735/24/25
CLF
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear CLF,
NOTIFICATION OF A REQUEST CONSULTATION PROCESS – FOI 735/24/25
I refer to your request for access to the following documents, in the possession of the Department of
Defence (Defence) under the
Freedom of Information Act 1982 (Cth) (FOI Act).
I am an officer authorised under section 23(1) of the FOI Act to make decisions in relation to FOI
requests.
I am writing to tell you that I believe that the work involved in processing your request in its current
form would substantially and unreasonably divert the resources of this agency from its other
operations due to its size and broad scope. This is called a ‘practical refusal reason’ (section 24AA).
On this basis, I intend to refuse your request. However, before I make a final decision to do this, you
have an opportunity to revise your request. This is called a ‘request consultation process’ as set out
under section 24AB of the FOI Act. You have
14 days to respond to this notice in one of the ways set
out below.
Reason for Intending to Refuse Your Request
In your request, you sought documents relating to:
… the Indigenous participation commitments and evaluation process for Standing Offer
Notice (SON4076897), which awarded contracts to the following prime contractors:
Barrington Corporate Risk Pty Limited (ABN: 54 101 991 584) Cogent Business Solutions Pty
Ltd (ABN: 44 076 633 200) Connect3i Pty Ltd (ABN: 39 621 200 637) Ernst & Young (ABN: 75
288 172 749) Mitchell Personnel Solutions Pty Ltd (ABN: 53 118 343 801) Omni Executive Pty
Ltd (ABN: 31 160 925 413) Sirras Consultants Pty Ltd (ABN: 68 619 212 234) Staff Check Pty
Limited (ABN: 99 107 014 942) Requested Documents I seek access to:
All Indigenous Participation Plans submitted by the above-listed prime contractors as part of
their bid for SON4076897, detailing how they proposed to meet Indigenous Procurement
Policy (IPP) and Mandatory Minimum Requirements (MMRs).
Documents outlining how the Department of Defence evaluated Indigenous participation in
these bids, including:
Any scoring criteria, weighting, or assessment frameworks used to evaluate Indigenous
engagement.
Any internal assessment reports or scoring matrices relating to the Indigenous participation
component.
Records of communication between the Department of Defence, AGSVA, and the prime
contractors regarding the Indigenous participation component of the contract.
Any directives, policy guidelines, or memos issued by the Department of Defence regarding
how Indigenous participation would be assessed and enforced post-award.
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For the purpose of providing this notice, I have considered whether processing your request would
be unreasonable. I consider that processing your request, as it currently stands, would be
unreasonable because the work involved in processing your request in its current form would
substantially and unreasonably divert the resources of the agency from its other operations.
Section 24(1) of the FOI Act provides that an agency may refuse to give access to documents in
accordance with an FOI request if:
• a practical refusal reason exists in relation to the request; and
• following a request consultation process under section 24AB of the FOI Act, the agency is
satisfied that the practical refusal reason still exists.
Section 24AA(1)(a)(i) of the FOI Act provides that a practical refusal reason exists in relation to an FOI
request if the work involved in processing the request would substantially and unreasonably divert
the resources of the department from its other operations.
I find that a significant amount of resources would have to be diverted to arrange for the in scope
material to undergo initial review, and finally to undertake the decision making process in regard to
the information that meets the parameters of your request.
Searches for your request have identified over 1000 documents, meaning that allowing an average of
two pages per document, 2000 pages would be required to be carefully reviewed and considered
prior to release. Using a conservative estimate of five minutes to review and make a decision on each
page, it would take the decision maker in excess of 166 hours to make their decision on access.
Request Consultation Process
You now have an opportunity to revise your request to enable Defence to process it.
Revising your request can mean narrowing the scope of the request to make it more manageable or
explaining in more detail the documents you wish to access. For example, by providing more specific
information about exactly what documents you are interested in, Defence will be able to pinpoint
the documents more quickly and avoid using excessive resources to process documents you are not
interested in.
Before the end of the consultation period, you must do one of the following, in writing:
x Withdraw your request
x Make a revised request
x Tell us that you do not wish to revise your request.
The consultation period starts on the day after you receive this notice and ends on
2 April 2025.
If you revise your request in a way that adequately addresses the practical refusal reason outlined
above, we will recommence processing it. (Please note that the time taken to consult you regarding
the scope of your request is not taken into account for the purposes of the 30 day time limit for
processing your request.)
In consideration of submitting a revised request, I suggest that you may wish to limit your request to
the Individual Participant Plans for the contractors listed in your current scope of request:
x Barrington Corporate Risk Pty Limited (ABN: 54 101 991 584)
x Cogent Business Solutions Pty Ltd (ABN: 44 076 633 200)
x Connect3i Pty Ltd (ABN: 39 621 200 637)
x Ernst & Young (ABN: 75 288 172 749)
x Mitchell Personnel Solutions Pty Ltd (ABN: 53 118 343 801)
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x Omni Executive Pty Ltd (ABN: 31 160 925 413)
x Sirras Consultants Pty Ltd (ABN: 68 619 212 234)
x Staff Check Pty Limited (ABN: 99 107 014 942)
If you do not do one of the three things listed above during the consultation period your request will
be taken to have been withdrawn.
Contact Officer
If you would like to revise your request or have any questions, please contact the Case Manager by
email, xxx.xxxxxxxxxxxxxx@xxxxxxx.xxx.xx.
Yours sincerely,
simonbuckley Digitally signed by simonbuckley
Date: 2025.03.19 10:14:48 +08'00'
Simon Buckley
SES Band 1
Assistant Secretary Security Policy and Services
Department of Defence
Russell Offices
PO Box 7910
Canberra BC ACT 2610
19 March 2025
