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In reply, please quote:
13 February 2026
FOI30/183
Zack
By email: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx Dear Zack,
Re: Freedom of Information– Internal Review Decision
Background:
1. By email dated 30 October 2025 to the Bureau of Meteorology you requested access
under the
Freedom of Information Act 1982 (Cth) ('FOI Act'). You wrote:
I request the invoices/receipts relating to payments to any of the following: DigiCert;
CyberTrust; GeoTrust; QuoVadis; RapidSSL; Thawte; Mocana; Setigo; Comodo (Comodo
CA); Xcitium
Timeframe 10 April 2024 to 10 May 2025
2. By email dated 9 December 2025 a decision notice in relation to your request was
provided to you via the above email address. That decision was an access refusal
decision in accordance with section 24A(1) of the FOI Act ('Original Decision').
3. Timeframe: By email dated 12 December 2025 you requested internal review. That
decision was due by 12 January 2026 (taking into account the weekend). In the
circumstances, the request was deemed to be refused. However, the Bureau has
sought to process and issue a decision notice on your internal review request.
4. This is a decision notice in relation to your internal review request.
5. I am authorised to make a decision in relation to your request pursuant
to s 23 of the FOI Act.
My decision and reasons for decision:
Enquiry:
6. I have considered relevant materials related to the decision-making process
underpinning the Original Decision. I have also considered the terms and character of
your request.
Decision:
7. My decision is:
a. to affirm the Original Decision.
Melbourne Office
GPO Box 1289, Melbourne VIC 3001 Australia | T: +61 3 9669 4000 | www.bom.gov.au | ABN 92 637 533 532
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b. I have had regard to all materials connected to the decision-making process
underpinning the Original Decision to refuse access pursuant to section 24A(1),
including that related to search enquiries and the nature of the Bureau 'payment'
systems.
c. Having regard to all relevant matters, it is my decision that all reasonable steps
were taken to identify document/s in scope of your request. However, given that
no document in scope was found, it was open to the decision-maker of the
Original Decision to refuse access to your request pursuant s 24A.
d. In carrying out the internal review process, which included speaking with relevant
personnel with knowledge of the Bureau's 'payment' systems, I have also
reached the decision that section 24A(1) apply in the circumstances.
8. Reasons for my decision is set out below.
Reasons for decision:
Section 24A(1) of the FOI Act:
9. The Original Decision was an access refusal decision made pursuant to subsection
24A(1). Subsection 24A(1) provides that:
An agency or Minister may refuse a request for access to a document if:
(a) all reasonable steps have been taken to find the document; and
(b) the agency or Minister is satisfied that the document:
(i)
is in the agency’s or Minister’s possession but cannot be found; or
(ii)
does not exist.
10. The Original Decision-maker correctly noted that antecedent to applying sub-s 24A(1),
the decision-maker must be satisfied that two circumstances exist (see Original Decision
at [10]). It requires an objective state of 'satisfaction' that reasonable steps were
undertaken '
to find the document' that is in scope of the access request, and that the
decision-maker is satisfied that, based upon the results of the search process, such
'document' cannot be found or does not exist.
Authoritative guidance:
11. The Original Decision also referred to
Josh Taylor and Minister for Foreign Affairs [2021]
AICmr 33 ('Josh Taytor'). The Australian Information Commissioner ('AIC') in
Josh Taylor
observed at [10] that 'r
easonable', as expressed in s 24A, involves taking steps that do
not go '
beyond the limit assigned by reason’ - such steps being:
not extravagant or excessive; moderate...Of such an amount, size, number etc., as
judged to be appropriate or suitable to the circumstances or purpose.
12. The reference above, as relating to the application of s 24A(1), is directed to the practical
aspect of undertaking a search process in respect of an access request. To this, the
Original Decision relevantly referred to the AIC's FOI Guidelines, which observes that:
[w]
hat constitutes a
reasonable search will depend on the circumstances of each
request and will be influenced by the normal business practices in the agency’s
operating environment.
13. Further to which the FOI Guidelines expresses that:
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[a]
t a minimum, an agency…should take comprehensive steps to locate documents, having
regard to:
•
the subject matter of the documents
•
the current and past file management systems and the practice of destruction or
removal of documents
•
the record management systems in place
•
the individuals within an agency or minister’s office who may be able to assist with the
location of documents, and
•
the age of the documents.
13. Your request is expressly for '
the invoices/receipts' within the timeframe of 10 April 2024
to 10 May 2025
as related
'
to payments to any of the following: DigiCert; CyberTrust;
GeoTrust; QuoVadis; RapidSSL; Thawte; Mocana; Setigo; Comodo (Comodo CA);
Xcitium'.
14. What is sought is clear. The request is for '
invoices' or '
receipts' within the specified
timeframe as related to '
payments' made to these specific
vendors:
a. DigiCert
b. CyberTrust
c. GeoTrust
d. QuoVadis
e. RapidSSL
f. Thawte
g. Mocana
h. Setigo
i. Comodo (Comodo CA); and
j. Xcitium
15. Again, in making this internal review decision, I have had regard to all materials
connected the decision-making process underpinning the Original Decision to refuse
access pursuant to section 24A(1), including that related to search enquiries and the
nature of the Bureau 'payment' systems. Also, as your request relates to 'invoices' and
'payments' as made to vendors, I have spoken to relevant personnel with knowledge of
the Bureau's relevant systems.
16. Having regard to relevant matters I do not consider the Original Decision to have been
incorrectly made. I do not consider there to be circumstances to overturn or modify the
Original Decision. I therefore affirm the Original Decision. I am satisfied that s 24A(1)
was not inappropriately applied in the circumstances. All reasonable steps were taken to
find a document in scope of your request, however, no relevant document was identified
from the search process.
Materials considered in making my decision:
17. In making my decision I have had regard to:
a. your request;
b. the Original Decision;
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c. matters regarding the search process undertaken in respect of the making of the
Original Decision;
d. the nature of the Bureau 'invoice' or 'payment' systems;
e. the FOI Act;
f. the FOI Guidelines issued under s 93A of the FOI Act by the Australian
Information Commissioner; and
g. other relevant matters in the circumstances.
Further information:
18. Information about your review rights is set out in the following pages.
19. The Bureau aims to provide accessible documents. If you need this document in a
different format, or if you have any questions, please contact
xxx@xxx.xxx.xx.
Yours sincerely
(Approved electronically)
Bridie Andriske
General Manager, Organisational Resilience and General Counsel
Enterprise Services Group
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Review rights: External review by the Australian Information Commissioner:
20. You may seek a review of this decision by way of the review rights available to you.
21. You have a right to apply to the Australian Information Commissioner for a review of the
internal review decision.
22. The AIC is an independent office holder who may review decisions of agencies under the
FOI Act. More information is available on website of the Office of the Australian
Information Commissioner:
www.oaic.gov.au.
23. You can contact the OAIC to request a review by one of the following ways:
a.
Via the online form on the OAIC website: https://www.oaic.gov.au/freedom-of-
information/reviews-and-complaints/information-commissioner-review
b.
Email: xxxxx@xxxx.xxx.xx
c. Post, addressing it to:
Director of FOI Dispute Resolution
GPO Box 5218, Sydney NSW 2001
FOI complaints:
24. If you are unhappy with the way we have handled your FOI request, please let us know
what we could have done better. We may be able to rectify the problem. If you are not
satisfied with our response, you can complain to the AIC. A complaint must be made in
writing and can be lodged in one of the following ways:
25. You can contact the OAIC to request a review by one of the following ways:
a.
Via the online form on the OAIC website: https://www.oaic.gov.au/freedom-of-
information/reviews-and-complaints/information-commissioner-review
b.
Email: xxxxx@xxxx.xxx.xx
c. Post, addressing it to:
Director of FOI Dispute Resolution
GPO Box 5218, Sydney NSW 2001
26. More information about Information Commissioner reviews and complaints can be found
on the OAIC's website:
https://www.oaic.gov.au/freedom-of-information/reviews-and-
complaints.
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Document Outline
