If not delivered return to PO Box 7820 Canberra BC ACT 2610
12 May 2025
Our reference: LEX 84090
MatureData (Right to Know)
Only by email
: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear MatureData
Decision on your Freedom of Information Request
I refer to your request received by Services Australia (the Agency) on 10 March 2025 and
revised on 19 and 26 March 2025, for access under the
Freedom of Information Act 1982 (the
FOI Act) to the following documents:
In the APS Data, Digital and Cyber Workforce Plan 2025-30, there was a case study
about Services Australia enterprise architect recruitment pilot which references "A
comprehensive labour market analysis was conducted to pinpoint talent trends and
fine-tune recruitment strategies." I request:
• The analytical documents/reports that were prepared to support the labour
market analysis.
• The labour market analysis specifically done on Enterprise Architects
• A presentation slide which summarises the research and learnings
• The early approval email that includes the project scope, which covers the
research that was planned
• The project closure report, which also covers the labour market analysis.
My decision
The Agency holds 6 documents (totalling 42 pages) that relate to your request.
I have decided to:
• grant you
full access to 2 documents (Documents 1 and 5), and
• grant you
part access to 4 documents (Documents 2, 3, 4 and 6) with some of the
content removed.
I have decided certain parts of documents you have requested are exempt under the FOI Act
because they contain:
PAGE 1 OF 11
• information that if disclosed could have a substantial adverse effect on the financial or
property interests of the Commonwealth or of an Agency, and release would be
contrary to the public interest (section 47D conditional exemption),
• information which if disclosed, would have a substantial adverse effect on the proper
and efficient conduct of the operations of the Agency, and release would be contrary
to the public interest (section 47E(d) conditional exemption), and
• personal information about other people, and release would be contrary to the public
interest (section 47F(1) conditional exemption).
In addition, I have determined it is appropriate for irrelevant information outside the scope of
your request to be deleted from the documents in accordance with section 22 of the FOI Act.
Please see the schedule at
Attachment A to this letter for a detailed list of the documents and
the reasons for my decision, including the relevant sections of the FOI Act.
How we wil send the documents to you
The documents are attached.
You can ask for a review of our decision
If you disagree with any part of the decision you can ask for a review. There are two ways you
can do this. You can ask for an internal review from within the Agency, or an external review
by the Of ice of the Australian Information Commissioner. See
Attachment B for more
information about how to request a review.
Further assistance
If you have any questions, please ema
il xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx. Yours sincerely
Leanne
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Reviews Branch | Legal Services Division
Services Australia
PAGE 2 OF 11
If not delivered return to PO Box 7820 Canberra BC ACT 2610
REASONS FOR DECISION
What you requested
In the APS Data, Digital and Cyber Workforce Plan 2025-30, there was a case study
about Services Australia enterprise architect recruitment pilot which references a "A
comprehensive labour market analysis was conducted to pinpoint talent trends and
fine-tune recruitment strategies."
I'm seeking all documents relating to that comprehensive labour market analysis.
On 19 March 2025 the Agency formally consulted with you under section 24AB of the FOI Act.
You provided a response on 20 March 2025. We wrote to you again on 26 March 2025 to seek
further clarification on the scope of your request. You revised your request, and this was
confirmed by email on the same date.
Your revised request was:
In the APS Data, Digital and Cyber Workforce Plan 2025-30, there was a case study
about Services Australia enterprise architect recruitment pilot which references "A
comprehensive labour market analysis was conducted to pinpoint talent trends and
fine-tune recruitment strategies." I request:
• The analytical documents/reports that were prepared to support the labour
market analysis.
• The labour market analysis specifically done on Enterprise Architects
• A presentation slide which summarises the research and learnings
• The early approval email that includes the project scope, which covers the
research that was planned
• The project closure report, which also covers the labour market analysis.
Also on 26 March 2025, the Agency acknowledged your request and sought your consent to
exclude personal details about our staff (such as their names) We also advised we needed
additional time to process your request and asked for a 21 day extension of time.
We wrote to you again on 31 March 2025 regarding our request for additional time to process
your request. On 31 March 2025 by return email, you provided your agreement to the extension
of time making the new due date 1 May 2025. The Of ice of the Australian Information
Commissioner was advised of the extension. You also consented to exclude staff details;
therefore, staff details have been redacted in accordance with section 22(1) of the FOI Act.
On 17 April 2025 we wrote to you again to advise we needed additional time to process your
request and asked for a further 9 day extension of time. You provided you agreement by return
email on the same day, making the new due date 12 May 2025. The Of ice of the Australian
Information Commissioner was advised of the extension.
PAGE 5 OF 11
What I took into account
In reaching my decision I took into account:
• your original request dated 10 March 2025
• your revised request on 19 and 26 March 2025
• other discussions and correspondence with you
• the documents which fall within the scope of your request
• whether the release of material is in the public interest
• consultations with Agency officers about:
o the nature of the documents
o the Agency's operating environment and functions
• guidelines issued by the Australian Information Commissioner under section 93A of
the FOI Act (the Guidelines), and
• the FOI Act.
Reasons for my decision
I am authorised to make decisions under section 23(1) of the FOI Act.
I have decided certain parts of documents you requested are exempt under the FOI Act. My
findings of fact and reasons for deciding the exemption applies to those documents are
discussed below.
Financial or property interests of the Commonwealth
I have applied the conditional exemption in section 47D of the FOI Act to parts of Documents
2 and 3.
This section of the FOI Act allows the Agency to exempt material from a document if its
disclosure would have a substantial adverse effect on the financial or property interests of the
Commonwealth, of Norfolk Island or of an Agency.
Financial or property interests refer to a variety of things including assets and expenditure. I
find Documents 2 and 3 relate to the Agency’s workforce and I am satisfied this information
relates to the financial interests of the Agency including separation rates, labour supply and
salary data.
Should the exempt material in Documents 2 and 3 be released to you and, in turn, into the
wider public domain, (noting that the FOI Act does not control or restrict use or dissemination
of the information once released in response to an FOI request), this would have a substantial
adverse effect on the financial interests of the Agency, specifically in seeking value for money
through the engagement vendors to supply a contractor workforce. I consider disclosure would
provide an unfair advantage to vendors in future recruitment processes. This would materially
compromise the Agency’s ability to obtain vendor services at a competitive commercial rate
and conduct fair and reasonable recruitment processes in the future.
For the reasons detailed above, I am satisfied parts of Documents 2 and 3 as outlined in the
Schedule are exempt under section 47D of the FOI Act.
PAGE 6 OF 11
Unreasonable disclosure of personal information
I have applied the conditional exemption in section 47F(1) of the FOI Act to parts of Documents
2, 3 and 6.
This section of the FOI Act allows the Agency to exempt material from a document if its release
would involve the unreasonable disclosure of personal information about any other person.
Personal information is information or an opinion about an identified individual, or an individual
who is reasonably identifiable. For example, it can include a person’s name, contact details,
date of birth, medical records, bank account details, taxation information and signature.
I find Document 6 as referred to in the Schedule contains personal information of other people,
including a signature of a senior Agency employee.
In addition, I find Documents 2, 3 and 6 contain workforce and recruitment metrics, candidate
profile data and head count numbers. I am satisfied that releasing such information as specific
job roles and locations accompanied with some of the small figures captured in the statistical
information would potentially identify the Agency staff members and third parties.
While I am not suggesting you would misuse the exempt information in any way, the FOI Act
does not control or restrict use or dissemination of the information once released so I must
consider actions any member of the public might take.
I am satisfied the disclosure of the third party personal information would be unreasonable for
the following reasons:
• the material relates to aspects of individuals personal affairs
• you do not have the consent from the individuals for the release of their personal
information
• the information is private and not available in ful or in part from publicly accessible
sources, and
• the identity of the individual concerned is readily apparent or could be easily
ascertained.
On this basis, I have decided the personal information included in Documents 2, 3 and 6
referred to in the Schedule is conditionally exempt under section 47F(1) of the FOI Act.
Public interest considerations
Section 11A(5) of the FOI Act provides that access to conditionally exempt material must be
given unless I am satisfied it would not be in the public interest to do so.
When weighing up the public interest for and against disclosure I have considered the relevant
factors in favour of disclosure. Particularly the extent to which disclosure would promote the
objects of the FOI Act and inform debate on a mat er of public importance.
I have also considered the relevant factors weighing against disclosure, indicating access
would be contrary to the public interest. I have considered the extent to which disclosure of the
exempt material could reasonably be expected to prejudice an individual’s right to privacy and
adversely affect or harm the interests of an individual or group of individuals.
PAGE 7 OF 11
I find there is little public interest in the disclosure of the third parties’ personal information,
beyond allowing you to access information contained that may be relevant to your request. I
do not see that there would be any public purpose achieved through release, and release of
this personal information would not advance the public interest in government transparency
and integrity.
Based on these factors, I am satisfied in this instance the public interest in disclosing the
information in the above-mentioned documents is outweighed by the public interest against
disclosure.
I have not taken into account any of the irrelevant factors set out in section 11B(4) of the FOI
Act in forming this view.
Operations of the Agency
I have applied the conditional exemption in section 47E(d) of the FOI Act to parts of Document
4.
This section of the FOI Act provides a document is conditionally exempt if it would have a
substantial adverse effect on the Agency’s ability to conduct its operations efficiently and
properly.
Document 4 contains Agency positional mailboxes. I consider that releasing the exempt
material to you would negatively affect the conduct of the operations of the Agency. This is
because the Agency’s purpose is to provide high-quality government services and payments
to Australians. It is a large, public facing, government organisation with many points of contact
designed to facilitate its purpose. The Agency has established channels of communication for
customers and members of the public, which have been put in place to ensure the effective
management of the significant volume of communication received.
Such channels include dedicated and externally published positional mailboxes of dif erent
business areas within the Agency. These have been established to ensure correspondence is
directed to the correct area and actioned accordingly.
If internal positional mailbox details were to be made publicly available, correspondence
received and directed could be mishandled, lost, duplicated or double-handled on account of
it not being directed to the most appropriate teams through the publicly available
communication channels. Noting the Agency’s interactions with the public number in the
hundreds of mil ions, diverting people from correct channels cannot be appropriately
categorised as insubstantial or nominal.
Whilst I have no reason to believe you would misuse the exempt material in this way, the FOI
Act does not control or restrict use or dissemination of the information once released, so I must
consider actions any member of the public might take once the information enters the public
domain and is available to the world at large.
Public Interest
Access to conditionally exempt material must be given unless I am satisfied it would not be in
the public interest to do so.
I consider the disclosure of the material would generally promote the objects of the FOI Act,
which is in the public interest. However, I also considered the disclosure of the Agency’s
positional mailboxes would prejudice the Agency’s ability to effectively and efficiently manage
contact with the public.
PAGE 8 OF 11
Based on these factors, I am satisfied in this instance, the public interest in disclosing the
information in the above-mentioned document is outweighed by the public interest against
disclosure. For the reasons set out above, I am satisfied parts of the document, as identified
in the Schedule, are conditionally exempt under section 47E(d) of the FOI Act.
I have not taken into account any of the irrelevant factors set out in section 11B(4) of the FOI
Act in forming this view.
Conclusion
In summary, I have decided parts of the documents, as set out in the Schedule, are
conditionally exempt under sections 47D, 47E(d) and 47F(1) of the FOI Act. Furthermore, I
have decided on balance it would be contrary to the public interest to release this information.
Accordingly, I have decided not to release the documents in full to you.
As identified in the Schedule, I have redacted the exempt information in the documents and
released the remaining material in accordance with section 22(1) of the FOI Act.
PAGE 9 OF 11
If not delivered return to PO Box 7820 Canberra BC ACT 2610
Attachment B
INFORMATION ON RIGHTS OF REVIEW
FREEDOM OF INFORMATION ACT 1982
Requesting a ful explanation of a Freedom of Information (FOI) decision
Before you ask for a formal review of a FOI decision, you can contact us to discuss your
request. We wil explain the decision to you. This al ows you to correct any misunderstandings.
Requesting a formal review of a FOI decision
If you consider the decision is incorrect, you have the right to apply for a review under sections
54 and 54L of the
Freedom of Information Act 1982 (the FOI Act).
You can apply for:
1. an
internal review by an Internal Review Officer of Services Australia (the Agency),
and/or
2. an
external review by the Australian Information Commissioner.
Applying for an internal review by an Internal Review Officer
In an internal review, a different decision maker to the Agency delegate who made the original
decision wil carry out the review. The Internal Review Of icer wil make a fresh decision on
your request and wil consider all aspects of the original decision and identify any relevant
additional factors.
An application for an internal review must be:
• made in writing
• made within 30 days of receiving this letter
• sent to the address at the top of the first page of this letter, or by email to
xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx
Note: You do not need to fil in a form. However, it is a good idea to set out any relevant
submissions you would like the Internal Review Officer to further consider, and your reasons
for disagreeing with the decision.
Applying for external review by the Australian Information Commissioner
If you disagree with the original or internal review decision, or if you have not received a
decision within 30 days of applying for an internal review, you wil have 60 days to apply in
writing for a review by the Australian Information Commissioner.
Note: The Australian Information Commissioner generally prefers FOI applicants to seek an
internal review before applying for an external review.
PAGE 10 OF 11
You can lodge your application:
Online:
www.oaic.gov.au
Post:
Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Email:
xxxxx@xxxx.xxx.xx
Important:
• If you are applying online, the application form the FOI Review Form is available at
Information Commissioner Review Application form
• If you have one, you should include with your application a copy of the Agency's original
and internal review decisions on your FOI request
• Include your contact details
• Set out your reasons for objecting to the Agency's decision.
Complaints to the Australian Information Commissioner and Commonwealth
Ombudsman
Australian Information Commissioner
You may complain to the Australian Information Commissioner concerning action taken by an
agency in the exercise of powers or the performance of functions under the FOI Act. There is
no fee for making a complaint. A complaint to the Australian Information Commissioner must
be made in writing. The Australian Information Commissioner's contact details are:
Telephone: 1300 363 992
Website:
www.oaic.gov.au
Smart Form:
FOI Complaint Form
Commonwealth Ombudsman
You may also complain to the Commonwealth Ombudsman concerning action taken by an
agency in the exercise of powers or the performance of functions under the FOI Act. There is
no fee for making a complaint. A complaint to the Commonwealth Ombudsman may be made
in person, by telephone or in writing. The Commonwealth Ombudsman's contact details are:
Phone:
1300 362 072
Website:
www.ombudsman.gov.au
The Commonwealth Ombudsman generally prefers applicants to seek review before
complaining about a decision.
PAGE 11 OF 11
