Alex Caughey Hutt
Associate Director, Information
Governance & Access,
University Governance Office
xxx@xxx.xxx.xx
23 January 2026
Joyce Mayer
Via email:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
FOI 202500303 – Decision Notice
Dear Joyce,
On 24 November 2025 the Australian National University (the University) received your
request seeking access to documents under the
Freedom of Information Act 1982 (the
Act)
.
Scope of the Request
Your request stated you were requesting:
“… any [and] all documents held by ANU for October 2024 for the College of
Science Dean payments. This includes invoices and SAP concur payments;
receipts and travel forms/email approvals.”
On 25 November 2025, we sought clarification from you on whether you were seeking
payments made to the Dean, or payments approved by the Dean. You confirmed on the
same day that you were seeking payments made to the Dean.
Thank you again for your engagement with us during the progression of your case.
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 of the Act to make decisions in respect of
requests to access documents or to amend or annotate records.
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 located two documents relevant to your request, which are outlined
in the attached Document Schedule. Document 1 is a Tax Invoice for conference
registration and a dinner co-payment. Document 2 is a Refund Notification confirming
that a refund was processed to the account associated with the Dean. While the
original payment was an expense incurred by the Dean, the subsequent refund of these
funds constitutes a payment made "to" the Dean within the scope of your clarified
request.
I have decided to grant access to Document 1 in full.
I have decided to grant partial access to Document 2, with some information being
exempt under section 47E(d) of the Act, as disclosure of the information requested
could reasonably be expected do have a substantial adverse effect on the proper and
efficient conduct of the operations of the University.
A copy of the documents and a Document Schedule are enclosed with this letter.
The Australian National University
2
CRICOS Provider #00120C
My findings of fact and reasons for deciding that the exemption applies to the
information in Document 2 are set out below.
4.
Sections 47E(d) of the FOI Act – Operations of an Agency
I have considered whether material within the documents may be exempt under section
47E(d) of the FOI Act.
Section 47E(d) of the Act provides that a document is conditionally exempt if its
disclosure could reasonably be expected to “… have a substantial adverse effect on the
proper and efficient conduct of the operations of an agency”.
Document 2 contains material that relates to a University payment method.
Specifically, the partial credit card number (the card type and the final four digits) used
to process the refund. This information has not been publicly released. If this
conditionally exempt material in Document 2 were to be released, there is a reasonable
expectation that such release could have a substantial adverse effect on University
operations by undermining, impairing or impeding the University’s ability to manage its
financial security.
Credit card details (even partial details), when combined with other information that is
already in the public domain, information that has been leaked, or information that is
known to a third party through any other means, can be used to facilitate unauthorised
transactions. In the same vein, the University needs to rely on the confidentiality of
payment instruments to maintain secure purchasing and procurement processes.
Disclosure of payment details not in the public domain could reasonably be expected to
compromise key financial controls that are in place to bolster the security of the
University’s financial systems and ensure the integrity of the University’s expenditure.
Further, if credit card details are disclosed, the University may need to cancel cards,
reissue cards and strengthen monitoring of card use. This would divert resources away
from current core functions to mitigate the impact of the disclosure of such details.
More broadly, if the University begins revealing sensitive operational details (including
credit card details) as a matter of course, it could reasonably be expected to weaken
our overall security posture and create systemic vulnerability.
The Australian National University
3
CRICOS Provider #00120C
These impacts would all be heightened were the credit card details to be made publicly
available for anyone’s access on the internet (as would be the case here, with the
University’s response being published on the
Right to Know website). Regardless of the
avenue this access request was made, I consider that disclosure of information under
the Act must be considered to be disclosure to the world at large and not just to you as
the applicant. In this instance, if a bad actor were to become party to these card details
– alongside any other information they might need to undermine the University’s
payment systems and controls – it could also put the staff member to whom the card
was issued at risk of having their University-issued card misused, and they would then
need to be involved in the consequences that stem from such misuse (e.g. time and
resource diverted to compiling information to understand the impact of the potential
misuse).
I therefore consider this material to be conditionally exempt under section 47E(d) of
the Act, as its release could reasonably be expected to have a substantial adverse
effect on the University’s ability to effectively manage its financial security and
therefore the integrity of its expenditure.
5.
Section 47E(d) of the Act and the public interest
In deciding that the information referred to above is conditionally exempt under section
47E(d) of the Act, I must also consider the fact that access to conditionally exempt
documents must generally be given unless it would be contrary to the public interest to
do so.
In applying this test, I have weighed the factors in favour of disclosure versus those
against it.
Public interest – Factors for disclosure
I have identified the following factors in favour of disclosure of the relevant material:
• Disclosure would arguably promote the objects of the Act, as described in
section 3 of the Act.
Public interest – Factors against disclosure
The Australian National University
4
CRICOS Provider #00120C
I have identified the following factors that weigh heavily against disclosure of the
relevant material:
• Disclosure could facilitate fraudulent activity.
• Disclosure could compromise key financial controls, and undermine the
University’s ability to safeguard its payment systems.
• Should the University’s financial systems be compromised as a result of a
disclosure, mitigation measures would need to implemented, which would
divert time and resources away from core functions and operations.
• Disclosure of the documents would not inform debate on a matter of public
importance.
• Disclosure of the redacted material would not provide an oversight of public
expenditure.
• Following from that, there is enough information being released in the
surrounding document to reveal oversight of public expenditure (or, in this
case, a refund).
• Disclosure of conditionally exempt material would not allow a person to
access his or her own personal information.
• There is no legitimate business, operational, legal or regulatory purpose for
the University to reveal these details.
I am also satisfied that the information at hand is not well known to the public
generally, and is not available from publicly accessible sources. As stated earlier in this
letter, I also consider that disclosure of information under the FOI Act must be
considered to be disclosure to the world at large and not just to you as the applicant.
Balancing the public interest factors for and against disclosure
After balancing all of the above relevant public interest considerations in relation to
the matters at hand, I consider that the public interest factors that are against
disclosure outweigh the factors in favour of disclosure. Consequently and overall, I
have decided that disclosure of the relevant material would have a substantial adverse
effect on the University’s ability to manage its financial security and expenditure
integrity.
The Australian National University
5
CRICOS Provider #00120C
I have therefore concluded that the disclosure of the conditionally exempt material in
Document 2 under section 47E(d) of the Act is not in the public interest and is therefore
exempt from disclosure under the Act.
5.1
Section 11B(4) – Irrelevant Considerations
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.
Your review rights are outlined on the following page.
Yours sincerely,
Alex Caughey Hutt
Associate Director
Information Governance & Access Director
University Governance Office
Australian National University
Encl.
1. Schedule of Documents – Ref. 202500303
2. Document Package – Ref. 202500303
The Australian National University
6
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
7
CRICOS Provider #00120C
