If not delivered return to PO Box 7820 Canberra BC ACT 2610
28 May 2025
Our reference: LEX 84719
Lei Ying
Only by email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Lei Ying
Decision on your Freedom of Information Request
I refer to your request, dated and received by Services Australia (the Agency) on 16 April 2025,
for access under the
Freedom of Information Act 1982 (the FOI Act) to the following
documents:
061-01110050 Restricted portability assessment procedure for Centrelink
International Services staff
My decision
The Agency holds 1 document (totalling 23 pages) that relate to your request.
I have decided to grant you
part access to the document with some of the content removed.
I have decided that parts of the document you have requested are exempt under the FOI Act
as the document includes information that, if disclosed, could have a substantial adverse
effect on the proper and efficient conduct of the operations of an agency (section 47E(d)
conditional exemption).
Please see the schedule at
Attachment A to this letter for a description of the document and
the reasons for my decision, including the relevant sections of the FOI Act.
How we wil send your document to you
The document is 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 Office of the Australian Information Commissioner. You do not have to pay for
a review of the decision. 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.
PAGE 1 OF 7
Yours sincerely
Sally
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Reviews Branch | Legal Services Division
Services Australia
PAGE 2 OF 7
If not delivered return to PO Box 7820 Canberra BC ACT 2610
REASONS FOR DECISION
What you requested
1. 061-01110050 Restricted portability assessment procedure for Centrelink
International Services staff
2. 008-03120040 Assessment for Disability Support Pension (DSP) customers going
overseas under the no future work capacity provisions
On 23 April 2025, we wrote to you about your original request. You revised your request,
agreeing to the release of operational blueprint 008-03120040 via the Agency’s disclosure
log and this was confirmed by email on 24 April 2025.
Your revised request was:
061-01110050 Restricted portability assessment procedure for Centrelink
International Services staff
We wrote to you on 6 May 2025 to advise we needed additional time to process your request
and asked for a 14-day extension of time. You provided your agreement by return email on
the same day, making the new due date 30 May 2025. The Office of the Australian
Information Commissioner was advised of the extension.
What I took into account
In reaching my decision I took into account:
• your original request dated 16 April 2025
• your revised request on 24 April 2025
• other discussions and correspondence with you
• the document which falls 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 document
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 that parts of the document you requested are exempt under the FOI Act. My
findings of fact and reasons for deciding the exemption applies to the document are
discussed below.
PAGE 4 OF 7
Section 47E of the FOI Act - Operations of the Agency
I have applied the conditional exemption in section 47E(d) to parts of the document.
Section 47E of the FOI Act allows the Agency to exempt material from a document if its
disclosure would have a substantial adverse effect on the Agency’s ability to conduct its
operations efficiently and properly.
The document contains a guide for Agency staff for assessing individual customer
circumstances and portability requirements for Centrelink payments. I am satisfied this
information is relevant to the implementation, delivery and management of a process
administered by the Agency and therefore is relevant to the conduct of the Agency’s
operations.
I consider that providing this material to you, which is not publicly available, would negatively
affect the conduct of the Agency’s operations because it may allow customers to circumvent
elements of the Agency’s processes for financial advantage.
The document also contains information about Agency computer systems and data. I am
satisfied there is a possibility of real harm resulting from release as the document contains
information about the Agency’s cyber operations and environment. Disclosure of this
information creates the real risk of third-party actors gaining insight into Agency systems and
architecture and exploiting this knowledge for malicious purposes.
While I have no reason to believe you would misuse these details in any way, the FOI Act does
not control or restrict the use or dissemination of information once released in response to an
FOI request, so I must consider actions any member of the public might take if the information
entered the public domain.
For the reasons detailed above, I am satisfied parts of the document are conditionally exempt
under section 47E(d) 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 matter of public importance.
However, I also consider disclosure of the detailed staff guidance material could be used as
a how to guide by malicious users to navigate Agency systems and therefore presents a
cyber security risk. Disclosure of the exempt material would increase the likelihood that
individuals could circumvent or manipulate steps in securing a favourable outcome for
receiving payments. This in turn would significantly prejudice the Agency’s ability to promptly
and effectively deliver services to the Australian public.
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.
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.
PAGE 5 OF 7
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 allows 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 Of icer of Services Australia (the agency),
and/or
2. an
external review by the Australian Information Commissioner.
Note: There are no fees for these reviews.
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 will carry out the review. The Internal Review Officer will 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 will 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 6 OF 7
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 7 OF 7
