Phillip Tweedie
University Secretary
Director, University
Governance Office
xxx@xxx.xxx.xx
02 February 2026
Adam H
Via Email:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
SUBJECT FOI 202500243– Decision Notice
Dear Adam H,
On 2 October 2025, the Australian National University received your request seeking
access to documents under the
Freedom of Information Act 1982 (the Act)
.
Scope of the Request
The University has taken your request to be as follows:
“… I seek access to any and all documents held by the Australian National
University that relate to:
•
Conflict of Interest declarations, disclosures, or forms submitted by Provost and
Senior Vice-President, Professor Rebekah Brown to the University, formally or
informally.
•
This request includes any documents that relate to actual, potential, or perceived
conflicts of interest.”
The purpose of this letter is to provide you with a decision on your request for access
under the Act.
The Australian National University
Canberra 2600, ACT Australia
TEQSA Provider ID: PRV12002 (Australian University)
CRICOS Provider Code: 00120C
1. Authority to Make Decision
I am an officer authorised under section 23(1) of the FOI Act to make decisions in
relation to FOI requests.
2. Relevant Material
In reaching my decision I referred to the following:
• The terms of your request.
• Documents relevant to the request.
• Advice from University staff with responsibility for matters relating to the
documents to which you sought access.
• The Act.
• Guidelines published by the Office of the Australian Information Commissioner
(OAIC) under section 93A of the Act
(the FOI Guidelines).
3. Decision
The University has identified two (2) document relevant to your request, which is
outlined in the attached Document Schedule.
I have decided Document 1 and Document 2 are partially released with redactions in
accordance with the following sections of the FOI Act:
• Section 22, as certain material is considered irrelevant to the scope of your
request.
• Section 47F, as disclosure of the information would involve the unreasonable
disclosure of personal information about an individual.
4. Reasons for Decision
Section 22 – Deletion of Irrelevant Matter
Section 22 of the FOI Act provides that where an agency decides to grant access to a
copy of a document from which exempt or irrelevant matter has been deleted, and it is
reasonably practicable to prepare such a copy, the agency must do so. The FOI
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Guidelines clarify that 'irrelevant matter' constitutes any information that does not fall
within the specific description of the request. In this instance, your request is
specifically narrowed to "Conflict of Interest declarations, disclosures, or forms."
Consequently, I have determined that certain personal and professional data points
contained within the identified documents do not fall within this scope.
Specifically, I have redacted Professor Rebekah Brown’s personal contact details,
including her residential address, personal mobile number, and personal email address,
as these are purely private and do not constitute a declaration of interest. Furthermore,
I have redacted information regarding specific educational qualifications and post-
nominals. While these are valid professional attributes, they do not meet the
description of a conflict of interest disclosure and are therefore irrelevant to your
inquiry. By removing this irrelevant material, the University provides a copy of the
documents focused solely on the substantive information requested.
Section 47F – Personal Privacy
Section 47F of the FOI Act provides that a document is conditionally exempt if its
disclosure would involve the unreasonable disclosure of personal information about
any person, including a deceased person. In applying this exemption to the Document 1
and Document 2, I have specifically targeted the responses provided to Questions 1-9
and 11-12. These sections solicit information that is intrinsically personal, such as
details regarding criminal history, personal financial solvency, and private legal
proceedings. Under the FOI Guidelines, "personal information" is broadly defined as
information or an opinion about an identified individual, and I am satisfied that the
specific declarations made by Professor Rebekah Brown - even where those
declarations consist of "No" responses - constitute personal information as they reveal
details of her private background and legal standing.
In determining whether the disclosure of this information would be "unreasonable"
under section 47F(2), I have balanced the public's right to access government-held
information against the individual’s right to privacy. I have found that the information in
question is not well known to the public, is not available from any publicly accessible
registers, and was provided to the University under a high expectation of
confidentiality for the sole purpose of internal due diligence. Professor Rebekah
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Brown, like any individual, maintains a significant expectation of privacy concerning
sensitive administrative records that do not impact her professional duties. Because
the responses to these suitability questions were "No," their disclosure would provide
no substantive insight into the University's management of actual or perceived
conflicts, yet would represent an intrusive and significant invasion of her private
history. Furthermore, I have considered the risk to identity security; the release of
handwritten signatures and specific personal identifiers could facilitate identity fraud
or expose the individual to unnecessary harassment, which is a factor that weighs
heavily against disclosure as an unreasonable intrusion.
The Public Interest Test (Section 11A)
As Section 47F is a conditional exemption, I must also apply the public interest test set
out in section 11A(5) of the FOI Act, which requires that access be granted unless
disclosure would, on balance, be contrary to the public interest. This requires a
balancing of factors for and against disclosure to determine where the greater public
interest lies.
Factors favouring disclosure
I recognise the public interest in the transparency of the University’s governance and
the accountability of its senior executives. There is a legitimate interest in the
community being able to confirm that high-ranking officials at a public institution like
the ANU are subject to rigorous integrity checks and that potential conflicts of interest
are managed appropriately.
Factors against disclosure
These factors are weighed against the substantial public interest in protecting
personal privacy and meeting the University’s legal obligations under the
Privacy Act
1988. There is a compelling public interest in ensuring that the University's integrity
and conflict-management frameworks remain effective; routine disclosure of sensitive
personal checks would likely have a "chilling effect" on the frankness and candour of
future declarants. If staff believe their private administrative declarations will be
published, they may be less willing to provide the full and honest responses required
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for the University to effectively manage risk. Furthermore, disclosing that a high-
profile individual was queried on their criminal or financial history - even when the
result is negative - could lead to unfair public speculation and harassment, which is not
in the public interest.
Conclusion on the Public Interest
I have concluded that the public interest in transparency is met by the release of the
substantive information within the documents that confirms Professor Rebekah Brown
has complied with her disclosure obligations. Releasing the remaining personal
suitability declarations would add no further value to public debate but would cause
significant harm to the individual's privacy and the University's ability to conduct future
integrity checks. Therefore, I find that the public interest factors against disclosure
outweigh those in favour, and access to the redacted material is refused under section
47F of the FOI Act.
The Australian National University
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Contact officer
If you would like to discuss revising your request or have any questions, please contact
our office via email in the first instance vi
a xxx@xxx.xxx.xx quoting FOI 202500243 as
your reference number in the subject line.
Your review rights are outlined on the following page.
Yours sincerely
Phillip Tweedie
University Secretary
Director, University Governance Office
Australian National University
Encl.
1. Schedule of Documents – Ref. 202500243
2. Document Package – Ref. 202500243
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Your review rights
If you are dissatisfied with my decision, you may apply for internal review or
Information Commissioner review of the decision. We encourage you to seek internal
review as a first step as it may provide a more rapid resolution of your concerns
Application for Internal Review of Decision
Section 54A of the Act, gives you the right to apply for an internal review of my
decision.
It must be made in writing within 30 days of receipt of this letter, no particular form is
required but it is desirable to set out in the application the grounds on which you
consider the decision should be reviewed.
The application should be addressed to Freedom of Information a
t xxx@xxx.xxx.xx.
Application for Information Commissioner Review of decision
Under section 54L of the FOI Act, you may apply to the Australian Information
Commissioner to review my decision. An application must be made in writing within 60
days of the date of this letter, and be lodged in one of the following ways:
Form: either online form or downloadable form available at
https://www.oaic.gov.au/freedom-of-information/your-freedom-of-information-
rights/freedom-of-information-reviews/information-commissioner-review
email:
xxxxx@xxxx.xxx.xx
Post: Director of FOI Dispute Resolution, GPO Box 5288, Sydney NSW 2001
More information is available on the Office of the Australian Information Commissioner
website
. https://www.oaic.gov.au/freedom-of-information/your-freedom-of-
information-rights/freedom-of-information-reviews
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