FOI 030/25/26
HighFlyer
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear HighFlyer,
NOTIFICATION OF A REQUEST CONSULTATION PROCESS – FOI 030/25/26
I refer to your request for access to the following documents, in the possession of the Department of
Defence (Defence) under the
Freedom of Information Act 1982 (Cth) (FOI Act).
I am an officer authorised under section 23(1) of the FOI Act to make decisions in relation to FOI
requests.
I am writing to tell you that I believe that the work involved in processing your request in its current
form would substantially and unreasonably divert the resources of this agency from its other
operations, due to its size, and because your request does not satisfy the requirement in paragraph
15(2)(b) of the FOI Act (identification of documents). This is called a ‘practical refusal reason’
(section 24AA).
On this basis, I intend to refuse your request. However, before I make a final decision to do this, you
have an opportunity to revise your request. This is called a ‘request consultation process’ as set out
under section 24AB of the FOI Act. You have
14 days to respond to this notice in one of the ways set
out below.
Reason for Intending to Refuse Your Request
In your request, you sought documents relating to:
…all executive employees who held a membership to the Qantas Chairmans Lounge or the
Virgins Beyond Lounge, at any time during the period 1 July 2024 - 30 June 2025.
Please provide, for this same period:
1. Any documents that detail official work completed during any attendance at one of the above-
mentioned airline lounges. This could include for example meeting invites, meeting notes,
agenda items, etc
2. All documents showing flight details where the departure or arrival airport has either of the
above-mentioned lounges.
3. All documents detailing any meal allowances paid to the executive employee in respect of
travel undertaken on the above flights.
For the purpose of providing this notice, I have considered whether your request satisfies the
requirements of section 15(2)(b) of the FOI Act. This requires that an applicant provide sufficient
information concerning the document(s) to which you seek access, as is reasonably necessary to
enable a responsible officer of the agency to find it. As detailed below, I do not consider that you have
met the requirements of section 15(2)(b) of the FOI Act.
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I consider that processing your request, as it currently stands, would be unreasonable for the following
reasons:
• Your request does not provide sufficient details to commence searches. For example, you have
not specified the person, or persons of interest, to whom you consider your request relates.
o Research – including in the form of document searches for material not in and of itself
responsive to your request – would be required to be undertaken by the officer(s)
supporting the processing of your request to identify and determine the group of
people to whom your request relates.
• Your request also does not provide sufficient information regarding the type, or types of
documents that would satisfy parts 1-3 of your request, and these sub-point are not narrowed by
topic or document type, and do not specify the individual(s) of interest.
• Parts 1-3 of your request also do not provide sufficient information concerning the document(s) as
is reasonably necessary to enable searches to be undertaken. As with the first sentence of your
request, further research, including in the form of extensive document searches not in and of itself
responsive to your request, would be required to be undertaken by a responsible officer, to then
identify the relevant search terms. For example, research would be required to identify, at a
minimum:
o who the request may relate to,
o whether any of those individuals held the relevant memberships during that time
period,
o whether those individuals have taken any flights,
o the dates and times and arrival/departure locations of those flights,
o the facilities available at those airports, and
o the various systems that could need to be searched to identify documents for part 1 of
your request (which at a minimum could be expected to include the Department’s
extensive document management system, individual and group email inboxes and
calendars, and then other programs specific to the work of the individual.
I therefore consider that the work involved in identifying the individuals and then processing request
in its current form would substantially and unreasonably divert the resources of the agency from its
other operations.
Section 24(1) of the FOI Act provides that an agency may refuse to give access to documents in
accordance with an FOI request if:
• a practical refusal reason exists in relation to the request; and
• following a request consultation process under section 24AB of the FOI Act, the agency is
satisfied that the practical refusal reason still exists.
Section 24AA(1)(a)(i) of the FOI Act provides that a practical refusal reason exists in relation to an
FOI request if the request does not satisfy the requirement in part 15(2)(b) of the FOI Act, or if work
involved in processing the request would substantially and unreasonably divert the resources of the
department from its other operations.
I have determined that your request does not provide sufficient information to support its processing.
I also find that processing the request in its current form would substantially and unreasonably divert
the resources of the agency for the reasons outlined above.
Request Consultation Process
You now have an opportunity to revise your request to enable Defence to process it.
Revising your request can mean narrowing the scope of the request to make it more manageable.
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Where the Department has assessed that your original request does not satisfy the requirement in
paragraph 15(2)(b) of the FOI Act, you will also be required to provide further information as is
reasonably necessary to enable an officer of the agency to identify the document, or documents to
which you seek access.
For example, you may wish to consider revising the scope of your request to support identification of
the individual, or group of individuals who declared a relevant membership during a particular time
period.
An example revised scope could be:
I seek access to the names of all employees who declared a membership to
(a) the Qantas Chairmans Lounge or
(b) the Virgins Beyond Lounge,
during the period 1 July 2024 - 30 June 2025.
Before the end of the consultation period, you must do one of the following, in writing:
• Withdraw your request
• Make a revised request
• Tell us that you do not wish to revise your request.
The consultation period starts on the day after you receive this notice and ends on
25 July 2025. During this period, you are welcome to seek assistance from the contact email I have listed below to
revise your request. If you revise your request in a way that adequately addresses the practical refusal
reason outlined above, we will recommence processing it. (Please note that the time taken to consult
you regarding the scope of your request is not taken into account for the purposes of the 30 day time
limit for processing your request.)
If you do not do one of the three things listed above during the consultation period or you do not
consult the contact person during this period, your request will be taken to have been withdrawn.
Contact Officer
If you would to revise your request or have any questions, please contact Defence FOI at
xxx.xxxxxxxxxxxxxx@xxxxxxx.xxx.xx.
Yours sincerely,
Chris Owens
Assistant Secretary Media and Information Disclosure
Governance Group
Department of Defence
10 July 2025
