 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 disagree with the original or internal review decision, or if you have not received a
decision within 30 days of applying for an internal review, you wil have 60 days to apply in
writing for a review by the Australian Information Commissioner.
Note: The Australian Information Commissioner generally prefers FOI applicants to seek an
internal review before applying for an external review.
You can lodge your application:
PAGE 9 OF 10
Online:
www.oaic.gov.au
Post:
Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Email:
xxxxx@xxxx.xxx.xx
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
original and internal review decisions 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.
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