Harry Williams
Via email to:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Harry
Freedom of Information Request LEX 53000 – Decision on access
I refer to the
Freedom of Information Act 1982 (
FOI Act) request to the Department of Social Services
(
Department) on 19 February 2025. The request, which had been revised by agreement, seeks access to
the following information related to the Cashless Debit Card:
briefs that discuss the expansion to new sites or nationally.
And any policy-related emails on the same topic.
You advised in previous correspondence that the request was intended to capture documents
generated between the dates of 1 October 2021 to 31 March 2022.
On 21 February 2025, you were provided with a notice of the Department’s intention to refuse your
request on practical refusal grounds, that processing your request would unreasonably and
substantial y divert the resources of the Department from its other operations.
As explained in this notice, in accordance with subsection 24AB(6) of the FOI Act, you were required to
do one of the fol owing by written notice to the Department before 11:59pm on Friday 7 March 2025:
a) withdraw the request;
b) make a revised request; or
c) indicate that you do not wish to revise the request.
On 24 February 2025, you responded to the notice advising that you wished to revise the scope of the
request to:
‘briefs and policy-related emails relating to the national expansion of the cashless debit card
generated between the dates of 1 October 2021 to 31 March 2022’
Decision
I have decided to refuse your request under section 24(1) of the FOI Act on practical refusal grounds,
specifically that the processing of your request would unreasonably and substantial y divert the resources
of the department from its other operations.
The reasons for my decision are set out in the Statement of Reasons at
Attachment A.
Review rights and complaints
Information concerning how you may seek a review of this decision or make a complaint about the
handling of this request is at
Attachment B.
GPO Box 9820 Canberra ACT 2601
Email Facsimile Telephone 1300 653 227
National Relay Service: TTY: 133 677, Speak and listen: 1300 555 727, Internet relay: www.relayservice.com.au
www.dss.gov.au
Contact
If you would like to discuss any aspect of my decision, please contact me
at xxx@xxx.xxx.xx.
Yours sincerely
Sarah B
Authorised FOI Decision Maker
25 March 2025
Attachments
A - Statement of Reasons
B - Review rights
ATTACHMENT A
STATEMENT OF REASONS
Material on which the decision is based
1. I relied on the following material in coming to this decision:
• the terms of the FOI request;
• the documents subject to the FOI request;
• the FOI Act;
• correspondence with yourself through the course of the request consultation process; and
• the Guidelines issued by the Office of the Australian Information Commissioner under section
93A of the FOI Act (
FOI Guidelines).
Section 24 – Diversion of resources
2. Under subsection 24(1) of the FOI Act, if an agency is satisfied that a practical refusal reason exists in
relation to a request, it must undertake a request consultation process in accordance with section
24AB of the FOI Act. If after the request consultation process the agency is satisfied that the practical
refusal reason still exists, it may refuse the request.
3. I am satisfied that a request consultation process has been undertaken by the Department in
accordance with section 24AB of the FOI Act. On 21 February 2025, you were issued with a notice of
intention to refuse the request, advising the scope of the captured a minimum of 500 documents
with an average of 3 pages per document. Further, if an officer of the Department were to assess
each for sensitivities and mark them up with redactions accordingly, it would take them a total of
4,500 minutes or 75 hours or 10 working days to review the documents at a rate of 3 minutes per
page. Accordingly, the processing of your request as originally framed would unreasonable and
substantial y divert the resources of the Department from its other operations.
4. The notice also provided advice as to how you could refine the scope of the request to ensure that
the practical refusal reason no longer applied, consistent with the Department’s obligations under
section 24(3) of the FOI Act. You opted not to take this advice, essential y making the same request
again. As a result the revised scope does not remove the practical refusal reason and the assessment
of the minimum amount of documents subject to its scope and amount of resources it would take to
process the request continues to apply.
5. The expansion of the Cashless Debit Card was a major initiative, being the core business function of
a dedicated team within the Department, generating hundreds, if not thousands of policy-related
emails during the requested period. I am satisfied that a practical refusal reason continues to exist
following the request consultation process.
6. Accordingly, I am satisfied that a practical refusal reason remains in relation to your request, and I
have decided to refuse your request under section 24(1) of the FOI Act.
INFORMATION ON REVIEW RIGHTS
You may seek review of this decision via:
(a) an internal review; or
(b) the Australian Information Commissioner (
Information Commissioner).
Internal review
If you apply for internal review, a fresh decision will be made by a different decision-maker within the
Department. An application for internal review must be:
(a) made in writing;
(b) made within 30 days of receiving this letter; and
(c) sent t
o xxx@xxx.xxx.xx.
The application should also include the reasons why you think this decision should be reviewed.
If the internal review decision results in you not being provided access to all of the documents to which
you have requested access, you have the right to seek a further review by the Information
Commissioner.
Information Commissioner review
You can apply for the Information Commissioner to review this decision either immediately or following
an internal review decision. You must apply to the Information Commissioner within 60 days of the
receipt of this decision letter.
Further details on this process can be found on the Information Commissioner’s website at
https://www.oaic.gov.au/.
COMPLAINTS TO THE INFORMATION COMMISSIONER
You may also make a complaint to the Information Commissioner concerning actions taken by the
Department while exercising its powers or performing its functions under the FOI Act.
Further details on this process can be found on the Information Commissioner’s website at
https://www.oaic.gov.au/.
