PO Box 7820, Canberra BC ACT 2610
22 September 2023
Our reference: LEX 76033
Renee
Only by email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Sir / Madam,
Acknowledgement and Request Consultation Notice
I refer to your request for access to documents under the Freedom of Information Act 1982
(the FOI Act). You requested access to:
I am writing to submit a formal Freedom of Information (FOI) request under the
Freedom of Information Act 1982 for access to documents and information related to
measures taken to ensure accessibility to your services, both in person and online, for
people with disabilities.
I am specifical y interested in obtaining any information, documents, and data
pertaining to the fol owing areas:
1. Inclusive Accessibility Measures: Any policies, guidelines, or initiatives
implemented to enhance accessibility for individuals with disabilities, including but not
limited to those with physical, sensory, cognitive, intel ectual, and psychosocial
disabilities.
2. Communication and Language, Inclusion and Accessibility: Information regarding
inclusive communication supports, inclusive language accessibility, and inclusive
accommodations provided to ALL individuals with disabilities, whether they are
nonverbal or have other unique ways of communicating, including neurodivergent and
autistic individuals who may require in-person communication.
3. Sensory-Appropriate Spaces: Details on the creation and maintenance of sensory-
appropriate spaces to accommodate neurodivergent individuals and those with
sensory sensitivities.
4. Face-to-Face Service Accessibility: Information on access to face-to-face services
for individuals who require in-person communication for accessibility purposes with
your agency.
5. Cognitive and Intel ectual Disabilities: Any measures taken to address the needs of
individuals with cognitive and intel ectual disabilities to ensure they can access and
benefit from your services.
PAGE 1 OF 8
6. Psychosocial Disabilities: Policies and practices related to the inclusion and
support of individuals with psychosocial disabilities to promote their participation in
your programs and services.
7. Accommodations: Details on accommodations that have been made for individuals
with disabilities to access your services effectively.
8. Targeted Measures for Direct Engagement: Details about any targeted measures
or initiatives undertaken to directly engage with individuals with disabilities (not just
organizations representing them) to assess their needs and preferences, as wel as
ways to provide them with opportunities to participate and provide feedback.
9. Accessibility Policies and Guidelines: Copies of internal accessibility policies,
guidelines, or procedures, as wel as any relevant training materials for staff and
service providers.
10. Internal Processes: Information on the internal processes and mechanisms in
place to monitor and improve accessibility, including any data or reports related to
accessibility outcomes.
I kindly request a copy of al relevant documents, reports, policies, emails, meeting
minutes, and any other materials that pertain to the above topics. Please provide the
most recent and up-to-date information available as wel as any other older
documents or information. As far back as possible.
Additional y, I request any other relevant documents or information relating to this
topic that may be of interest. Please provide information in any form it is available,
whether written by hand, in a document, memo, note, PDF file, MP3, MP4, or any
other type of file or document. Please include any data or reports that may be
relevant.
Currently your request does not sufficiently identify the documents you require.
Services Australia (the Agency) is formal y consulting with you under section 24AB of the FOI
Act.
This letter is giving you an opportunity to provide us with specific information about the
documents you need. Providing this additional information wil assist the Agency in
processing your request.
If you decide not to provide further information or revise your request, I wil have to refuse
your freedom of information (FOI) request as a 'practical refusal reason' exists. For a more
detailed explanation of what this means, including some suggestions on what to consider
when revising your request, please see Attachment A.
How to send us a 'revised request'
Before I make a final decision on your request, you can submit a revised request.
Within the next 14 days (consultation period) you must do one of the fol owing, in writing:
withdraw the request
make a revised request, or
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tel us you do not want to revise your request.
The consultation process begins the day after the day you receive this notice. Accordingly,
your response is expected by 6 October 2023.
If you do not contact us during the consultation period, your matter wil be taken as
withdrawn by operation of the FOI Act. See Attachment A for relevant sections of the FOI
Act.
If you decide to make a revised request you should be specific about the documents you
want. This could help the Agency find the documents.
Contact officer
I am the contact officer for your request. During the consultation period you are welcome to
ask for my help in revising your request. You can contact me:
in writing to the address at the top of this letter, or
via email to xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx
Note: When you contact us please quote the reference number FOI LEX 76033.
Timeframe for processing your request
Your request was received by the Agency on 17 September 2023. The 30 day statutory
period for processing your request commenced from the day after that date. However the
time taken to consult with you now is not included in this 30 day time period.
The timeframe for processing your request may also be extended if we need to consult third
parties or for other reasons. We wil advise you if this happens.
Charges
The Agency wil advise you if a charge is payable to process your request and the amount of
any such charge as soon as practicable. No charge is payable for providing a person with
their own personal information.
Your Address
The FOI Act requires you provide us with an address which we can send notices to. You
have advised your electronic address is xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx.
We wil send al notices and correspondence to this address. Please advise us as soon as
possible if you wish correspondence to be sent to another address or if your address
changes. If you do not advise us of changes to your address, correspondence and notices
wil continue to be sent to the address specified above.
Administrative Release of Documents
The Agency has administrative access arrangements (arrangements) for the release of
certain documents without the need for a formal FOI request. Unless you advise us
otherwise, in processing your request we may provide you with documents under these
arrangements where appropriate. The arrangements do not extend to information or
materials of third parties. You wil be notified when documents are released to you under the
arrangements.
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Disclosure Log
Please note information released under the FOI Act may be published in a disclosure log on
the Agency's website. Section 11C of the FOI Act requires this publication, however it is
subject to certain exceptions, including where publication of personal, business, professional
or commercial information would be unreasonable.
Exclusion of junior staff details
The Agency is working towards ensuring al staff have a choice about whether they provide
their ful name, personal logon identifiers and direct contact details in response to public
enquiries. Where such details are included in the scope of a request, this may add to
processing time and applicable charges as it may be necessary to consider whether the
details are exempt under the FOI Act. On this basis, unless you tel us otherwise, we wil
assume these details are out of scope of your request and they wil be redacted under
Further assistance
If you have any questions please email xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx.
Yours sincerely
Elizabeth
FOI Practitioner
FOI and Ombudsman Branch | Legal Services Division
Services Australia
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PO Box 7820, Canberra BC ACT 2610
Attachment A
What I took into account
You requested access under the FOI Act to the fol owing documents:
I am writing to submit a formal Freedom of Information (FOI) request under the
Freedom of Information Act 1982 for access to documents and information related to
measures taken to ensure accessibility to your services, both in person and online, for
people with disabilities.
I am specifical y interested in obtaining any information, documents, and data
pertaining to the fol owing areas:
1. Inclusive Accessibility Measures: Any policies, guidelines, or initiatives
implemented to enhance accessibility for individuals with disabilities, including but not
limited to those with physical, sensory, cognitive, intel ectual, and psychosocial
disabilities.
2. Communication and Language, Inclusion and Accessibility: Information regarding
inclusive communication supports, inclusive language accessibility, and inclusive
accommodations provided to ALL individuals with disabilities, whether they are
nonverbal or have other unique ways of communicating, including neurodivergent and
autistic individuals who may require in-person communication.
3. Sensory-Appropriate Spaces: Details on the creation and maintenance of sensory-
appropriate spaces to accommodate neurodivergent individuals and those with
sensory sensitivities.
4. Face-to-Face Service Accessibility: Information on access to face-to-face services
for individuals who require in-person communication for accessibility purposes with
your agency.
5. Cognitive and Intel ectual Disabilities: Any measures taken to address the needs of
individuals with cognitive and intel ectual disabilities to ensure they can access and
benefit from your services.
6. Psychosocial Disabilities: Policies and practices related to the inclusion and
support of individuals with psychosocial disabilities to promote their participation in
your programs and services.
7. Accommodations: Details on accommodations that have been made for individuals
with disabilities to access your services effectively.
8. Targeted Measures for Direct Engagement: Details about any targeted measures
or initiatives undertaken to directly engage with individuals with disabilities (not just
organizations representing them) to assess their needs and preferences, as wel as
ways to provide them with opportunities to participate and provide feedback.
9. Accessibility Policies and Guidelines: Copies of internal accessibility policies,
guidelines, or procedures, as wel as any relevant training materials for staff and
service providers.
10. Internal Processes: Information on the internal processes and mechanisms in
place to monitor and improve accessibility, including any data or reports related to
PAGE 5 OF 8
accessibility outcomes.
I kindly request a copy of al relevant documents, reports, policies, emails, meeting
minutes, and any other materials that pertain to the above topics. Please provide the
most recent and up-to-date information available as wel as any other older
documents or information. As far back as possible.
Additional y, I request any other relevant documents or information relating to this
topic that may be of interest. Please provide information in any form it is available,
whether written by hand, in a document, memo, note, PDF file, MP3, MP4, or any
other type of file or document. Please include any data or reports that may be
relevant.
Publicly available information
The Agency holds many publicly available documents that define the organisations’
understanding of disability and directs the overal strategy to ensure al users can access and
benefit from the services provided. They have been provided to you below.
Operational Blueprints
Operational Blueprints are internal Agency documents which outline the Agency’s policies
and procedures.
Two Operational Blueprints have been identified as procedures to guide Agency employees
when interacting with customers with disabilities. These documents are publicly available and
can be found at the fol owing links:
Identifying customer vulnerability and risk issues 003-06010030
https://operational.servicesaustralia.gov.au/public/Pages/help-in-an-emergency/003-
06010030-01.html
Providing services to customers with disabilities 008-01030000
01030000-01.html
Website
As a Federal Government Agency, our values are underpinned by the Australian Disability
Strategy 2021-2023. More information on this can be found on our website at the fol owing
link:
https://www.servicesaustralia.gov.au/protocol-for-engaging-people-with-
disability?context=1
Disclosure Log
The FOI Disclosure Log lists Agency information that has been released in response to
historical FOI requests. On 12 April 2023, we released ‘Our Vulnerability Strategy- July 2021’
under FOI. This strategy outlines how the Agency supports our vulnerable customers. You
may request a copy of the strategy by emailing
xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxx.xxx,au and requesting the disclosure log documents
in relation to LEX 72499.
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Further assistance
If your request is not met by the publicly available documents above, you may wish to revise
your request so we are able to process it.
In your request, you have referred to ‘information’ and ‘data’. Under the FOI Act, applicants
can request access to specific documents an agency holds. Requests for ‘information’ or
‘data’ are more general in nature and are unable to be processed under the FOI Act.
Considering this, you may wish to remove this wording from your request and identify the
specific documents you wish to access.
Further, the point of your request where you have requested ‘any other relevant documents
or information relating to this topic which might be of interest’, is unclear as it does not
reference a specific document held by the Agency. Therefore, you may wish to consider
withdrawing this part of your request.
You have specified that you are requesting documents from ‘as far back as possible’. A
request of this size may potential y be too voluminous for the Agency to process, as it may
unreasonably divert our resources. To assist us in processing your request, it would be
appreciated if you could specify a date, for example, our current policies or limit the date
range of the request.
If you do not revise your request, I intend to refuse your FOI request as a 'practical refusal
reason' exists under sections 24AA(1)(b) and 24 of the FOI Act. Under the FOI Act, the
practical refusal reason is your request does not satisfy the requirements in section 15(2)(b)
of the FOI Act (identification of documents).
Assistance with your request
In summary, I seek clarification on whether your request is met by the publicly available
documents.
Alternatively, you may wish to revise your request. I suggest the fol owing scope, as it would
remove the ambiguous language and provide a date range, this would enable us to process
the request.
Policies, guidelines, or documents place concerning current initiatives impacting our
customers, in regards to the fol owing:
1. Inclusive Accessibility Measures
2. Communication, language, inclusion, and accessibility
3. Creation and maintenance of Sensory-Appropriate Spaces
4. Access to Face-to-Face Service Accessibility
5. Support for customers with cognitive and intel ectual disabilities
6. Support for customers with psychosocial disability
7. Accommodations that have been made for customers with a disability
8. Targeted measures for direct engagement for customers with a disability
9. Training materials for staff when interacting with customer with disabilities
PAGE 7 OF 8
10. Mechanisms to monitor and improve accessibility
Relevant sections of the FOI Act
Section 24AA(1)(b) of the FOI Act provides a practical refusal reason exists in relation to a
request for a document if the request does not satisfy the requirement in section 15(2)(b) of
the FOI Act.
Section 15(2)(b) of the FOI Act provides a request must provide such information as is
reasonably necessary to enable the Agency to identify the documents are being requested.
Section 24AB(6) provides the applicant must, before the end of the consultation period, do
one of the fol owing, by written notice to the Agency:
withdraw the request
make a revised request, or
indicate that the applicant does not wish to revise the request.
Section 24AB(7) of the FOI Act provides the request is taken to have been withdrawn at the
end of the consultation period if:
the applicant does not consult the contact person during the consultation period in
accordance with the notice, or
the applicant does not do one of the things mentioned in subsection (6) before the
end of the consultation period.
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