Senior executive (and their partners') Exclusive Airline Lounge Memberships

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References

OFFICIAL: Sensitive
Personal-Privacy

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

Acknowledgement of Freedom of Information Access request

This letter acknowledges that on 3 February 2025 the Department Of Home
Affairs (the Department) received your request to access documents held
by the Department under the Freedom of Information Act 1982 (the FOI
Act). This letter also provides important information about your request.

Scope of request

You have requested access to the following:

I refer to the 'Annual disclosure of airline lounge memberships
(2024-2025) ' table at the following link:

https://www.homeaffairs.gov.au/reports-a...

The table lists 11 officials who have declared memberships of Qantas
Chairman's Lounge or Virgin's Beyond lounge.

Also listed with declared memberships are the partners of departmental
officials Stephanie Foster PSM Secretary, Gavan Reynolds ABF Commissioner,
Michelle McGuinness, and Hamish Hansford.

I request the following documents under the FOI Act:

1. For each of the named individuals, their total number of flights and
total expenditure, by airline, for the most recent available 12 month
period (only flights funded by Home Affairs)

2. Any documents that detail any assessments made as to the 'estimated
value' of these memberships (including those made by the individuals, or
Home Affairs).

3. Any documents that detail any reasons for accepting (or declining)
invitations to these exclusive airline lounges.

4. Any documents that are requests for advice from these individuals, or
advice given to these individuals, that touch on whether the memberships
are in accordance with applicable policies in relation to conflict of
interest, gifts, etc.

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.

Your request has been allocated FOI request number FA 25/02/00104 . Please
include your FOI request number in all correspondence with the Freedom of
Information Section.

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The timeframe for processing a request is 30 days from the day we receive
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of information reviews | OAIC.

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[4][Department of Home Affairs request email].

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [5][Department of Home Affairs request email]

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Personal-Privacy
OFFICIAL: Sensitive

show quoted sections

OFFICIAL: Sensitive
Personal-Privacy

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know)

Thank you for the further addition to the scope of your FOI request.

On 4 February 2025 you amended the scope of your request to:

I refer to my FOI requested dated 3 February 2025 which is available at
the following link:

https://www.righttoknow.org.au/request/s...

I also request under the FOI act an expansion of scope of item 5 on my
request below:

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.

I expand the scope of this item to also include any invitations the
airlines have sent in which the officials partners were invited to join
the lounges.

I also request the following documents under the FOI Act:

6. The declarations made by the officials with respect to their partners
membership, including the names of their partners, and any reasons given
as to why the membership was sought, offered, or accepted.

7. All correspondence between the airlines and the officials/their
partners/the department with respect to any aspect of the partners
membership (including but not limited to any initial invitations/requests
for membership, renewals, use of the membership, or anything else)

We will continue to process your revised FOI request and notify you of the
outcome after a decision is made on your request.

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [1][Department of Home Affairs request email]

Personal-Privacy
OFFICIAL: Sensitive

show quoted sections

OFFICIAL: Sensitive
Personal-Privacy

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

I refer to your request received on 3 February 2025 for access to
documents under the FOI Act.

The current due date for your request is 5 March 2025. The Department
seeks your agreement under section 15AA of the FOI Act to extend the
timeframe for the processing of your request by 30 days. This would
extend the due date for your request to Friday 4 April 2025.

The reason we are seeking an extension of time is due to demand for
Departmental documents is high and we continue to experience increasing
volumes of incoming requests particularly in recent months. Each request
received by the Department is managed in the context of this large volume
which can impact the timeliness of our decisions and as such we seek
agreement from applicants on extensions of time where possible. We
are endeavouring to ensure, as an applicant, you understand the likely
timeframe for your request to be finalised. We continue to try to process
requests as quickly as possible regardless of if an extension is
provided.

If you could please provide a response to this request by close of
business, 9 February 2025.

Kind regards

Jade

Position number 00011307

FOI Officer, Freedom of Information

Privacy, FOI and Records Management Branch | Legal Group

Department of Home Affairs

E: [1][Department of Home Affairs request email]

Personal-Privacy
OFFICIAL: Sensitive

Important Notice: The content of this email is intended only for use by
the individual or entity to whom it is addressed. If you have received
this email by mistake, please advise the sender and delete the message and
attachments immediately. This email, including attachments, may contain
confidential, sensitive, legally privileged and/or copyright information.

Any review, retransmission, dissemination or other use of this information
by persons or entities other than the intended recipient is prohibited.
The Department of Home Affairs, the ABF and the National Emergency
Management Agency respect your privacy and have obligations under the
Privacy Act 1988.

Unsolicited commercial emails MUST NOT be sent to the originator of this
email.

References

Visible links
1. mailto:[Department of Home Affairs request email]

OFFICIAL: Sensitive
Personal-Privacy

For Action by 26 January 2025

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

I refer to your email dated 3 February 2025, in which you requested access
to documents held by the Department Of Home Affairs (the Department) under
the Freedom of Information Act 1982 (the FOI Act).

You have requested access to the following:

I refer to the 'Annual disclosure of airline lounge memberships
(2024-2025) ' table at the following link:

https://www.homeaffairs.gov.au/reports-a...

The table lists 11 officials who have declared memberships of Qantas
Chairman's Lounge or Virgin's Beyond lounge.

Also listed with declared memberships are the partners of departmental
officials Stephanie Foster PSM Secretary, Gavan Reynolds ABF Commissioner,
Michelle McGuinness, and Hamish Hansford.

I request the following documents under the FOI Act:

1. For each of the named individuals, their total number of flights and
total expenditure, by airline, for the most recent available 12 month
period (only flights funded by Home Affairs)

2. Any documents that detail any assessments made as to the 'estimated
value' of these memberships (including those made by the individuals, or
Home Affairs).

3. Any documents that detail any reasons for accepting (or declining)
invitations to these exclusive airline lounges.

4. Any documents that are requests for advice from these individuals, or
advice given to these individuals, which touch on whether the memberships
are in accordance with applicable policies in relation to conflict of
interest, gifts, etc.

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.
I expand the scope of this item to also include any invitations the
airlines have sent in which the officials partners were invited to join
the lounges.

6. The declarations made by the officials with respect to their partners
membership, including the names of their partners, and any reasons given
as to why the membership was sought, offered, or accepted.

7. All correspondence between the airlines and the officials/their
partners/the department with respect to any aspect of the partners
membership (including but not limited to any initial invitations/requests
for membership, renewals, use of the membership, or anything else)

Intention to refuse request

I am writing to advise you that I intend to refuse your request on the
basis that a practical refusal reason exists. However, before I make a
final decision to do this, you have an opportunity to revise your request
to remove the practical refusal reason. This is called a ‘request
consultation process’. You have 14 days to respond to this notice in one
of the ways set out below.

Power to refuse request

Section 24 of the FOI Act provides that if the Department is satisfied
that a practical refusal reason exists in relation to a request, the
Department must undertake a consultation process with you, and if, after
that consultation process, the Department remains satisfied that the
practical refusal reason still exists, the Department may refuse to give
you access to the documents subject to the request.

Practical refusal

A practical refusal reason exists under section 24AA of the FOI Act if
either (or both) of the following applies:

(1)(a)(i) The work involved in the processing of the request would
substantially and unreasonably divert the resources of the Department from
its other operations

(1)(b) the request does not satisfy the requirement in section
15(2)(b) of the FOI Act, which requires you to provide such information
concerning the document you are seeking access to, to enable the
Department to be able to identify it.

I consider that the request does not satisfy the requirements of section
15(2)(b) of the FOI Act, and accordingly that practical refusal reasons
exist under section 24AA(1)(b) of the FOI Act.

Reasons for practical refusal

In order for your request to be valid for the purposes of the FOI Act, it
must provide such information concerning the documents that you are
seeking access to, as is reasonably necessary to enable the Department to
identify the documents.

Given the broad nature of the activities undertaken by the Department, I
do not consider that you have provided a reasonable description of the
documents to which you are seeking access.

As such, I am satisfied that your request is not valid and a practical
refusal reason exists in this request. You have not provided sufficient
information concerning the document you are seeking to access, to enable
the Department to be able to identify it.

Request Consultation Process

To enable the Department to consider your request for access under the FOI
Act, the Department will require sufficient information concerning the
specific existing documents to which you seek access, in order to enable
the Department to identify those documents.

You do not necessarily need to be able to identify the exact documents you
are seeking, but you need to provide the Department with sufficient
information to enable us to identify them. Given the very broad nature of
the functions that this Department has responsibility for, at a very
minimum, we will require advice as to which business areas might hold the
documents you are seeking to access. A copy of the Department’s
organisation chart is available on the Department’s website [1]here which
may assist you with this.

In addition, you may wish to consider providing a timeframe for your
request to assist the Department’s officers to reasonably be able to
identify the documents to which you seek access.

You now have an opportunity to revise your request to ensure it is a valid
request under section 15(2)(b) of the FOI Act and to enable it to proceed.

FOI and the relevant business area require your assistance to narrow down
the scope of your request due to its broad nature and the amount of
Departmental resources involved in processing this request.

• Please provide a specific date range that is relevant to your
overall request as the Business areas cannot conduct a search unless the
date range is provided. (Example 01/01/2024- 01/01/2025)

Under section 24AB(6) of the FOI Act, you have 14 days to do one of the
following:

· withdraw your request;

· make a revised request;

· Indicate that you do not wish to revise your request.

If you do not do one of the three things listed above during the
consultation period (14 days), or you do not consult the contact person
listed below during this period, your request will be taken to have been
withdrawn in accordance with section 24AB(7) of the FOI Act.

Contact

Should you wish to revise your request or have any questions in relation
to this process, please do not hesitate to contact the FOI section at
[Department of Home Affairs request email].

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [2][Department of Home Affairs request email]

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Personal-Privacy
OFFICIAL: Sensitive

show quoted sections

OFFICIAL: Sensitive
Personal-Privacy

Good morning Mr Squiggle (Right To Know),

I sincerely apologise for the last email that was sent to you with
incorrect due dates, these dates have been updated to the 26 February
2025.

Please disregard the previous PRN sent (Wednesday, 12 February 2025 11:16
AM)

For Action by 26 February 2025

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

I refer to your email dated 3 February 2025, in which you requested access
to documents held by the Department Of Home Affairs (the Department) under
the Freedom of Information Act 1982 (the FOI Act).

You have requested access to the following:

I refer to the 'Annual disclosure of airline lounge memberships
(2024-2025) ' table at the following link:

[1]https://www.homeaffairs.gov.au/reports-a...

The table lists 11 officials who have declared memberships of Qantas
Chairman's Lounge or Virgin's Beyond lounge.

Also listed with declared memberships are the partners of departmental
officials Stephanie Foster PSM Secretary, Gavan Reynolds ABF Commissioner,
Michelle McGuinness, and Hamish Hansford.

I request the following documents under the FOI Act:

1. For each of the named individuals, their total number of flights and
total expenditure, by airline, for the most recent available 12 month
period (only flights funded by Home Affairs)

2. Any documents that detail any assessments made as to the 'estimated
value' of these memberships (including those made by the individuals, or
Home Affairs).

3. Any documents that detail any reasons for accepting (or declining)
invitations to these exclusive airline lounges.

4. Any documents that are requests for advice from these individuals, or
advice given to these individuals, which touch on whether the memberships
are in accordance with applicable policies in relation to conflict of
interest, gifts, etc.

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.
I expand the scope of this item to also include any invitations the
airlines have sent in which the officials partners were invited to join
the lounges.

6. The declarations made by the officials with respect to their partners
membership, including the names of their partners, and any reasons given
as to why the membership was sought, offered, or accepted.

7. All correspondence between the airlines and the officials/their
partners/the department with respect to any aspect of the partners
membership (including but not limited to any initial invitations/requests
for membership, renewals, use of the membership, or anything else)

Intention to refuse request

I am writing to advise you that I intend to refuse your request on the
basis that a practical refusal reason exists. However, before I make a
final decision to do this, you have an opportunity to revise your request
to remove the practical refusal reason. This is called a ‘request
consultation process’. You have 14 days to respond to this notice in one
of the ways set out below.

Power to refuse request

Section 24 of the FOI Act provides that if the Department is satisfied
that a practical refusal reason exists in relation to a request, the
Department must undertake a consultation process with you, and if, after
that consultation process, the Department remains satisfied that the
practical refusal reason still exists, the Department may refuse to give
you access to the documents subject to the request.

Practical refusal

A practical refusal reason exists under section 24AA of the FOI Act if
either (or both) of the following applies:

(1)(a)(i) The work involved in the processing of the request would
substantially and unreasonably divert the resources of the Department from
its other operations

(1)(b) the request does not satisfy the requirement in section
15(2)(b) of the FOI Act, which requires you to provide such information
concerning the document you are seeking access to, to enable the
Department to be able to identify it.

I consider that the request does not satisfy the requirements of section
15(2)(b) of the FOI Act, and accordingly that practical refusal reasons
exist under section 24AA(1)(b) of the FOI Act.

Reasons for practical refusal

In order for your request to be valid for the purposes of the FOI Act, it
must provide such information concerning the documents that you are
seeking access to, as is reasonably necessary to enable the Department to
identify the documents.

Given the broad nature of the activities undertaken by the Department, I
do not consider that you have provided a reasonable description of the
documents to which you are seeking access.

As such, I am satisfied that your request is not valid and a practical
refusal reason exists in this request. You have not provided sufficient
information concerning the document you are seeking to access, to enable
the Department to be able to identify it.

Request Consultation Process

To enable the Department to consider your request for access under the FOI
Act, the Department will require sufficient information concerning the
specific existing documents to which you seek access, in order to enable
the Department to identify those documents.

You do not necessarily need to be able to identify the exact documents you
are seeking, but you need to provide the Department with sufficient
information to enable us to identify them. Given the very broad nature of
the functions that this Department has responsibility for, at a very
minimum, we will require advice as to which business areas might hold the
documents you are seeking to access. A copy of the Department’s
organisation chart is available on the Department’s website [2]here which
may assist you with this.

In addition, you may wish to consider providing a timeframe for your
request to assist the Department’s officers to reasonably be able to
identify the documents to which you seek access.

You now have an opportunity to revise your request to ensure it is a valid
request under section 15(2)(b) of the FOI Act and to enable it to proceed.

FOI and the relevant business area require your assistance to narrow down
the scope of your request due to its broad nature and the amount of
Departmental resources involved in processing this request.

• Please provide a specific date range that is relevant to your
overall request as the Business areas cannot conduct a search unless the
date range is provided. (Example 01/01/2024- 01/01/2025)

Under section 24AB(6) of the FOI Act, you have 14 days to do one of the
following:

· withdraw your request;

· make a revised request;

· Indicate that you do not wish to revise your request.

If you do not do one of the three things listed above during the
consultation period (14 days), or you do not consult the contact person
listed below during this period, your request will be taken to have been
withdrawn in accordance with section 24AB(7) of the FOI Act.

Contact

Should you wish to revise your request or have any questions in relation
to this process, please do not hesitate to contact the FOI section at
[3][Department of Home Affairs request email].

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [4][Department of Home Affairs request email]

Personal-Privacy
OFFICIAL: Sensitive

From: FOI
Sent: Wednesday, 12 February 2025 11:16 AM
To: 'Mr Squiggle' <[FOI #12805 email]>
Subject: CM: Practical Refusal Notice - FA 25/02/00104 - Due 26 January
2025 [SEC=OFFICIAL:Sensitive, ACCESS=Personal-Privacy]

OFFICIAL: Sensitive
Personal-Privacy

For Action by 26 January 2025

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

I refer to your email dated 3 February 2025, in which you requested access
to documents held by the Department Of Home Affairs (the Department) under
the Freedom of Information Act 1982 (the FOI Act).

You have requested access to the following:

I refer to the 'Annual disclosure of airline lounge memberships
(2024-2025) ' table at the following link:

[5]https://www.homeaffairs.gov.au/reports-a...

The table lists 11 officials who have declared memberships of Qantas
Chairman's Lounge or Virgin's Beyond lounge.

Also listed with declared memberships are the partners of departmental
officials Stephanie Foster PSM Secretary, Gavan Reynolds ABF Commissioner,
Michelle McGuinness, and Hamish Hansford.

I request the following documents under the FOI Act:

1. For each of the named individuals, their total number of flights and
total expenditure, by airline, for the most recent available 12 month
period (only flights funded by Home Affairs)

2. Any documents that detail any assessments made as to the 'estimated
value' of these memberships (including those made by the individuals, or
Home Affairs).

3. Any documents that detail any reasons for accepting (or declining)
invitations to these exclusive airline lounges.

4. Any documents that are requests for advice from these individuals, or
advice given to these individuals, which touch on whether the memberships
are in accordance with applicable policies in relation to conflict of
interest, gifts, etc.

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.
I expand the scope of this item to also include any invitations the
airlines have sent in which the officials partners were invited to join
the lounges.

6. The declarations made by the officials with respect to their partners
membership, including the names of their partners, and any reasons given
as to why the membership was sought, offered, or accepted.

7. All correspondence between the airlines and the officials/their
partners/the department with respect to any aspect of the partners
membership (including but not limited to any initial invitations/requests
for membership, renewals, use of the membership, or anything else)

Intention to refuse request

I am writing to advise you that I intend to refuse your request on the
basis that a practical refusal reason exists. However, before I make a
final decision to do this, you have an opportunity to revise your request
to remove the practical refusal reason. This is called a ‘request
consultation process’. You have 14 days to respond to this notice in one
of the ways set out below.

Power to refuse request

Section 24 of the FOI Act provides that if the Department is satisfied
that a practical refusal reason exists in relation to a request, the
Department must undertake a consultation process with you, and if, after
that consultation process, the Department remains satisfied that the
practical refusal reason still exists, the Department may refuse to give
you access to the documents subject to the request.

Practical refusal

A practical refusal reason exists under section 24AA of the FOI Act if
either (or both) of the following applies:

(1)(a)(i) The work involved in the processing of the request would
substantially and unreasonably divert the resources of the Department from
its other operations

(1)(b) the request does not satisfy the requirement in section
15(2)(b) of the FOI Act, which requires you to provide such information
concerning the document you are seeking access to, to enable the
Department to be able to identify it.

I consider that the request does not satisfy the requirements of section
15(2)(b) of the FOI Act, and accordingly that practical refusal reasons
exist under section 24AA(1)(b) of the FOI Act.

Reasons for practical refusal

In order for your request to be valid for the purposes of the FOI Act, it
must provide such information concerning the documents that you are
seeking access to, as is reasonably necessary to enable the Department to
identify the documents.

Given the broad nature of the activities undertaken by the Department, I
do not consider that you have provided a reasonable description of the
documents to which you are seeking access.

As such, I am satisfied that your request is not valid and a practical
refusal reason exists in this request. You have not provided sufficient
information concerning the document you are seeking to access, to enable
the Department to be able to identify it.

Request Consultation Process

To enable the Department to consider your request for access under the FOI
Act, the Department will require sufficient information concerning the
specific existing documents to which you seek access, in order to enable
the Department to identify those documents.

You do not necessarily need to be able to identify the exact documents you
are seeking, but you need to provide the Department with sufficient
information to enable us to identify them. Given the very broad nature of
the functions that this Department has responsibility for, at a very
minimum, we will require advice as to which business areas might hold the
documents you are seeking to access. A copy of the Department’s
organisation chart is available on the Department’s website [6]here which
may assist you with this.

In addition, you may wish to consider providing a timeframe for your
request to assist the Department’s officers to reasonably be able to
identify the documents to which you seek access.

You now have an opportunity to revise your request to ensure it is a valid
request under section 15(2)(b) of the FOI Act and to enable it to proceed.

FOI and the relevant business area require your assistance to narrow down
the scope of your request due to its broad nature and the amount of
Departmental resources involved in processing this request.

• Please provide a specific date range that is relevant to your
overall request as the Business areas cannot conduct a search unless the
date range is provided. (Example 01/01/2024- 01/01/2025)

Under section 24AB(6) of the FOI Act, you have 14 days to do one of the
following:

· withdraw your request;

· make a revised request;

· Indicate that you do not wish to revise your request.

If you do not do one of the three things listed above during the
consultation period (14 days), or you do not consult the contact person
listed below during this period, your request will be taken to have been
withdrawn in accordance with section 24AB(7) of the FOI Act.

Contact

Should you wish to revise your request or have any questions in relation
to this process, please do not hesitate to contact the FOI section at
[7][Department of Home Affairs request email].

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [8][Department of Home Affairs request email]

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Personal-Privacy
OFFICIAL: Sensitive

show quoted sections

OFFICIAL: Sensitive
Personal-Privacy

For Action by 26 February 2025

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Good morning Mr Squiggle (Right To Know),

Thank you for your email.

I refer to your response email dated Wed 12/02/2025 5:53 PM In reply to
the Practical Refusal Notice (PRN) sent to you from the FOI section on
Wednesday, 12 February 2025 11:49 AM,

Your response as Follows:

Dear FOI Officer
Thank you for your email.
I am happy to restrict the date range of my request to the period 1/7/2023
to 3/3/2025.
Yours sincerely,
Mr Squiggle

Please be advised the date range you provided cannot be accepted due to
seeking documents from a future date.

We can however accept a revised date range of 1/7/2023 to 12/02/2025.

Please Advise the FOI section if this date range will be sufficient for
your FOI request?

If you do require Documents from beyond the suggested time frames you can
lodge a separate FOI request.

Please respond by COB 26 February 2025.

Once we receive your reply we can continue to process your revised FOI
request and notify you of the outcome after a decision is made on your
request.

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [1][Department of Home Affairs request email]

Personal-Privacy
OFFICIAL: Sensitive

From: FOI
Sent: Wednesday, 12 February 2025 11:49 AM
To: '[FOI #12805 email]'
<[FOI #12805 email]>
Subject: CM: FW: Practical Refusal Notice - FA 25/02/00104 - Due 26
February 2025 [SEC=OFFICIAL:Sensitive, ACCESS=Personal-Privacy]

OFFICIAL: Sensitive
Personal-Privacy

Good morning Mr Squiggle (Right To Know),

I sincerely apologise for the last email that was sent to you with
incorrect due dates, these dates have been updated to the 26 February
2025.

Please disregard the previous PRN sent (Wednesday, 12 February 2025 11:16
AM)

For Action by 26 February 2025

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

I refer to your email dated 3 February 2025, in which you requested access
to documents held by the Department Of Home Affairs (the Department) under
the Freedom of Information Act 1982 (the FOI Act).

You have requested access to the following:

I refer to the 'Annual disclosure of airline lounge memberships
(2024-2025) ' table at the following link:

[2]https://www.homeaffairs.gov.au/reports-a...

The table lists 11 officials who have declared memberships of Qantas
Chairman's Lounge or Virgin's Beyond lounge.

Also listed with declared memberships are the partners of departmental
officials Stephanie Foster PSM Secretary, Gavan Reynolds ABF Commissioner,
Michelle McGuinness, and Hamish Hansford.

I request the following documents under the FOI Act:

1. For each of the named individuals, their total number of flights and
total expenditure, by airline, for the most recent available 12 month
period (only flights funded by Home Affairs)

2. Any documents that detail any assessments made as to the 'estimated
value' of these memberships (including those made by the individuals, or
Home Affairs).

3. Any documents that detail any reasons for accepting (or declining)
invitations to these exclusive airline lounges.

4. Any documents that are requests for advice from these individuals, or
advice given to these individuals, which touch on whether the memberships
are in accordance with applicable policies in relation to conflict of
interest, gifts, etc.

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.
I expand the scope of this item to also include any invitations the
airlines have sent in which the officials partners were invited to join
the lounges.

6. The declarations made by the officials with respect to their partners
membership, including the names of their partners, and any reasons given
as to why the membership was sought, offered, or accepted.

7. All correspondence between the airlines and the officials/their
partners/the department with respect to any aspect of the partners
membership (including but not limited to any initial invitations/requests
for membership, renewals, use of the membership, or anything else)

Intention to refuse request

I am writing to advise you that I intend to refuse your request on the
basis that a practical refusal reason exists. However, before I make a
final decision to do this, you have an opportunity to revise your request
to remove the practical refusal reason. This is called a ‘request
consultation process’. You have 14 days to respond to this notice in one
of the ways set out below.

Power to refuse request

Section 24 of the FOI Act provides that if the Department is satisfied
that a practical refusal reason exists in relation to a request, the
Department must undertake a consultation process with you, and if, after
that consultation process, the Department remains satisfied that the
practical refusal reason still exists, the Department may refuse to give
you access to the documents subject to the request.

Practical refusal

A practical refusal reason exists under section 24AA of the FOI Act if
either (or both) of the following applies:

(1)(a)(i) The work involved in the processing of the request would
substantially and unreasonably divert the resources of the Department from
its other operations

(1)(b) the request does not satisfy the requirement in section
15(2)(b) of the FOI Act, which requires you to provide such information
concerning the document you are seeking access to, to enable the
Department to be able to identify it.

I consider that the request does not satisfy the requirements of section
15(2)(b) of the FOI Act, and accordingly that practical refusal reasons
exist under section 24AA(1)(b) of the FOI Act.

Reasons for practical refusal

In order for your request to be valid for the purposes of the FOI Act, it
must provide such information concerning the documents that you are
seeking access to, as is reasonably necessary to enable the Department to
identify the documents.

Given the broad nature of the activities undertaken by the Department, I
do not consider that you have provided a reasonable description of the
documents to which you are seeking access.

As such, I am satisfied that your request is not valid and a practical
refusal reason exists in this request. You have not provided sufficient
information concerning the document you are seeking to access, to enable
the Department to be able to identify it.

Request Consultation Process

To enable the Department to consider your request for access under the FOI
Act, the Department will require sufficient information concerning the
specific existing documents to which you seek access, in order to enable
the Department to identify those documents.

You do not necessarily need to be able to identify the exact documents you
are seeking, but you need to provide the Department with sufficient
information to enable us to identify them. Given the very broad nature of
the functions that this Department has responsibility for, at a very
minimum, we will require advice as to which business areas might hold the
documents you are seeking to access. A copy of the Department’s
organisation chart is available on the Department’s website [3]here which
may assist you with this.

In addition, you may wish to consider providing a timeframe for your
request to assist the Department’s officers to reasonably be able to
identify the documents to which you seek access.

You now have an opportunity to revise your request to ensure it is a valid
request under section 15(2)(b) of the FOI Act and to enable it to proceed.

FOI and the relevant business area require your assistance to narrow down
the scope of your request due to its broad nature and the amount of
Departmental resources involved in processing this request.

• Please provide a specific date range that is relevant to your
overall request as the Business areas cannot conduct a search unless the
date range is provided. (Example 01/01/2024- 01/01/2025)

Under section 24AB(6) of the FOI Act, you have 14 days to do one of the
following:

· withdraw your request;

· make a revised request;

· Indicate that you do not wish to revise your request.

If you do not do one of the three things listed above during the
consultation period (14 days), or you do not consult the contact person
listed below during this period, your request will be taken to have been
withdrawn in accordance with section 24AB(7) of the FOI Act.

Contact

Should you wish to revise your request or have any questions in relation
to this process, please do not hesitate to contact the FOI section at
[4][Department of Home Affairs request email].

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [5][Department of Home Affairs request email]

Personal-Privacy
OFFICIAL: Sensitive

From: FOI
Sent: Wednesday, 12 February 2025 11:16 AM
To: 'Mr Squiggle' <[6][FOI #12805 email]>
Subject: CM: Practical Refusal Notice - FA 25/02/00104 - Due 26 January
2025 [SEC=OFFICIAL:Sensitive, ACCESS=Personal-Privacy]

OFFICIAL: Sensitive
Personal-Privacy

For Action by 26 January 2025

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle (Right To Know),

I refer to your email dated 3 February 2025, in which you requested access
to documents held by the Department Of Home Affairs (the Department) under
the Freedom of Information Act 1982 (the FOI Act).

You have requested access to the following:

I refer to the 'Annual disclosure of airline lounge memberships
(2024-2025) ' table at the following link:

[7]https://www.homeaffairs.gov.au/reports-a...

The table lists 11 officials who have declared memberships of Qantas
Chairman's Lounge or Virgin's Beyond lounge.

Also listed with declared memberships are the partners of departmental
officials Stephanie Foster PSM Secretary, Gavan Reynolds ABF Commissioner,
Michelle McGuinness, and Hamish Hansford.

I request the following documents under the FOI Act:

1. For each of the named individuals, their total number of flights and
total expenditure, by airline, for the most recent available 12 month
period (only flights funded by Home Affairs)

2. Any documents that detail any assessments made as to the 'estimated
value' of these memberships (including those made by the individuals, or
Home Affairs).

3. Any documents that detail any reasons for accepting (or declining)
invitations to these exclusive airline lounges.

4. Any documents that are requests for advice from these individuals, or
advice given to these individuals, which touch on whether the memberships
are in accordance with applicable policies in relation to conflict of
interest, gifts, etc.

5. Any requests sent by the named officials to the airlines in relation to
their partners' memberships (including any initial requests for their
partners to be given membership) and any airline response to these
requests.
I expand the scope of this item to also include any invitations the
airlines have sent in which the officials partners were invited to join
the lounges.

6. The declarations made by the officials with respect to their partners
membership, including the names of their partners, and any reasons given
as to why the membership was sought, offered, or accepted.

7. All correspondence between the airlines and the officials/their
partners/the department with respect to any aspect of the partners
membership (including but not limited to any initial invitations/requests
for membership, renewals, use of the membership, or anything else)

Intention to refuse request

I am writing to advise you that I intend to refuse your request on the
basis that a practical refusal reason exists. However, before I make a
final decision to do this, you have an opportunity to revise your request
to remove the practical refusal reason. This is called a ‘request
consultation process’. You have 14 days to respond to this notice in one
of the ways set out below.

Power to refuse request

Section 24 of the FOI Act provides that if the Department is satisfied
that a practical refusal reason exists in relation to a request, the
Department must undertake a consultation process with you, and if, after
that consultation process, the Department remains satisfied that the
practical refusal reason still exists, the Department may refuse to give
you access to the documents subject to the request.

Practical refusal

A practical refusal reason exists under section 24AA of the FOI Act if
either (or both) of the following applies:

(1)(a)(i) The work involved in the processing of the request would
substantially and unreasonably divert the resources of the Department from
its other operations

(1)(b) the request does not satisfy the requirement in section
15(2)(b) of the FOI Act, which requires you to provide such information
concerning the document you are seeking access to, to enable the
Department to be able to identify it.

I consider that the request does not satisfy the requirements of section
15(2)(b) of the FOI Act, and accordingly that practical refusal reasons
exist under section 24AA(1)(b) of the FOI Act.

Reasons for practical refusal

In order for your request to be valid for the purposes of the FOI Act, it
must provide such information concerning the documents that you are
seeking access to, as is reasonably necessary to enable the Department to
identify the documents.

Given the broad nature of the activities undertaken by the Department, I
do not consider that you have provided a reasonable description of the
documents to which you are seeking access.

As such, I am satisfied that your request is not valid and a practical
refusal reason exists in this request. You have not provided sufficient
information concerning the document you are seeking to access, to enable
the Department to be able to identify it.

Request Consultation Process

To enable the Department to consider your request for access under the FOI
Act, the Department will require sufficient information concerning the
specific existing documents to which you seek access, in order to enable
the Department to identify those documents.

You do not necessarily need to be able to identify the exact documents you
are seeking, but you need to provide the Department with sufficient
information to enable us to identify them. Given the very broad nature of
the functions that this Department has responsibility for, at a very
minimum, we will require advice as to which business areas might hold the
documents you are seeking to access. A copy of the Department’s
organisation chart is available on the Department’s website [8]here which
may assist you with this.

In addition, you may wish to consider providing a timeframe for your
request to assist the Department’s officers to reasonably be able to
identify the documents to which you seek access.

You now have an opportunity to revise your request to ensure it is a valid
request under section 15(2)(b) of the FOI Act and to enable it to proceed.

FOI and the relevant business area require your assistance to narrow down
the scope of your request due to its broad nature and the amount of
Departmental resources involved in processing this request.

• Please provide a specific date range that is relevant to your
overall request as the Business areas cannot conduct a search unless the
date range is provided. (Example 01/01/2024- 01/01/2025)

Under section 24AB(6) of the FOI Act, you have 14 days to do one of the
following:

· withdraw your request;

· make a revised request;

· Indicate that you do not wish to revise your request.

If you do not do one of the three things listed above during the
consultation period (14 days), or you do not consult the contact person
listed below during this period, your request will be taken to have been
withdrawn in accordance with section 24AB(7) of the FOI Act.

Contact

Should you wish to revise your request or have any questions in relation
to this process, please do not hesitate to contact the FOI section at
[9][Department of Home Affairs request email].

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [10][Department of Home Affairs request email]

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Personal-Privacy
OFFICIAL: Sensitive

show quoted sections

OFFICIAL: Sensitive
Personal-Privacy

In reply please quote:

FOI Request: FA 25/02/00104

File Number: FA25/02/00104

Dear Mr Squiggle.

Thank you for revising the scope of your FOI request.

On 14/02/2025 you amended the scope of your request to:

Thank you for your email. I am happy to restrict the date range to
1/7/2023 to 12/02/2025. Yours sincerely, Mr Squiggle.

We will continue to process your revised FOI request and notify you of the
outcome after a decision is made on your request.

Kind regards,

Leigh
Authorised FOI Officer, Freedom of Information
Position Number 60201191

Privacy, FOI and Records Management Branch

Legal Group

Department of Home Affairs

E: [1][Department of Home Affairs request email]

Personal-Privacy
OFFICIAL: Sensitive

Important Notice: The content of this email is intended only for use by
the individual or entity to whom it is addressed. If you have received
this email by mistake, please advise the sender and delete the message and
attachments immediately. This email, including attachments, may contain
confidential, sensitive, legally privileged and/or copyright information.

Any review, retransmission, dissemination or other use of this information
by persons or entities other than the intended recipient is prohibited.
The Department of Home Affairs, the ABF and the National Emergency
Management Agency respect your privacy and have obligations under the
Privacy Act 1988.

Unsolicited commercial emails MUST NOT be sent to the originator of this
email.

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