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PIA 57785 Copilot - MS Teams and transcription use cases

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Dear Services Australia,

I am writing to request access to a document under the Freedom of Information Act 1982 (Cth).

The document I seek is the Privacy Impact Assessment (PIA) titled:

"Copilot - MS Teams and transcription use cases"
Reference Number: 57785

I request that access be provided in electronic format.

Pursuant to section 29(5) of the FOI Act, I request a waiver of any applicable charges on the grounds that providing access to this document is in the general public interest.
Services Australia collects very sensitive personal, financial, and health information for a vast majority of Australians. The use of generative AI tools like Microsoft Copilot to process or transcribe internal communications raises significant questions about data security, privacy risks, and the potential for inadvertent disclosure of citizen information.

Disclosure of this PIA is essential for public understanding and scrutiny of the agency's risk assessment processes. It allows the public to see how Services Australia is identifying and mitigating the privacy risks associated with foreign AI technology and the public's very sensitive personal information, thereby promoting accountability.

Yours faithfully,

Steven Roddis

FREEDOMOFINFORMATION, Services Australia

Thank you for contacting the Freedom of Information (FOI) team of Services
Australia (the Agency).

This email acknowledges your correspondence and provides general FOI
information .
We are currently experiencing a higher than usual volume of requests,
which has resulted in some delays in our review and response process. We
are seeking your agreement to extend the processing time by an additional
30 days. If you agree to this additional time, we would appreciate it if
you could reply to this email with “I agree to a 30 day extension of time”
at your earliest opportunity.
Administrative release of documents  
The Agency uses administrative access arrangements ('the arrangements') to
release certain types of documents outside the FOI Act. We will advise you
if the documents you seek are suitable for release to you under the
arrangements. If you consent to receiving documents under the
arrangements, please reply to this email with “I agree to receive
documents via the arrangements where appropriate”.
Personal information of Agency staff
As part of the FOI process, we seek your consent to remove any information
that may identify junior staff. Please reply to this email with “I agree
to exclude staff details”. 
Once you consent to remove this information, it will be irrelevant under
Section 22 of the FOI Act.
How we will send documents to you
We will use this email address to send you documents. We will advise you
if we are unable to send documents to you via email due to their size.
How long do I have to wait?
Unless your request has been extended, we are required to notify you
within 30 days.  
Requesting a formal external review of a FOI deemed refusal decision
After the due date has past and you did not receive a decision, the
request becomes a ‘deemed refusal decision’. You may request the
Information Commissioner to review the ‘deemed refusal decision’. For
further information, see [1]Apply for an Information Commissioner review |
OAIC (or visit [2]www.oaic.gov.au).

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1. https://www.oaic.gov.au/freedom-of-infor...
2. http://www.oaic.gov.au/

Dear Services Australia,

Thank you for your email acknowledging my request under the Freedom of Information Act 1982 (FOI Act).

I am writing to decline your request for a 30-day extension to the statutory processing period.

The reason cited, 'a higher than usual volume of requests,' is a matter of the agency's internal resourcing. The FOI Act provides a statutory timeframe to ensure the public receives timely access to information, which is a cornerstone of government transparency and accountability. In my opinion, routinely seeking extensions due to workload pressures works against the spirit and objects of the Act and can incentivise the under-resourcing of essential functions like FOI processing.

The automated nature of your email also suggests that my specific request has not yet been reviewed. I therefore expect a decision to be provided within the original statutory timeframe.

Regarding the other points in your email:

Administrative Release: I agree to receive documents via administrative arrangements where appropriate, provided this does not prejudice my rights under the FOI Act.

Personal Information of Staff: I agree to the exclusion of names and identifying details of junior (non-SES) staff, except where the identity of a specific individual is directly relevant and material to the substance of my request.

Yours faithfully,

Steven Roddis

FREEDOMOFINFORMATION, Services Australia

1 Attachment

Dear Steven

 

I am writing in regards to your Freedom of Information request to Services
Australia (the Agency) as follows:

 

I am writing to request access to a document under the Freedom of
Information Act 1982 (Cth).

 

The document I seek is the Privacy Impact Assessment (PIA) titled:

 

"Copilot - MS Teams and transcription use cases"

Reference Number: 57785

 

I am currently reviewing the document you requested and consulting further
on any sensitivities that may attract an exemption under the FOI Act. As
such, I require additional time to finalise the decision and progress the
matter through the quality assurance process.

 

If a decision is not notified to you within time, your request will be
deemed to be refused by operation of the FOI Act. The Agency will still
continue to process your request as a Statement of Reasons, however you
will unfortunately lose your internal review rights. Our objective for
this extension of time request is to ensure the decision and documents
relevant to your request are released on time under the FOI Act, thus
maintaining your internal review rights.

 

On this basis, I respectfully request an extension of time of 20 days to
process your request. The effect of the extension would mean the new
decision due date would be 19 November 2025. If we are able to process
your request and provide you with a decision before this date, we will do
so.

 

If you agree to this extension of time, it would be greatly appreciated if
you could please respond to this email stating ‘I agree’ by close of
business 22 October 2025.

 

Please note as stated above, if we do not receive a reply from you by the
above date we will still continue to process your request as a Statement
of Reasons.

 

Thank you for your patience and understanding.

 

Kind regards

 

Tracy, FOI Officer

Authorised FOI Decision Maker

Freedom of Information Team

FOI and Reviews Branch | Legal Services Division

 

[1]Visual brand element showing Services Australia progress symbol to left
with Services Australia wording to the right of the symbol. Underneath is
servicesaustralia.gov.au and icons representing our social media accounts.
To follow us on social media go to servicesaustralia.gov.au/socialmedia
Aligning the bottom of the signature block is the Services Australia
indigenous artwork strip consisting of cultural elements depicting our
agency’s progress story for First Nations people.

 

Services Australia acknowledges the Traditional Custodians of the lands we
live on. We pay our respects to all Elders, past and present, of all
Aboriginal and Torres Strait Islander nations.

 

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Dear FREEDOMOFINFORMATION,

You could have requested this earlier, but instead did this right on the deadline.
I do not agree to the extension.

Yours sincerely,

Steven Roddis

FREEDOMOFINFORMATION, Services Australia

Thank you for contacting the Freedom of Information (FOI) team of Services
Australia (the Agency).

This email acknowledges your correspondence and provides general FOI
information .
We are currently experiencing a higher than usual volume of requests,
which has resulted in some delays in our review and response process. We
are seeking your agreement to extend the processing time by an additional
30 days. If you agree to this additional time, we would appreciate it if
you could reply to this email with “I agree to a 30 day extension of time”
at your earliest opportunity.
Administrative release of documents  
The Agency uses administrative access arrangements ('the arrangements') to
release certain types of documents outside the FOI Act. We will advise you
if the documents you seek are suitable for release to you under the
arrangements. If you consent to receiving documents under the
arrangements, please reply to this email with “I agree to receive
documents via the arrangements where appropriate”.
Personal information of Agency staff
As part of the FOI process, we seek your consent to remove any information
that may identify junior staff. Please reply to this email with “I agree
to exclude staff details”. 
Once you consent to remove this information, it will be irrelevant under
Section 22 of the FOI Act.
How we will send documents to you
We will use this email address to send you documents. We will advise you
if we are unable to send documents to you via email due to their size.
How long do I have to wait?
Unless your request has been extended, we are required to notify you
within 30 days.  
Requesting a formal external review of a FOI deemed refusal decision
After the due date has past and you did not receive a decision, the
request becomes a ‘deemed refusal decision’. You may request the
Information Commissioner to review the ‘deemed refusal decision’. For
further information, see [1]Apply for an Information Commissioner review |
OAIC (or visit [2]www.oaic.gov.au).

show quoted sections

References

Visible links
1. https://www.oaic.gov.au/freedom-of-infor...
2. http://www.oaic.gov.au/

Dear Services Australia,

Apologies I misread the deadline, I agree to the 20 day extension.

Yours faithfully,

Steven Roddis

FREEDOMOFINFORMATION, Services Australia

2 Attachments

Dear Steven

             

Please find attached the decision letter relating to your request for
access to documents held by Services Australia, under the Freedom of
Information Act 1982.

 

If you have any questions regarding this matter or are unable to open the
attachments, please contact me by replying to this email.

 

Kind regards

 

Tracy, (A/g Senior FOI Officer)

FOI and Reviews Branch
Legal Services Division

[1]Visual brand element showing Services Australia progress symbol to left
with Services Australia wording to the right of the symbol. Underneath is
servicesaustralia.gov.au and icons representing our social media accounts.
To follow us on social media go to servicesaustralia.gov.au/socialmedia
Aligning the bottom of the signature block is the Services Australia
indigenous artwork strip consisting of cultural elements depicting our
agency’s progress story for First Nations people.

 

Services Australia acknowledges the Traditional Custodians of the lands we
live on. We pay our respects to all Elders, past and present, of all
Aboriginal and Torres Strait Islander nations.

 

show quoted sections

References

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Dear Services Australia,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Services Australia's handling of my FOI request 'PIA 57785 Copilot - MS Teams and transcription use cases'.

Regarding Section 42:
The decision claims the document is exempt in full because it contains legal advice. However, the document is a Privacy Impact Assessment for Microsoft Copilot.
While legal advice regarding privacy compliance is privileged, the underlying factual descriptions of the technology, the data flows, the specific "use cases," and the administrative framework within which Copilot operates are not legal advice. These are operational facts.

If the document describes the functional operation of Microsoft Copilot (ie. what the software does, what data it ingests, and where that data goes), that information exists for an administrative and operational purpose, not solely for the dominant purpose of providing legal advice.

Regarding 47(1)(b)
Privacy Impact Assessments are standard compliance tools governed by the Privacy Act 1988 and guided extensively by the OAIC. The methodology for conducting a PIA is largely standardised across the Commonwealth.
It is difficult to accept that a law firm’s specific "approach" to a standard government compliance exercise is a trade secret of such value that it overrides the public’s right to know how their sensitive data is being processed. Even if specific proprietary methodology text exists, it does not permeate the entire 57-page document. The substantive content, ie. the analysis of Services Australia’s specific risk belongs to the Agency and the public, not the commercial vendor.

Regarding 47C
The subject of the PIA involves the application of Generative AI (Microsoft Copilot) to the sensitive personal, financial, and health data of millions of Australians. There is a profound public interest in transparency regarding:

Whether citizens' data is being retained by Microsoft or used for model training.
The accuracy and reliability risks identified by the Agency.
The safeguards in place to prevent hallucinations or data leakage.
Promoting public scrutiny of how the Agency manages these specific, novel technological risks significantly outweighs the generic interest in protecting a consultant’s "methodology."

Severance
The document totals 57 pages. The decision maker refused access in full.
It is highly improbable that every sentence of a 57-page document constitutes privileged legal advice or commercially sensitive methodology.
The Agency has a statutory obligation under section 22 of the FOI Act to consider whether an edited copy can be provided.

A full history of my FOI request and all correspondence is available on the Internet at this address: http://www.righttoknow.org.au/request/pi...

Yours faithfully,

Steven Roddis

FREEDOMOFINFORMATION, Services Australia

Thank you for contacting the Freedom of Information (FOI) team of Services
Australia (the Agency).

This email acknowledges your correspondence and provides general FOI
information .
We are currently experiencing a higher than usual volume of requests,
which has resulted in some delays in our review and response process. We
are seeking your agreement to extend the processing time by an additional
30 days. If you agree to this additional time, we would appreciate it if
you could reply to this email with “I agree to a 30 day extension of time”
at your earliest opportunity.
Administrative release of documents  
The Agency uses administrative access arrangements ('the arrangements') to
release certain types of documents outside the FOI Act. We will advise you
if the documents you seek are suitable for release to you under the
arrangements. If you consent to receiving documents under the
arrangements, please reply to this email with “I agree to receive
documents via the arrangements where appropriate”.
Personal information of Agency staff
As part of the FOI process, we seek your consent to remove any information
that may identify junior staff. Please reply to this email with “I agree
to exclude staff details”. 
Once you consent to remove this information, it will be irrelevant under
Section 22 of the FOI Act.
How we will send documents to you
We will use this email address to send you documents. We will advise you
if we are unable to send documents to you via email due to their size.
How long do I have to wait?
Unless your request has been extended, we are required to notify you
within 30 days.  
Requesting a formal external review of a FOI deemed refusal decision
After the due date has past and you did not receive a decision, the
request becomes a ‘deemed refusal decision’. You may request the
Information Commissioner to review the ‘deemed refusal decision’. For
further information, see [1]Apply for an Information Commissioner review |
OAIC (or visit [2]www.oaic.gov.au).

show quoted sections

References

Visible links
1. https://www.oaic.gov.au/freedom-of-infor...
2. http://www.oaic.gov.au/

FOI.LEGAL.TEAM, Services Australia

2 Attachments

Dear Mr Roddis,

 

Please find attached an acknowledgement letter dated 24 November 2025 in
relation to your request for internal review of the Freedom of Information
(FOI) decision made by an authorised decision maker of Services Australia
(the Agency) dated 19 November 2025.

 

If there are any issues with opening the attached document, please do not
hesitate to contact me by replying to this email.

 

Kind regards,

 

Sonya, Authorised FOI Decision Maker  

Freedom of Information and Reviews Branch

Legal Services Division

PO Box 7820 Canberra BC ACT 2610

 

[1]Visual brand element showing Services Australia progress symbol to left
with Services Australia wording to the right of the symbol. Underneath is
servicesaustralia.gov.au and icons representing our social media accounts.
To follow us on social media go to servicesaustralia.gov.au/socialmedia
Aligning the bottom of the signature block is the Services Australia
indigenous artwork strip consisting of cultural elements depicting our
agency’s progress story for First Nations people.

 

Services Australia acknowledges the Traditional Custodians of the lands we
live on. We pay our respects to all Elders, past and present, of all
Aboriginal and Torres Strait Islander nations.

 

This email and any attachments may contain information subject to legal
professional privilege or information that is otherwise sensitive or
confidential. If you are not the intended recipient of this email, you are
prohibited from using or disseminating this communication. If you have
received this communication in error please notify the sender immediately
and permanently delete this email.

 

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We don't know whether the most recent response to this request contains information or not – if you are Steven Roddis please sign in and let everyone know.