Procurement compliance considerations
Dear Australian Transaction Reports and Analysis Centre,
This is a Freedom of Information Request under the Freedom of Information Act 1982. I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary.
Yours faithfully,
AS
This is an automated response to your email which has been received by the
Privacy and Information Access team at AUSTRAC. A team member will be in
contact with you shortly.
**********************************************************************
Please note that your email address is known to AUSTRAC for the
purposes of communicating with you. The information transmitted in
this e-mail is for the use of the intended recipient only and may
contain confidential and/or legally privileged material. If you have
received this information in error you must not disseminate, copy or
take any action on it and we request that you delete all copies of
this transmission together with attachments and notify the sender.
This footnote also confirms that this email message has been swept for
the presence of computer viruses.
**********************************************************************
OFFICIAL
Dear AS,
Thank you for submitting a request for access to information you believe to be held by AUSTRAC.
In accordance with section 15(5)(a) of the Freedom of Information Act 1982 (FOI Act), I formally acknowledge receipt of your freedom of information request for access to:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
Under section 15(5)(b) of the FOI Act the statutory time frame for processing a request is 30 days, within which a decision on access to the requested documents is to be notified. We received your request on 21 October 2024 and the 30 day statutory period for processing your request commenced from the day after that date.
Charges
AUSTRAC may impose a charge for the work involved in providing access to the documents in accordance with the Freedom of Information (Charges) Regulations. If your request for access to documents attracts a charge, you will be notified in writing. Note: There is no charge for documents that contain the personal information of the applicant.
Exclusion of non-SES staff details, and SES staff contact details
AUSTRAC’s policy is to exclude the details (name, position title, telephone and/or mobile number, and email address) of officers not in the Senior Executive Service (SES), as well as the contact details (telephone and/or mobile number and email address) of SES staff, contained in documents that fall within scope of an FOI request. If you require names, position titles and contact details of non-SES officers, or the contact details of SES staff, please inform us so that the decision maker may consider your request. Otherwise, we will take it that you agree to the information being excluded from the scope of your request.
If you have any questions in relation to your request, or require further information, please contact the Privacy and Information Access team at [email address] and quote reference PIAT-6234.
Regards
Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: AS <[FOI #12191 email]>
Sent: Monday, 21 October 2024 5:21 AM
To: INFO_ACCESS <[email address]>
Subject: Freedom of Information request - Procurement compliance considerations [EXTERNAL]
Dear Australian Transaction Reports and Analysis Centre,
This is a Freedom of Information Request under the Freedom of Information Act 1982. I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary.
Yours faithfully,
AS
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #12191 email]
Is [AUSTRAC request email] the wrong address for Freedom of Information requests to Australian Transaction Reports and Analysis Centre? If so, please contact us using this form:
https://www.righttoknow.org.au/change_re...
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
Please note that in some cases publication of requests and responses will be delayed.
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
**********************************************************************
Please note that your email address is known to AUSTRAC for the
purposes of communicating with you. The information transmitted in
this e-mail is for the use of the intended recipient only and may
contain confidential and/or legally privileged material. If you have
received this information in error you must not disseminate, copy or
take any action on it and we request that you delete all copies of
this transmission together with attachments and notify the sender.
This footnote also confirms that this email message has been swept for
the presence of computer viruses.
**********************************************************************
OFFICIAL
Good afternoon AS,
I refer to your below FOI request seeking access to the following documents:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
AUSTRAC have been working hard on your request since it was received. AUSTRAC are still in the process of identifying all relevant documents captured within scope of your request. Although some documents are readily identifiable (for example the contract itself) AUSTRAC are still in the process of identifying and assessing every document captured within the broad scope.
Identifying the documents within scope, assessing the documents within scope and also having a unusually high number of FOI requests on hand at this point in time has resulted in me seeking a 30 day extension of time from you to process your FOI request. If you were agreeable to the extension, your FOI request would be due on Friday 20 December 2024.
I plan to use the additional time to continue identifying documents in scope, assessing documents identified and facilitating a FOI decision notice that is consisent with the FOI Act.
I look forward to your response to my extension request, thank you very much for the consideration.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Wednesday, 23 October 2024 10:52 AM
To: 'AS' <[FOI #12191 email]>
Subject: RE: FOI acknowledgement - Freedom of Information request - Procurement compliance considerations [EXTERNAL] [SEC=OFFICIAL]
OFFICIAL
Dear AS,
Thank you for submitting a request for access to information you believe to be held by AUSTRAC.
In accordance with section 15(5)(a) of the Freedom of Information Act 1982 (FOI Act), I formally acknowledge receipt of your freedom of information request for access to:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
Under section 15(5)(b) of the FOI Act the statutory time frame for processing a request is 30 days, within which a decision on access to the requested documents is to be notified. We received your request on 21 October 2024 and the 30 day statutory period for processing your request commenced from the day after that date.
Charges
AUSTRAC may impose a charge for the work involved in providing access to the documents in accordance with the Freedom of Information (Charges) Regulations. If your request for access to documents attracts a charge, you will be notified in writing. Note: There is no charge for documents that contain the personal information of the applicant.
Exclusion of non-SES staff details, and SES staff contact details AUSTRAC’s policy is to exclude the details (name, position title, telephone and/or mobile number, and email address) of officers not in the Senior Executive Service (SES), as well as the contact details (telephone and/or mobile number and email address) of SES staff, contained in documents that fall within scope of an FOI request. If you require names, position titles and contact details of non-SES officers, or the contact details of SES staff, please inform us so that the decision maker may consider your request. Otherwise, we will take it that you agree to the information being excluded from the scope of your request.
If you have any questions in relation to your request, or require further information, please contact the Privacy and Information Access team at [email address] and quote reference PIAT-6234.
Regards
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: AS <[FOI #12191 email]>
Sent: Monday, 21 October 2024 5:21 AM
To: INFO_ACCESS <[email address]>
Subject: Freedom of Information request - Procurement compliance considerations [EXTERNAL]
Dear Australian Transaction Reports and Analysis Centre,
This is a Freedom of Information Request under the Freedom of Information Act 1982. I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary.
Yours faithfully,
AS
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #12191 email]
Is [AUSTRAC request email] the wrong address for Freedom of Information requests to Australian Transaction Reports and Analysis Centre? If so, please contact us using this form:
https://www.righttoknow.org.au/change_re...
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
Please note that in some cases publication of requests and responses will be delayed.
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
**********************************************************************
Please note that your email address is known to AUSTRAC for the
purposes of communicating with you. The information transmitted in
this e-mail is for the use of the intended recipient only and may
contain confidential and/or legally privileged material. If you have
received this information in error you must not disseminate, copy or
take any action on it and we request that you delete all copies of
this transmission together with attachments and notify the sender.
This footnote also confirms that this email message has been swept for
the presence of computer viruses.
**********************************************************************
OFFICIAL
Good afternoon AS,
I’m writing in respect to my earlier correspondence below dated Monday 11 November 2024.
I’m hopeful the below correspondence provides enough information concerning the reasons an extension of time is being requested.
I look forward to hearing from you as soon as possible in respect to your consideration of an extension of time. Thank you.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Monday, 11 November 2024 1:11 PM
To: 'AS' <[FOI #12191 email]>
Subject: Extension of Time Request - PIAT-6234 [SEC=OFFICIAL]
OFFICIAL
Good afternoon AS,
I refer to your below FOI request seeking access to the following documents:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
AUSTRAC have been working hard on your request since it was received. AUSTRAC are still in the process of identifying all relevant documents captured within scope of your request. Although some documents are readily identifiable (for example the contract itself) AUSTRAC are still in the process of identifying and assessing every document captured within the broad scope.
Identifying the documents within scope, assessing the documents within scope and also having a unusually high number of FOI requests on hand at this point in time has resulted in me seeking a 30 day extension of time from you to process your FOI request. If you were agreeable to the extension, your FOI request would be due on Friday 20 December 2024.
I plan to use the additional time to continue identifying documents in scope, assessing documents identified and facilitating a FOI decision notice that is consisent with the FOI Act.
I look forward to your response to my extension request, thank you very much for the consideration.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Wednesday, 23 October 2024 10:52 AM
To: 'AS' <[FOI #12191 email]>
Subject: RE: FOI acknowledgement - Freedom of Information request - Procurement compliance considerations [EXTERNAL] [SEC=OFFICIAL]
OFFICIAL
Dear AS,
Thank you for submitting a request for access to information you believe to be held by AUSTRAC.
In accordance with section 15(5)(a) of the Freedom of Information Act 1982 (FOI Act), I formally acknowledge receipt of your freedom of information request for access to:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
Under section 15(5)(b) of the FOI Act the statutory time frame for processing a request is 30 days, within which a decision on access to the requested documents is to be notified. We received your request on 21 October 2024 and the 30 day statutory period for processing your request commenced from the day after that date.
Charges
AUSTRAC may impose a charge for the work involved in providing access to the documents in accordance with the Freedom of Information (Charges) Regulations. If your request for access to documents attracts a charge, you will be notified in writing. Note: There is no charge for documents that contain the personal information of the applicant.
Exclusion of non-SES staff details, and SES staff contact details AUSTRAC’s policy is to exclude the details (name, position title, telephone and/or mobile number, and email address) of officers not in the Senior Executive Service (SES), as well as the contact details (telephone and/or mobile number and email address) of SES staff, contained in documents that fall within scope of an FOI request. If you require names, position titles and contact details of non-SES officers, or the contact details of SES staff, please inform us so that the decision maker may consider your request. Otherwise, we will take it that you agree to the information being excluded from the scope of your request.
If you have any questions in relation to your request, or require further information, please contact the Privacy and Information Access team at [email address] and quote reference PIAT-6234.
Regards
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: AS <[FOI #12191 email]>
Sent: Monday, 21 October 2024 5:21 AM
To: INFO_ACCESS <[email address]>
Subject: Freedom of Information request - Procurement compliance considerations [EXTERNAL]
Dear Australian Transaction Reports and Analysis Centre,
This is a Freedom of Information Request under the Freedom of Information Act 1982. I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary.
Yours faithfully,
AS
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #12191 email]
Is [AUSTRAC request email] the wrong address for Freedom of Information requests to Australian Transaction Reports and Analysis Centre? If so, please contact us using this form:
https://www.righttoknow.org.au/change_re...
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
Please note that in some cases publication of requests and responses will be delayed.
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
**********************************************************************
Please note that your email address is known to AUSTRAC for the
purposes of communicating with you. The information transmitted in
this e-mail is for the use of the intended recipient only and may
contain confidential and/or legally privileged material. If you have
received this information in error you must not disseminate, copy or
take any action on it and we request that you delete all copies of
this transmission together with attachments and notify the sender.
This footnote also confirms that this email message has been swept for
the presence of computer viruses.
**********************************************************************
OFFICIAL
Good afternoon AS,
I refer to the correspondence below. Please respond as soon as possible in respect to the s 15AA extension request.
Thank you very much.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Wednesday, 13 November 2024 2:37 PM
To: 'AS' <[FOI #12191 email]>
Subject: RE: Extension of Time Request - PIAT-6234 [SEC=OFFICIAL]
OFFICIAL
Good afternoon AS,
I’m writing in respect to my earlier correspondence below dated Monday 11 November 2024.
I’m hopeful the below correspondence provides enough information concerning the reasons an extension of time is being requested.
I look forward to hearing from you as soon as possible in respect to your consideration of an extension of time. Thank you.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Monday, 11 November 2024 1:11 PM
To: 'AS' <[FOI #12191 email]>
Subject: Extension of Time Request - PIAT-6234 [SEC=OFFICIAL]
OFFICIAL
Good afternoon AS,
I refer to your below FOI request seeking access to the following documents:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
AUSTRAC have been working hard on your request since it was received. AUSTRAC are still in the process of identifying all relevant documents captured within scope of your request. Although some documents are readily identifiable (for example the contract itself) AUSTRAC are still in the process of identifying and assessing every document captured within the broad scope.
Identifying the documents within scope, assessing the documents within scope and also having a unusually high number of FOI requests on hand at this point in time has resulted in me seeking a 30 day extension of time from you to process your FOI request. If you were agreeable to the extension, your FOI request would be due on Friday 20 December 2024.
I plan to use the additional time to continue identifying documents in scope, assessing documents identified and facilitating a FOI decision notice that is consisent with the FOI Act.
I look forward to your response to my extension request, thank you very much for the consideration.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Wednesday, 23 October 2024 10:52 AM
To: 'AS' <[FOI #12191 email]>
Subject: RE: FOI acknowledgement - Freedom of Information request - Procurement compliance considerations [EXTERNAL] [SEC=OFFICIAL]
OFFICIAL
Dear AS,
Thank you for submitting a request for access to information you believe to be held by AUSTRAC.
In accordance with section 15(5)(a) of the Freedom of Information Act 1982 (FOI Act), I formally acknowledge receipt of your freedom of information request for access to:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
Under section 15(5)(b) of the FOI Act the statutory time frame for processing a request is 30 days, within which a decision on access to the requested documents is to be notified. We received your request on 21 October 2024 and the 30 day statutory period for processing your request commenced from the day after that date.
Charges
AUSTRAC may impose a charge for the work involved in providing access to the documents in accordance with the Freedom of Information (Charges) Regulations. If your request for access to documents attracts a charge, you will be notified in writing. Note: There is no charge for documents that contain the personal information of the applicant.
Exclusion of non-SES staff details, and SES staff contact details AUSTRAC’s policy is to exclude the details (name, position title, telephone and/or mobile number, and email address) of officers not in the Senior Executive Service (SES), as well as the contact details (telephone and/or mobile number and email address) of SES staff, contained in documents that fall within scope of an FOI request. If you require names, position titles and contact details of non-SES officers, or the contact details of SES staff, please inform us so that the decision maker may consider your request. Otherwise, we will take it that you agree to the information being excluded from the scope of your request.
If you have any questions in relation to your request, or require further information, please contact the Privacy and Information Access team at [email address] and quote reference PIAT-6234.
Regards
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: AS <[FOI #12191 email]>
Sent: Monday, 21 October 2024 5:21 AM
To: INFO_ACCESS <[email address]>
Subject: Freedom of Information request - Procurement compliance considerations [EXTERNAL]
Dear Australian Transaction Reports and Analysis Centre,
This is a Freedom of Information Request under the Freedom of Information Act 1982. I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary.
Yours faithfully,
AS
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #12191 email]
Is [AUSTRAC request email] the wrong address for Freedom of Information requests to Australian Transaction Reports and Analysis Centre? If so, please contact us using this form:
https://www.righttoknow.org.au/change_re...
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
Please note that in some cases publication of requests and responses will be delayed.
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
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Please note that your email address is known to AUSTRAC for the
purposes of communicating with you. The information transmitted in
this e-mail is for the use of the intended recipient only and may
contain confidential and/or legally privileged material. If you have
received this information in error you must not disseminate, copy or
take any action on it and we request that you delete all copies of
this transmission together with attachments and notify the sender.
This footnote also confirms that this email message has been swept for
the presence of computer viruses.
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OFFICIAL
Good afternoon AS,
I refer to the correspondence below, noting the due date for your request is COB tomorrow.
I'd appreciate a response as soon as possible in respect to the extension of time that has been requested.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Monday, 18 November 2024 4:22 PM
To: 'AS' <[FOI #12191 email]>
Subject: RE: Extension of Time Request - PIAT-6234 [SEC=OFFICIAL]
OFFICIAL
Good afternoon AS,
I refer to the correspondence below. Please respond as soon as possible in respect to the s 15AA extension request.
Thank you very much.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Wednesday, 13 November 2024 2:37 PM
To: 'AS' <[FOI #12191 email]>
Subject: RE: Extension of Time Request - PIAT-6234 [SEC=OFFICIAL]
OFFICIAL
Good afternoon AS,
I’m writing in respect to my earlier correspondence below dated Monday 11 November 2024.
I’m hopeful the below correspondence provides enough information concerning the reasons an extension of time is being requested.
I look forward to hearing from you as soon as possible in respect to your consideration of an extension of time. Thank you.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Monday, 11 November 2024 1:11 PM
To: 'AS' <[FOI #12191 email]>
Subject: Extension of Time Request - PIAT-6234 [SEC=OFFICIAL]
OFFICIAL
Good afternoon AS,
I refer to your below FOI request seeking access to the following documents:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
AUSTRAC have been working hard on your request since it was received. AUSTRAC are still in the process of identifying all relevant documents captured within scope of your request. Although some documents are readily identifiable (for example the contract itself) AUSTRAC are still in the process of identifying and assessing every document captured within the broad scope.
Identifying the documents within scope, assessing the documents within scope and also having a unusually high number of FOI requests on hand at this point in time has resulted in me seeking a 30 day extension of time from you to process your FOI request. If you were agreeable to the extension, your FOI request would be due on Friday 20 December 2024.
I plan to use the additional time to continue identifying documents in scope, assessing documents identified and facilitating a FOI decision notice that is consisent with the FOI Act.
I look forward to your response to my extension request, thank you very much for the consideration.
Regards,
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: INFO_ACCESS
Sent: Wednesday, 23 October 2024 10:52 AM
To: 'AS' <[FOI #12191 email]>
Subject: RE: FOI acknowledgement - Freedom of Information request - Procurement compliance considerations [EXTERNAL] [SEC=OFFICIAL]
OFFICIAL
Dear AS,
Thank you for submitting a request for access to information you believe to be held by AUSTRAC.
In accordance with section 15(5)(a) of the Freedom of Information Act 1982 (FOI Act), I formally acknowledge receipt of your freedom of information request for access to:
"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary."
Under section 15(5)(b) of the FOI Act the statutory time frame for processing a request is 30 days, within which a decision on access to the requested documents is to be notified. We received your request on 21 October 2024 and the 30 day statutory period for processing your request commenced from the day after that date.
Charges
AUSTRAC may impose a charge for the work involved in providing access to the documents in accordance with the Freedom of Information (Charges) Regulations. If your request for access to documents attracts a charge, you will be notified in writing. Note: There is no charge for documents that contain the personal information of the applicant.
Exclusion of non-SES staff details, and SES staff contact details AUSTRAC’s policy is to exclude the details (name, position title, telephone and/or mobile number, and email address) of officers not in the Senior Executive Service (SES), as well as the contact details (telephone and/or mobile number and email address) of SES staff, contained in documents that fall within scope of an FOI request. If you require names, position titles and contact details of non-SES officers, or the contact details of SES staff, please inform us so that the decision maker may consider your request. Otherwise, we will take it that you agree to the information being excluded from the scope of your request.
If you have any questions in relation to your request, or require further information, please contact the Privacy and Information Access team at [email address] and quote reference PIAT-6234.
Regards
Ashley Smith | Manager, Privacy and Information Access Team Privacy and Information Access Team
Legal and Enforcement Branch
@AUSTRAC W: www.austrac.gov.au
OFFICIAL
-----Original Message-----
From: AS <[FOI #12191 email]>
Sent: Monday, 21 October 2024 5:21 AM
To: INFO_ACCESS <[email address]>
Subject: Freedom of Information request - Procurement compliance considerations [EXTERNAL]
Dear Australian Transaction Reports and Analysis Centre,
This is a Freedom of Information Request under the Freedom of Information Act 1982. I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd
In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance
With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance
Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this
This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community
All the above applying to the US headquartered business and Australian subsidiary.
Yours faithfully,
AS
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #12191 email]
Is [AUSTRAC request email] the wrong address for Freedom of Information requests to Australian Transaction Reports and Analysis Centre? If so, please contact us using this form:
https://www.righttoknow.org.au/change_re...
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
Please note that in some cases publication of requests and responses will be delayed.
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
**********************************************************************
Please note that your email address is known to AUSTRAC for the
purposes of communicating with you. The information transmitted in
this e-mail is for the use of the intended recipient only and may
contain confidential and/or legally privileged material. If you have
received this information in error you must not disseminate, copy or
take any action on it and we request that you delete all copies of
this transmission together with attachments and notify the sender.
This footnote also confirms that this email message has been swept for
the presence of computer viruses.
**********************************************************************