Our reference: FOI 24/25-0985
GPO Box 700
Canberra ACT 2601
1800 800 110
17 February 2025
ndis.gov.au
Nosey
By email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Nosey
Freedom of Information request — Notification of Decision
Thank you for your correspondence of 14 December 2024, in which you requested access to
documents held by the National Disability Insurance Agency (NDIA), under the
Freedom of
Information Act 1982 (FOI Act).
Scope of your request
You have requested access to the fol owing documents:
“…I seek access to any and all documents, records, data, and supporting material held by
[Name of Agency] concerning the sharing of personal information originating from the
Department of Veterans’ Affairs (DVA) over the last ten years. This includes any data
transfers from or to the DVA, whether they were one-off exchanges or ongoing, systematic
transfers of DVA client information, including personal, medical, financial, or service-related
details concerning veterans or their dependents.
I am interested in obtaining a comprehensive understanding of what DVA client information
[Authority name] has received or accessed and for what purposes. Specifically, I request:
Al records of data sharing arrangements between DVA and [Authority name], including but
not limited to memoranda of understanding, service-level agreements, emails, letters,
meeting minutes, file transfer logs, internal reports, and instructions that outline what data
was shared, when it was shared, and the format or system used for the transfer.
Any policies, procedures, guidelines, or frameworks that govern how [Authority name]
requests, obtains, stores, handles, or uses DVA client information. This includes documents
that detail the criteria for approving access to such data, any consent or authorization
processes, security controls, and retention or destruction policies.
Copies of any ethics committee approvals, privacy impact assessments, internal review
board decisions, or other documents that reflect deliberations or authorizations for obtaining
DVA client information. This includes records that show the agency considered the ethical,
legal, or privacy implications of receiving or using DVA client data.
Documents that outline the intended uses or practical applications of the DVA client data,
such as project proposals, business cases, internal strategy papers, or briefings that explain
1
why [Authority name] sought access to this information, how it was intended to be integrated
into the agency’s operations, and any expected outcomes or benefits.
A representative sample (in a suitably de-identified or redacted form) of the data or data
fields received, so long as providing this sample does not breach any exemption under the
FOI Act. The purpose is to understand the nature and granularity of the information shared,
without disclosing identifiable personal details.
If the only data [Authority name] received pertains solely to data linked to the Centrelink
Confirmation eServices (CCeS) arrangements as described at [link provided], and there
were no other forms of DVA data shared, then no CCeS-related data needs to be provided
under this request…”
Consultation period
I wrote to you via email on 15 and 22 January to propose a revised scope that would allow
us to continuing processing your request. You responded on 26 January 2025 stating that
you did not approve a revision of scope.
I wrote to you on 29 January 2025 notifying my intention to refuse your request. This was as
the work involved in processing your request would substantially and unreasonably divert the
resources of the NDIA from its other operations due to its size and complexity. This is called
a “practical refusal reason” under section 24AA of the FOI Act.
In that letter, you were invited to revise the scope of your request, withdraw the request or
indicate you did not wish to revise the scope.
You did not respond to this letter within the 14 day timeframe, and as such, we assume that
you wish to proceed with your original request.
Decision on access to documents
I am authorised to make decisions under section 23(1) of the FOI Act. My decision on your
request and the reasons for my decision are set out below.
I have decided to refuse your request for access under section 24A of the FOI Act.
In reaching my decision, I took the fol owing into account:
• your correspondence outlining the scope of your request
• the FOI Act
• the FOI Guidelines published under section 93A of the FOI Act
• consultation with relevant officers of the NDIA
2
• the NDIA’s operating environment and functions.
Reasons for decision
As you have declined to reduce the scope of your request, the practical refusal reason stil
exists and I have decided to refuse access on this basis.
You have not confirmed if the NDIA is the agency from which you seek documents, as you
have not referred to the National Disability Insurance Agency or the NDIA in the request.
Your request instead refers to “Name of Agency” and “Authority name.” These terms are
unclear.
We have consulted with relevant NDIA staff who could be expected to be able to identify
documents within the scope of the request, including staff who are knowledgeable about
how to conduct searches of the NDIA’s systems. This outcome shows that the terms of your
request do not provide sufficient information to allow us to identify the specific documents
that you are seeking.
In addition, the request is very broad and covers a date range of more than 10 years. You
have not provided a targeted document type or category, rather you have requested “any
and all”. As such, searches would have to be conducted across every business unit of the
NDIA. The NDIA has over 25 different divisions. To do a comprehensive search, we would
have to do consultations with all of them to locate “any and all” documents held by the NDIA.
In addition, searches would be required across multiple systems including:
• PACE case management system
• CRM case management system
• LEX case management system
• Content Manager document holding system
• SharePoint document management system
• The entirety of the NDIA email system, requiring specialist IT support
• General computer files
• Paper files
3
The documents assessed as being within scope of the request wil then need to be reviewed
for any sensitivities and possible exemption under the FOI Act and scheduled, we wil need
to consider any consultations and carry these out if required, a decision wil need to be made
on each document, and a decision letter prepared. This wil significantly increase the time
that it wil take an FOI officer to process your request.
As a result, I am of the view that the work involved in the processing of this request would
substantial y and unreasonably divert the resources of the NDIA from its other operations.
Rights of review
Your rights to seek a review of my decision, or lodge a complaint, are set out at
Attachment A.
Should you have any enquiries concerning this matter, please do not hesitate to contact me
by email at xxx@xxxx.xxx.xx.
Yours sincerely
Cindy – CGN062
Senior Freedom of Information Officer
Complaints Management & FOI Branch
General Counsel Division
4
34566789
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