Mr Phillip Tweedie
University Secretary
Director, University Governance Office
xxx@xxx.xxx.xx
28 January 2026
Joyce Mayer
By email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
FOI 202500255 - Decision Notice
Dear Joyce Mayer
On 10 September 2025, the Australian National University received your request seeking access to
documents under the
Freedom of Information Act 1982 (the Act)
.
We sincerely apologise for the delay in responding.
1. Scope of Request
“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 head of Government
relations, Brooke Disney to the University, formally or informally, with specific relation to
CMAX Advisory, a lobbyist group employed by the Office of the Interim Vice-Chancellor to
provide support in government relations.
-This request includes any documents that relate to actual, potential, or perceived conflicts
of interest, including personal relationships or friendships.
- A copy of the conflict form(s) and emails which document a potential, perceived or real
conflict and the mitigations in place.”
The Australian National University
Canberra 2600, ACT Australia
TEQSA Provider ID: PRV12002 (Australian University)
CRICOS Provider Code: 00120C
2.
Authority to Make Decision
I am an officer authorised under section 23 of the Act to make decisions in respect of requests to
access documents or to amend or annotate records.
3. 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
• Advice from third parties on consultation
• The Act
• Guidelines published by the Office of the Australian Information Commissioner (OAIC)
under section 93A of the Act (the FOI Guidelines)
4. Decision
The University has located 1 (one) document considered to be within the scope of your request.
I have decided to release these documents in part, with exempt material redacted.
The exemptions claimed for each document are set out in the Schedule attached and my reasons
for the redactions are outlined below.
4.2
Section 47F of the Act – Personal Privacy
Section 47F of the Act provides that material is conditionally exempt if its disclosure under this Act
would involve the unreasonable disclosure of personal information about any person.
The information I have exempted under this section of the Act contains the personal information
relating to a person and their signature.
I have decided that the disclosure of this personal information would be an unreasonable
disclosure of personal information about that person, and that the disclosure of their signature
may expose the person to identity fraud.
The Australian National University
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CRICOS Provider #00120C
The Act states that, when deciding whether the disclosure of the personal information would be
‘unreasonable’, I must have regard to four factors set out in section 47F(2) of the Act. I have
therefore considered each of these factors below:
• The extent to which the information is well known
• Whether the person to whom the information relates is known to be (or to have been)
associated with the matters dealt with in the document
• The availability of the information from publicly available resources
• Any other matters that the agency or the Minister considers relevant
I am satisfied that the disclosure of the redacted information within the documents would involve
an unreasonable disclosure of personal information about those individuals whose identity is able
to be ascertained and is “personal information” within the meaning of the
Privacy Act 1988.
The information is the type of information that ordinary people would not wish to have disclosed,
particularly noting the release under FOI is release to the world.
This information is not available from publicly accessible sources.
I have decided that the information referred to above is conditionally exempt under section 47F of
the Act.
4.3
Section 47F and the Public Interest
Section 31B of the Act provides that material is exempt if it is conditionally exempt under
Division 3, and access to the material would also, on balance, be contrary to the public interest for
the purposes of s.11A(5) of the Act.
In applying this test, I have weighed the factors in favour of disclosure against those against it.
I do not consider that access to the information exempted would promote the objects of the Act,
as described in section 3.
I have identified the following factors against disclosure:
• The disclosure of personal information which is conditionally exempt under section 47F(1)
of the FOI Act could reasonably be expected to prejudice the protection of those
The Australian National University
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CRICOS Provider #00120C
individuals' right to privacy. The personal information which is conditionally exempt under
section 47F(1) is the type of information a person would wish to keep private and is not
well known to the public generally.
• This information is not available from publicly accessible sources. I have had regard to the
fact that disclosure of information under the FOI Act must be considered to be a disclosure
to the world at large and not just to you as the applicant.
• The University is committed to complying with its obligations under the
Privacy Act 1988,
which sets out standards and obligations that regulate how the University must handle and
manage personal information. It is firmly in the public interest that the University uphold
the rights of individuals to their own privacy and meets its obligations under the
Privacy
Act 1988. I consider that this factor weighs heavily against disclosure of the personal
information contained within the document.
Balancing all the above relevant public interest considerations, I have concluded that the disclosure
of the conditionally exempt information in the documents is not in the public interest and
therefore the material is exempt from disclosure under the FOI Act.
Irrelevant matters
I have also had regard to section 11B(4) of the Act which sets out the factors which are irrelevant
to my decision, which are:
• Access to the documents could result in embarrassment to the Commonwealth
Government or cause a loss of confidence in the Commonwealth Government.
• Access to the documents could result in any person misinterpreting or misunderstanding
the documents.
• The authors of the documents were (or are) of high seniority in the agency to which the
request for access to the documents was made.
• Access to the documents could result in confusion or unnecessary debate.
I have not taken into account any of those factors in this decision.
A copy of the document as redacted is enclosed with this letter.
Your review rights are outlined on the following page.
The Australian National University
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CRICOS Provider #00120C
Yours sincerely
Mr Phillip Tweedie
University Secretary
Director, University Governance Office
Australian National University
The Australian National University
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CRICOS Provider #00120C
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 at
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
The Australian National University
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CRICOS Provider #00120C
