fa 250901634 Practical Refusal Notice 29.10.2025.pdf

OFFICIAL: Sensitive//Personal-Privacy

A practical refusal reason exists under section 24AA of the FOI Act if either (or both) of the
following applies:
(1)(a)(i) the work involved in the processing of the request would substantially and
unreasonably divert the resources of the Department from its other operations.
(1)(b)   the request does not satisfy the requirement in section 15(2)(b) of the FOI Act,
which requires you to provide such information concerning the document you are seeking
access to, to enable the Department to be able to identify it.
It was considered that the request did not satisfy the requirements of section 15(2)(b) of the FOI
Act, and accordingly that a practical refusal reasons exist under section 24AA(1)(b) of the FOI
Act.
You were provided with a 14 day ‘consultation period’ to revise the scope of your request to
remove the practical refusal reason.
On 15 October 2025, you provided the following revised scope:

I seek access to:
1. Al  feedback submissions received by the Department of Home Affairs’ Global
Feedback Unit (GFU) that were referred to the Responsible Business Area (RBA) for the
Australian Embassy in Bangkok covering the period 1 July 2025 to the date of this
request.

2. Al  relevant correspondence or communications between the GFU and the RBA in
relation to these feedback submissions, for the same period.

For clarity, this request is for:

• GFU complaints/feedback referred to the specific post (Bangkok), and

• Correspondence generated in response to, or relating to, those referrals.

I consent to the redaction of personal or identifying information of Departmental staff
below the Senior Executive Service (SES) level. However, I request that position
numbers of all staff continue to be included.

I trust this substantially reduces the number of documents falling within scope, and I am
hopeful the Department wil  now be able to process the request without substantial or
unreasonable diversion of resources.
After considering your revised scope, I consider that the work involved in the processing of the
request would substantially and unreasonably divert the resources of the Department from its
other operations, and accordingly that practical refusal reasons exist under section 24AA(1)(a)(i)
of the FOI Act.
Intention to refuse request
I am writing to advise you that I intend to refuse your request on the basis that a practical refusal
reason exists. However, before I make a final decision to do this, you have an opportunity to
revise your request to remove the practical refusal reason. This is called a ‘request consultation
process’. You have 14 days to respond to this notice in one of the ways set out below.

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OFFICIAL: Sensitive//Personal-Privacy

OFFICIAL: Sensitive//Personal-Privacy

Power to refuse request
Section 24 of the FOI Act provides that if the Department is satisfied that a practical refusal
reason exists in relation to a request, the Department must undertake a consultation process
with you, and if, after that consultation process, the Department remains satisfied that the
practical refusal reason stil  exists, the Department may refuse to give you access to the
documents subject to the request.
Practical refusal
A practical refusal reason exists under section 24AA of the FOI Act if either (or both) of the
following applies:
(1)(a)(i) the work involved in the processing of the request would substantially and
unreasonably divert the resources of the Department from its other operations
(1)(b)   the request does not satisfy the requirement in section 15(2)(b) of the FOI Act,
which requires you to provide such information concerning the document you are
seeking access to, to enable the Department to be able to identify it.
I consider that the work involved in the processing of the request would substantially and
unreasonably divert the resources of the Department from its other operations, and accordingly
that practical refusal reasons exist under section 24AA(1)(a)(i) of the FOI Act.
Reasons for practical refusal
The Department has made a preliminary assessment of the documents that would be captured
by your request and has identified a total of 191 documents potentially captured by your request.
Due to the volume of documents within scope, the Department has completed a sample
assessment of their page numbers to determine the estimated resources required in order to
process your request. A sample of 19  documents, revealed approximately 47  pages, which
averages 2.47 pages per document. Given this calculation there could be an estimated 472.47
pages within scope of your request.
If the Department were to commence assessments, the FOI section would need to review the
documents in collaboration with relevant business areas, make appropriate redactions, convert
documents to pdf, create a schedule of documents and make a decision on your request. The
Department has also spent approximately 3  hours searching and retrieving the relevant
documents. I consider that the decision maker wil  require at least 5 minutes to assess each
page captured by your request. On that basis, I estimate that the decision maker would require
approximately 42.33 hours to complete making a decision on access to the documents captured
by your request.
This would include deciding whether to grant, refuse or defer access to the 191 documents to
which your request relates, or to grant access to edited copies of such documents in the files,
and includes the resources that would have to be used to examine the documents, make copies,
or edited copies, of the documents, and to notify you of a decision on access in your request. I
am satisfied that the Department would be required to divert significant resources from its current
operations in order to identify, locate and collate the documents held within the Department, and
to make a decision on access to those documents. This diversion would result in a significant
drain on the resources of the area within the Department that would be required to process this
request.

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OFFICIAL: Sensitive//Personal-Privacy

OFFICIAL: Sensitive//Personal-Privacy

I am satisfied that the Department would be required to divert significant resources from its
current operations in order to identify, locate and collate the documents held within the
Department, and to make a decision on access to those documents. This diversion would result
in a significant drain on the resources of the area within the Department that would be required
to process this request.
I consider that this would result in this request imposing both a substantial and an unreasonable
diversion of resources of the Department from its other operations and that a practical refusal
reason exists in relation to this request.
You now have an opportunity to revise your request to enable it to proceed. You may wish to
revise the wording of your FOI request by considering using more specific wording or requesting
documents relating to specific ‘promotional opportunities’, such as:
•  reduce the date range of the request further,
•  remove the second part of the request relating  to  ‘all relevant correspondence or
communications between the GFU and the RBA in relation to these feedback
submissions’
Under section 24AB(6) of the FOI Act, you have 14 days to do one of the following:
•  withdraw your request;
•  make a revised request;
•  indicate that you do not wish to revise your request.
If you do not do one of the three things listed above during the consultation period (14 days), or
you do not consult the contact person listed below during this period, your request wil  be taken
to have been withdrawn in accordance with section 24AB(7) of the FOI Act.
Contact
Should you wish to revise your request or have any questions in relation to this process, please
do not hesitate to contact Mary at xxx@xxxxxxxxxxx.xxx.xx.

Yours Sincerely

{Electronically signed}

Mary
FOI Case Of icer 60186969 | Legal Group
Privacy, FOI & Records Management Branch
Freedom of Information | Legal Group
Department of Home Af airs
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OFFICIAL: Sensitive//Personal-Privacy