FOI 187/25/26
James Smith
Email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear James,
NOTIFICATION OF A REQUEST CONSULTATION PROCESS – FOI 187/25/26
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 substantial y and unreasonably divert the resources of this agency from its other
operations due to its size and broad scope. 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:
…any media statement, communications pack, emails and other documents and
correspondence produced by Defence or its recruitment or communications or public relations
subcontractors (or any combination of the above) in respect of the various stories published by
various media outlets on 3 and 4 August such as the below:
The Guardian
Australian defence force fails to meet recruitment targets but numbers improving
https://www.theguardian.com/australia-news/2025/aug/04/australian-defence-force-fails-to-
meet-recruitment-targets-but-numbers-improving
ABC News
TikTok and online games driving surge in Defence Force recruitment - ABC News
https://www.abc.net.au/news/2025-08-03/social-media-gaming-advertising-help-bolstering-
defence-recruits/105602334
The Sydney Morning Herald
Ads on TikTok and video games drive 15-year surge in defence force enrolment
https://www.smh.com.au/politics/federal/ads-on-tiktok-and-video-games-drive-15-year-surge-
in-defence-force-enrolment-20250803-p5mjvz.html
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AFR
Cheap homes, bonuses and TikTok: how Defence is turning around its recruitment crisis
https://www.afr.com/politics/federal/cheap-homes-bonuses-and-tiktok-how-defence-is-
turning-around-its-recruitment-crisis-20250803-p5mjxv
Yahoo
Defence force recruitment has biggest surge in a decade
https://au.news.yahoo.com/defence-force-recruitment-biggest-surge-
173000368.html?guccounter=1
The Canberra Times
ADF enlistments at 15-year high after social media campaign
https://www.canberratimes.com.au/story/9030900/adf-enlistments-at-15-year-high-after-
social-media-campaign/
The Australian
Cash bonuses, lower standards help boost ADF numbers
https://www.theaustralian.com.au/nation/defence/cash-bonuses-lower-standards-help-boost-
adf-numbers/news-story/8950c7b62ce3a3cc3f5a17fa2dcc6818
The Courier Mail
How gaming and TikTok helped ADF smash recruitment targets
www.couriermail.com.au%2Fnews%2Fqueensland%2Fqld-politics%2Fhow-gaming-and-tiktok-
helped-adf-smash-recruitment-targets%2Fnews-
story%2F880ebdffd8c2bfe0c2fbda2dc130a468.
For the purpose of providing this notice, I have considered whether processing your request would
be unreasonable. I consider that processing your request, as it currently stands, would be
unreasonable because the work involved in processing your 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
• fol owing 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 work involved in processing the request would substantial y and unreasonably divert
the resources of the department from its other operations.
I find that a significant amount of resources would have to be diverted to arrange for the required
searches to be undertaken, to then review any documents that were identified as being possibly
relevant to your request, and final y, to undertake the decision making process on any documents
that did meet the parameters of your request. This assessment is based on the following:
• The request seeks access to ‘any’ documents relating to eight separate media stories. As
presently framed, the breadth of this wording is such that it is likely to capture a substantial
volume and diverse range of documents held across multiple areas of the agency. The use of
the term ‘any’ is particularly broad, as it does not confine the scope to specific types of
documents, timeframes, or custodians. When combined with the eight separate subject
matters identified, the request is of a scale and complexity that would require extensive
searches and significant coordination across Defence.
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• In assessing the impacts of further processing your request, the time required to examine
these documents becomes a significant and compelling factor, given the context above.
• Relevant records would very likely need to be assessed for consideration of personal privacy
and related matters for each individual document, and for considerations around FOI Act
exemptions.
• Based on the current scope of your FOI request, we anticipate the requirement for
consultation with multiple third parties prior to the release of any material.
I am satisfied that processing your request in its current form would substantial y and unreasonably
divert the resources of the agency from its other operations and therefore constitutes a practical
refusal reason.
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 or
explaining in more detail the documents you wish to access. For example, by providing more specific
information about exactly what documents you are interested in, Defence will be able to pinpoint
the documents more quickly and avoid using excessive resources to process documents you are not
interested in.
Before the end of the consultation period, you must do one of the fol owing, 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
16 September
2025.
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.)
In your consideration of submitting a revised request, you may like to consider clarifying the type of
documents you are seeking access to, and/or revising your request to seek the following:
Please provide any media statement/release or communications pack produced by Defence or
its subcontractors related to the listed stories published by various media outlets on 3 and 4
August.
In its present form, the FOI application is overly broad, and unlikely to be processed further.
If you do not do one of the three things listed above during the consultation period your request wil
be taken to have been withdrawn.
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Contact Officer
If you would like to revise your request or have any questions, please contact the Case Manager by
emailing xxx.xxxxxxxxxxxxxx@xxxxxxx.xxx.xx.
Yours sincerely,
Executive Level 1 officer Freedom of Information Directorate
Governance Group
Department of Defence
Russell Offices
R1-05-A PO Box 7910
Canberra BC ACT 2610
1 September 2025
