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Agency reference: FOI 22/085
Contact:
FOI Team
E-mail:
xxxx@xxxxxxx.xxx.xx
C Drake
By email only: xxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Mr Drake,
Decision and Statement of Reasons issued under the Freedom of
Information Act 1982 – FOI 22/085
On 24 September 2022, the Department of Finance (Finance) received your email, in which
you sought access under the Commonwealth
Freedom of Information Act 1982 (FOI Act) to
the following:
1. the Sponsorship Agreement between auDA and Finance;
2. the Registry-Registrar Agreement between Identity Digital and Finance;
3. the outbound consultation with auDA and Identity Digital;
4. the joint submissions made by auDA and Identity Digital;
5. all outbound correspondence in which I am mentioned (by name or otherwise) and/or which my FoI
22/54 is mentioned or related to;
6. all inbound correspondence in response to items 3 and 5 above, or in which I am mentioned (by name
or otherwise) and/or which my FoI 22/54 is mentioned or related to;
7. The "information" cited in your statement "inconsistent with the information that has been provided
directly to Finance by Identity Digital."
On 10 October 2022, Finance notified you of the $164.42 preliminary assessment of the
charges payable by you for Finance to process your request, pursuant to section 29(1) of the
FOI Act.
On 12 October 2022, you outlined your contention of the preliminary assessment of charge
and sought waiver of the charges. You stated that some of the information requested relates
to your personal information, also that the charge had been wrongly assessed and that there
is public interest in disclosure of the documents requested.
On 1 November 2022, I, as the decision maker affirmed the preliminary charge assessment
of $164.42.
On 13 November 2022, you sought internal review of the Department’s decision. On
13 December 2022, the decision maker affirmed the original decision.
One Canberra Avenue, Forrest ACT 2603 • Internet www.finance.gov.au
OFFICIAL
On 16 February 2023, you sought Information Commissioner (IC) review of the internal
review decision under section 54L of the FOI Act.
During the IC review, Finance notified the Office of the Australian Information
Commissioner (OAIC) that it no longer considers that you are liable to pay a charge to
process your request.
On 24 October 2024, the Acting Deputy Commissioner substituted their decision that you
are not liable to pay any charge in respect of your request.
On 20 November 2024, Finance notified you that it will be processing your request, that
third party consultation would be undertaken and that the processing period has been
extended by 30 calendar days to allow for this consultation. As such, a decision is currently
due to you by Monday 23 December 2024. Finance also notified the Office of the OAIC that
a decision is now due on this date.
Authorised decision-maker
I am authorised by the Secretary of Finance and section 23(1) of the FOI Act to make
decisions in relation to FOI requests.
The purpose of this letter is to provide you with notice of my decision under the FOI Act.
My Decision
I have identified nine documents falling within the scope of your request.
I have decided to:
• release six documents with some information redacted as the documents contain
material subject to legal professional privilege (section 42 of the FOI Act),
documents subject to deliberative process (section 47C of the FOI Act), documents
that would have a substantial adverse effect on the proper and efficient conduct of
the operations of an agency (section 47E) and irrelevant information (section 22).
• refuse to release one document as its disclosure would found an action, by .au
Domain Administration Ltd (auDA) and Identity Digital Australia Pty Ltd
(Identity Digital) (formerly known as Afilias Australia Pty Ltd) for breach of
confidence (section 45 of the FOI Act). That same document is also exempt on the
grounds of national security (section 33 of the FOI Act).
• not release two documents to you at this time as third parties have objected.
Locating and identifying documents
The documents were identified by conducting searches of Finance’s information
management systems including SharePoint and Outlook using all reasonable search terms
that could return documents relevant to your request.
Relevant Finance staff able to identify documents within the scope of the request were also
consulted.
The documents are identified in the Schedule at
Attachment A.
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Material taken into account In accordance with section 26(1)(a) of the FOI Act, my findings on any material question of
fact, the material on which those findings were based, and the reasons for my decision to
grant access to the documents follows.
In making my decision, I have had regard to the following:
• the terms of your FOI request;
• the content of the documents that fall within the scope of your request;
• consultations with third parties in accordance with the FOI Act and submissions
made by those third parties;
• the relevant provisions of the FOI Act, including sections 3, 11 and 11A; and
• the FOI Guidelines issued by the Office of the Australian Information Commissioner
(FOI Guidelines)
1.
Reasons for decision
I have decided to grant part access to the material within the scope of your request, subject
to the following provisions of the FOI Act.
Section 45 – Breach of confidence
Section 45 provides:
(1) A document is an exempt document if its disclosure under this Act would found an action, by a
person (other than an agency or the Commonwealth), for breach of confidence.
The FOI Guidelines provide:
[5.158] A breach of confidence is the failure of a recipient to keep confidential, information which has
been communicated in circumstances giving rise to an obligation of confidence. The FOI Act
expressly preserves confidentiality where that confidentiality would be actionable at common law or
in equity.
[5.159] To found an action for breach of confidence (which means section 45 would apply), the
following five criteria must be satisfied in relation to the information:
it must be specifically identified
it must have the necessary quality of confidentiality
it must have been communicated and received on the basis of a mutual understanding of confidence
it must have been disclosed or threatened to be disclosed, without authority
unauthorised disclosure of the information has or will cause detriment.
I consider that the five criteria listed in the FOI Guidelines at 5.159 are satisfied, for the
same reasons as providing in Finance’s decision letter for your request 22-54
(
Attachment A). Given that I support the reasoning provided in that letter, I do not consider
it necessary to repeat that information here.
Based upon the above, I consider that the Master List is exempt in full under section 45 of
the FOI Act.
1
https://www.oaic.gov.au/freedom-of-information/freedom-of-information-guidance-for-government-
agencies/foi-guidelines
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Section 33 – National Security
As stated in the decision letter for your request 22-54 (
Attachment A) I found that the
Master List is exempt in full under section 45 of the FOI Act.
The consulted third parties considered that sections 33 and 47G of the FOI Act also apply to
exempt the Master List in full. At the time I did not consider the application of these or any
other applicable exemptions in detail. However, I will now also consider the application of
section 33.
Section 33 provides:
A document is an exempt document if disclosure of the document under this Act:
(a) would, or could reasonably be expected to, cause damage to:
(i) the security of the Commonwealth;
(ii) the defence of the Commonwealth; or
…
The FOI Guidelines provide:
[5.24] …There must be ‘real’ and ‘substantial’ grounds for expecting the damage to occur which can
be supported by evidence or reasoning. A mere allegation or possibility of damage is insufficient to
meet the ‘reasonable expectation’ test. Davies J said in
Re Maher and Attorney-General’s Department
that ‘there must be a cause and effect that can be reasonably anticipated’: But if it can be reasonably
anticipated that disclosure of the document would lessen the confidence which another country would
place on the Government of Australia, that is a sufficient ground for a finding that the disclosure of
the document could reasonably be expected to damage international relations. Trust and confidence
are intangible aspects of international relations.”
[5.29] The term ‘security of the Commonwealth’ includes the protection of Australia and its
population from activities that are hostile to, or subversive of, the Commonwealth’s interests.
[5.33] It is well accepted that securing classified government information forms part of the security of
the Commonwealth. The assessment that s 33(a)(i) requires must be made at the time the decision is
made and in the environment that exists at the time. Where a request is received for classified
government information, the documents must be considered both individually and collectively. The
Information Commissioner believes that it might be safer for the FOI decision maker to err on the side
of non-disclosure provided the interests of other citizens are able to be protected. Where there is
doubt, this should be in favour of non-disclosure.
As set out under the ‘Detriment’ criteria of the Breach of confidence exemption in the
decision letter for your request 22-54 (
Attachment A), the disclosure of the Master List
(Document 09) will cause detriment to auDA, Identity Digital and Finance as the
Master List is kept intentionally confidential. Its release puts the gov.au namespace at risk of
targeted cyber-attacks and would adversely affect or compromise integrity or stability of the
internet domain name system. For example, release of the Master List could be used for
malicious purposes such as systematically using vulnerability scanning tools against the list
to identify security vulnerabilities, or compiling lists of email addresses for use in spear-
phishing attacks.
The information within Document 09 in its totality would cause damage to the security of
the Commonwealth. As set out in the decision letter for request 22-54 (
Attachment A),
Finance acknowledges that there is information that is already in the public domain such as
individual domain names. The WHOIS lookup tool enables users to access one domain
name at a time that is registered on the WHOIS database, however, I consider that abstract
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accessibility is vastly different to access in fact to the domain names. When considered
collectively, the disclosure of the exempt information, that is, the Master List discloses
material further than the details in the public domain and would pose a very real risk of
damage to the security of the Commonwealth.
I have therefore decided that Document 09 is exempt from disclosure under section 33 of the
FOI Act.
Section 42 – Material subject to legal professional privilege
Subsection 42(1) provides:
A document is an exempt document if it is of such a nature that it would be privileged from
production in legal proceedings on the ground of legal professional privilege.
The FOI Guidelines provide:
[5.128] LPP applies to some but not all communications between legal advisers and clients. The
underlying policy basis for LPP is to promote the full and frank disclosure between a lawyer and
client to the benefit of the effective administration of justice. It is the purpose of the communication
that is determinative. The information in a document is relevant and may assist in determining the
purpose of the communication, but the information in itself is not determinative.
[5.129] At common law, determining whether a communication is privileged requires a consideration
of:
• whether there is a legal adviser-client relationship
• whether the communication was for the purpose of giving or receiving legal
advice, or use in connection with actual or anticipated litigation
• whether the advice given is independent
• whether the advice given is confidential
I have examined Document 07 and satisfied that it includes a third-party submission made
by auDA regarding your request for access to the “master list” of gov.au public domain
names as part of your original FOI request 22-54. The submission was prepared by outside
Counsel for auDA. I am satisfied that the submission comprise confidential legal advice
passing between the external legal advisers to auDA and then to Finance’s legal advisers, for
the dominant purpose of giving or receiving independent legal advice in regards to the
freedom of information request.
I have therefore decided that parts of the document are exempt from disclosure under
section 42 of the FOI Act
Section 47C – Documents subject to deliberative process
Section 47C provides:
(1) A document is conditionally exempt if its disclosure under this Act would disclose matter
(
deliberative matter) in the nature of, or relating to, opinion, advice or recommendation obtained,
prepared or recorded, or consultation or deliberation that has taken place, in the course of, or for the
purposes of, the deliberative processes involved in the functions of:
(a) an agency; or
(b) a Minister; or
(c) the Government of the Commonwealth
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The FOI Guidelines provide:
[6.54] A deliberative process involves the exercise of judgement in developing and making a selection
from different options:
The action of deliberating, in common understanding, involves the weighing up or
evaluation of the competing arguments or considerations that may have a bearing
upon one's course of action. In short, the deliberative processes involved in the
functions of an agency are its thinking processes – the processes of reflection, for
example, upon the wisdom and expediency of a proposal, a particular decision or a
course of action.
The FOI Guidelines at [6.61] provide a list of recordings or exchanges that may be
considered to be a deliberative process. These include:
•
opinions
•
advice
•
recommendations
•
a collection of facts or opinions, including the pattern of facts or opinions considered
•
interim decisions or deliberations.
As explained above, Document 07 includes a third party submissions made by auDA
regarding your request for access to the “master list” of gov.au public domain names as part
of your original FOI request 22-54. This document contains information including opinion,
advice and recommendations from auDA, and was provided to Finance in the process of
considering the specific FOI request.
One of Finance’s functions as an agency is to consider and make access decisions for FOI
requests. The relevant information was created as part of a consultation process to provide
third parties with an opportunity to object to disclosure by setting out the specific exemption
under the FOI Act that supports why that the document should not be disclosed, or parts of
the document should be redacted before disclosure. The third-party submission does not
represent Finance’s final position. As such, I consider this deliberative matter satisfies the
requirements outlined in section 47C and the FOI Guidelines.
Accordingly, I have decided that this information in Documents 07 would disclose
deliberative matter and is conditionally exempt under section 47C of the FOI Act.
Section 47E – Certain Operations of Agency
Section 47E provides:
(1) A document is conditional y exempt if its disclosure under this Act would, or could reasonably be
expected to, do any of the following:
…
(d) have a substantial adverse effect on the proper and efficient conduct of the operations of
an agency
The FOI Guidelines provide:
[6.114] The conditional exemption may also apply to a document that relates to a complaint made to
an investigative body. Disclosure of this type of information could reasonably affect the willingness
of people to make complaints to the investigative body, which would have a substantial adverse effect
on the proper and efficient conduct of the investigative body’s operations. Further, disclosure of
information provided in confidence by parties to a complaint or investigation may reduce the
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willingness of parties to provide information relevant to a particular complaint and may reduce their
willingness to participate fully and frankly with the
investigative process. In such cases the investigative body’s ability to obtain all information would be
undermined and this may have a substantial adverse effect on the proper and efficient conduct of the
investigative body’s operations.
[6.115] The predicted effect must bear on the agency’s ‘proper and efficient’ operations, that is, the
agency is undertaking its operations in an expected manner…
In
DZ and Commonwealth Ombudsman [2014] AICmr 137, it was found that disclosure of
certain material could adversely affect the willingness of agencies to cooperate with another
investigative body. Furthermore, the Information Commissioner provided that:
“It is likely that a situation will arise in future that involves information held across more than one
agency and that agencies will be less forthcoming about the issues this raises if the information is not
treated confidentially. If agencies are less forthcoming and less willing to consider and consult on the
proper course of action in this situation, the [Ombudsman’s] investigations will be less efficient.”
As above, Document 07 includes a third party submissions made by auDA regarding your
request for access to the “master list” of gov.au public domain names as part of your original
FOI request 22-54. I consider that disclosure of this information would, or could reasonably
be expected to, have a substantial adverse effect on the proper and efficient conduct of the
operations of Finance.
The submission was provided by auDA on the assumption that it would be treated as
confidential information and not disclosed. If sensitive information shared in confidence by
third parties is exposed, it could reasonably be expected that those third parties would be
less forthcoming with the breadth of material and views they provide in future submissions.
If this occurred, this would materially impact the quality of Finance’s decision making in
relation to freedom of information requests.
If third parties only provide high level or incomplete information in their submissions, due
to concerns that more fulsome submissions will not be kept confidential, then decision
makers would not have all the relevant information to assess the access request. I consider
this would substantially affect the ability of Finance’s decision makers to make correct and
preferable decisions about freedom of information requests, which may disadvantage
freedom of information applicants.
Therefore, I consider that the disclosure of this information could have a material adverse
effect on other third parties to Finance and have a substantial adverse effect on Finance’s
operations in making freedom of information access decisions in the future.
Accordingly, I have decided that information in Documents 07 is conditionally exempt
under section 47E(d) of the FOI Act
Public interest test
Section 11A of the FOI Act relevantly provides:
(5) The agency or Minister must give the person access to the document if it is conditionally
exempt at a particular time unless (in the circumstances) access to the document at that time
would, on balance, be contrary to the public interest.
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In finding that the documents are conditionally exempt in part, I am required to consider
whether it would be contrary to the public interest to give access to the information in the
documents at this time.
Factors favouring disclosure
Section 11B of the FOI Act relevantly provides:
(3) Factors favouring access to the document in the public interest include whether access to
the document would do any of the following:
(a) promote the objects of this Act (including all the matters set out in sections 3 and
3A);
(b) inform debate on a matter of public importance;
(c) promote effective oversight of public expenditure;
(d) allow a person to access his or her own personal information.
In considering the scope of your request and the content of the documents, I have taken into
account the intention of the FOI Act to provide for open Government and that the release of
the documents would promote transparency of Government activities. I consider that the
release of the documents would promote the objects of the FOI Act in demonstrating the
actions that agencies take and the matters considered in making decisions.
Further, I have balanced this consideration against the factors against disclosure below.
Factors against disclosure
Paragraph [6.233] the FOI Guidelines provides a non-exhaustive list of factors against
disclosure. I consider that the following factors apply to these documents, in that the release
of the information in the documents could reasonably be expected to:
• prejudice an agency’s ability to obtain confidential information
• prejudice an agency’s ability to obtain similar information in the future;
• prejudice the effectiveness of an agency’s decision-making and deliberative
processes; in particular, by:
o discouraging full and complete sharing of opinions and recommendations;
and
o harming the development of sound decision-making.
I consider that the release of documents within the scope of your request would inhibit third
party communications in considering freedom of information access decisions. Finance
seeks submissions from other Commonwealth agencies and third parties, which are relied on
as a prominent element of the decision-making process. Some information is provided on
the assumption that it remains confidential. If the redacted material is released it would
divulge information or matter communicated in confidence between auDA and Finance,
which could adversely affect the level of trust and cooperation.
It could lead to auDA and other third parties losing trust in Finance’s ability to handle
confidential information about current and future freedom of information access requests,
resulting in less comprehensive and frank submissions. Accordingly, disclosing this material
would adversely affect Finance’s ability to consider all relevant material relating to freedom
of information access requests and substantially impact the quality of decision-making. I
consider that this would be contrary to the public interest and that this factor weighs strongly
against disclosure.
I consider, for the reasons above, that the release of the conditionally exempt material in the
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documents would be contrary to the public interest and that the above factors weigh strongly
against disclosure
Irrelevant factors
Section 11B of the FOI Act relevantly provides:
(4) The following factors must not be taken into account in deciding whether access to the document
would, on balance, be contrary to the public interest:
(a) access to the document could result in embarrassment to the Commonwealth
Government, or cause a loss of confidence in the Commonwealth Government;
(b) access to the document could result in any person misinterpreting or misunderstanding
the document;
(c) the author of the document was (or is) of high seniority in the agency to which the
request for access to the document was made;
(d) access to the document could result in confusion or unnecessary debate.
I have not taken into account any of these irrelevant factors.
Balancing public interest factors
The FOI Guidelines relevantly provide:
[6.238] To conclude that, on balance, disclosure of a document would be contrary to the public
interest is to conclude that the benefit to the public resulting from disclosure is outweighed by the
benefit to the public of withholding the information. The decision maker must analyse, in each case,
where on balance the public interest lies based on the particular facts of the matter at the time the
decision is made.
I acknowledge that there is public interest in providing access to the information in the
documents. However, on balance, I consider that the factors against disclosure outweigh the
factors favouring disclosure.
I consider there is a public benefit in Finance being able to provide high quality decisions
and advice in exercising its functions and powers in relation to the Commonwealth’s
freedom of information scheme. This involves, and can only be achieved through, the
provision of comprehensive and frank submissions from third parties such as auDA, and
agencies.
To enable Finance to undertake a best practice approach in considering act of freedom of
information requests, I consider it essential to maintain confidentiality in general over all
submissions received about a freedom of information request. This will ensure that Finance
continues to receive robust information and advice which, in turn, enables
Finance to make robust and well-informed access decisions for freedom of information
requests. Maintaining the confidentiality of material received for freedom of information
decisions therefore benefits all current and future freedom of information applicants.
Therefore, I consider that on balance the release of the conditionally exempt material in the
documents would be against the public interest and have decided to refuse the release of this
material.
Section 22 - Irrelevant information removed from the documents
Section 22 of the FOI Act relevantly provides:
(1) This section applies if:
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(a) an agency or Minister decides:
(i) to refuse to give access to an exempt document; or
(ii) that to give access to a document would disclose information that would reasonably be
regarded as irrelevant to the request for access; and
(b) it is possible for the agency or Minister to prepare a copy (an edited copy) of the document,
modified by deletions, ensuring that:
(i) access to the edited copy would be required to be given under section 11A (access to
documents on request); and
(ii) the edited copy would not disclose any information that would reasonably be regarded as
irrelevant to the request…
On 22 November 2024, Finance advised that subject to any objections raised by you, the
names and contact details of junior staff (non-SES officers) and staff employed under the
Members of Parliament (Staff) Act 1984 (adviser level and below) would be redacted under
subparagraph 22(a)(ii) of the FOI Act on the basis that these details are irrelevant to the
request.
Documents 03, 04, 05, 06 and 07 within scope of your request contain information which is
not relevant to your request under paragraph 22(a) of the FOI Act. Accordingly, this
information is irrelevant to your request and Finance has prepared an edited copy of the
documents that has removed this information in accordance with paragraph 22(b) of the
FOI Act.
Charges
As set out above on 24 October 2024, the Acting Deputy Commissioner substituted their
decision that you are not liable to pay any charge in respect of your request.
On 20 November 2024, Finance notified you that it will be processing your request.
Third party consultation
Finance consulted with third parties and provided them with a copy of the documents.
The third parties objected to our proposed decision to release Document 01 and 02 to you.
This means we are not able to provide a copy of the documents in full to you at this time.
The third parties have 30 calendar days to seek an internal review of our decision to release
the documents to you, or to appeal to the Office of the Australian Information
Commissioner. We will notify you if the third party seeks a further review. If no review is
made, we will release the documents to you after 22 January 2024.
Review and appeal rights
You are entitled to request an internal review or an external review by the Office of the
Australian Information Commissioner (OAIC) of my decision. The process for review and
appeal rights is set out at
Attachment B.
Information Publication Scheme The Information Publication Scheme requires an agency to publish information released in
response to individual requests made under the FOI Act, except in specified circumstances.
I am of the view that details of your request should be made available on the Department’s
FOI Disclosure Log, which can be accessed at
https://www.finance.gov.au/about-
us/freedom-information/disclosure-log.
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Finance only publishes details of the FOI request and the documents released in response to
the request, and does not publish details of FOI applicants.
If you have any questions about this request, please contact the FOI Team.
Yours sincerely,
Vickers, Marc
Digitally signed by Vickers, Marc
Date: 2024.12.20 12:10:45 +11'00'
Marc Vickers
Assistant Secretary
Governance and Procurement | Information and Communications Technology
Department of Finance
December 2024
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ATTACHMENT B
SCHEDULE OF DOCUMENTS RELEVANT TO FOI 22-085
Document Date of
No. of Description of Document
Decision
No.
Document
Pages
1
2LD Sub-Sponsorship Agreement for gov.au
Third Party Objection.
2
Registry-Registrar Agreement
3
10/08/2022
1
Email from Finance to Afilias/ Identity Digital Release in part - Irrelevant material redacted under
4
22/08/2022
4
Email correspondence between Finance and
section 22.
auDA – Third Party Consultation
5
5/09/2022
4
Email correspondence between Finance and
auDA – Third Party Consultation
6
10/08/2022
1
Email from Finance to auDA
7
02/09/2022
14
auDA and Identity Digital submissions
Release in part – Material subject to legal professional
privilege redacted under section 42.
8
06/09/2022
4
Email from Finance to Afilias / Identity Digital Release in part - Irrelevant material redacted under
– Third Party Consultation
section 22.
9
-
-
Master List
Refused – Exempt as document containing material
obtained in confidence under section 45.
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ATTACHMENT C
Your Review Rights
Legislation
A copy of the FOI Act is available at:
https://www.legislation.gov.au/Series/C2004A02562.
If you are unable to access the legislation through this website, please contact our office for
a copy.
Internal Review (IR)
If you disagree with this decision, you can seek a review of the original decision. The review
will be conducted by a different decision maker, usually someone at a more senior level.
You must apply for an IR within
30 calendar days of being notified of the decision or
charge, unless we agree to extend your time. You should contact us if you wish to seek an
extension.
We are required to make an IR decision within 30 calendar days of receiving your
application. If we do not make an IR decision within this timeframe, then the original
decision stands.
Your request for an IR should include:
• a statement that you are seeking a review of our decision;
• attach a copy of the decision you are seeking a review of; and
• state the reasons why you consider the original decision maker made the wrong
decision.
Email
: xxxx@xxxxxxx.xxx.xx
Post
: The FOI Coordinator
Legal and Assurance Branch
Department of Finance
One Canberra Avenue
FORREST ACT 2603
Information Commissioner review
You may apply directly to the Office of the Australian Information Commissioner (OAIC)
for an Information Commissioner review of this decision. You must apply in writing
within
60 calendar days of this notice.
For further information about review rights and how to submit a request for a review to the
OAIC, please s
ee https://www.oaic.gov.au/freedom-of-information/your-freedom-
ofinformation-rights/freedom-of-information-reviews/information-commissioner-review.
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Third parties
If you are a third party objecting to a decision to grant someone else access to your
information, you must apply to the Information Commissioner within
30 calendar days of
being notified of our decision to release your information.
The OAIC asks that you commence a review by completing their online form which is
available on their website.
Your review application must include a copy of the notice of our decision that you are
objecting to, and your contact details. You should also set out why you are objecting to the
decision.
Email:
xxxxx@xxxx.xxx.xx
Post: Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992 (local call charge).
Making a complaint
You may complain to the Information Commissioner about action taken by the Department
in relation to your request.
Your enquiries to the Information Commissioner can be directed to:
Phone: 1300 363 992 (local call charge)
Email:
xxxxxxxxx@xxxx.xxx.xx
There is no particular form required to make a complaint to the Information Commissioner.
The request should be in writing and should set out the grounds on which it is considered
that the action taken in relation to the request should be investigated and identify the
Department of Finance as the relevant agency.
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Document Outline
