If not delivered return to PO Box 7820 Canberra BC ACT 2610
2 February 2017
Our reference: LEX 25282
Mr Justin Warren
By email:
xxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx Dear Mr Warren
Your Freedom of Information request
I refer to your request dated 14 January 2017 and received by the Department of Human
Services (the
department) on the same day for access under the
Freedom of Information
Act 1982 (the
FOI Act) to the following documents:
' - The business case document(s) for the Pay As You Go (PAYG) data matching
initiative that is the subject of Question on Notice HS 15 from the Senate Community
Affairs Legislation Committee Budget Estimates hearing on 3 June 2015.
http://www.aph.gov.au/Parliamentary_Business/Senate_Estimates/clacctte/estimates/
bud1516/DHS/index
- Documents that describe the algorithm or process used to perform the data
matching that identified the "approximately 1,080,000" discrepancies between PAYG
data and data reported by DHS customers, as referred to in the Answer to Question
HS 15.
- Documents that describe the analysis process for how the value of "historical
discrepancies", as described in the Answer to Question HS 15, was determined. Such
documents should describe the statistical method, the sampling process used,
statistics returned (standard error, mean, confidence interval, etc.), how the likely
average debt value was determined, etc.
- Documents containing the program specifications/requirements used to define how
the data matching process should be implemented by programmers. Such documents
would refer to, for example, the use of certain fields to match on such as ABN,
Business Name, Customer Name, etc'.
Your request involves too much work for the department
Your request covers a wide range of documents. We are asking you to revise your request to
give us more specific details about the information you are after because of the amount of
work involved for the department.
If you decide not to make any revisions I will have to refuse your FOI request as a 'practical
refusal reason' exists.
For a more detailed explanation of what this means see
Attachment A.
PAGE 1 OF 4
How to send us a 'revised request'
Before I make a final decision on your request, you can narrow the size of your original
request and submit a revised request.
Within the next 14-days you must do one of the following, in writing:
withdraw the request
make a revised request, or
tell us that you do not want to revise your request.
If you do not do contact us during the 14 day consultation period, we will assume you do not
want to continue with your request. See
Attachment A for relevant sections of the FOI Act.
If you decide to make a revised request you should be more specific about what documents
you want. This could help the department find the documents in less time and use fewer
resources to process them.
We have 30 days to give you a decision about your request, however the time taken to
consult with you now is not included in this 30 day time period.
Contact officer
I am the contact officer for your request. During the consultation period you are welcome to
ask for my help in revising your request. You can contact me:
in writing to the address at the top of this letter
via email t
o xxx.xxxxx.xxxx@xxxxxxxxxxxxx.xxx.xx
Note: When you contact us please quote the reference number
FOI LEX 25282.
Your response will be expected by
16 February 2017. If no response is received, your
matter will be taken as withdrawn.
Further assistance
If you have any questions please email
xxx.xxxxx.xxxx@xxxxxxxxxxxxx.xxx.xx.
Yours sincerely
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Litigation Branch | Legal Services Division
Department of Human Services
PAGE 2 OF 4
Department of Human Services
Attachment A
What I took into account
Because of the amount of work involved for the department, under sections 24AA and 24 of
the FOI Act I intend to refuse your FOI request as a 'practical refusal reason' exists. Under
the Act, the practical refusal reason is that processing your request 'would substantially and
unreasonably divert the resources' of this agency.
To process your request the department would have to do extensive searches to find and
process the documents you asked for. The department holds more than 300 documents,
totalling over 8700 pages.
Based on my experience with the type and volume of records you want, I estimate it would
take more than 850 hours in processing time. This includes looking at all the documents to
see if any of the pages might need redactions - that is, removing content, for example, where
the information is exempt or conditionally exempt.
Amount of time to process your request
I have calculated the number of hours it would take to process your request in full.
Search for and retrieve documents
22 hours
Examine pages for decision making at an average of two minutes
291 hours
per page
Time of three minutes per page for about 8000 pages needing
400 hours
redaction
Write statement of reasons for decision
142 hours
Total
855 hours
Relevant sections of the Freedom of Information Act 1982
Section 24AA(1)(a)(i) of the FOI Act provides that a practical refusal reason exists in relation
to a FOI request if the work involved in processing the request would substantially and
unreasonably divert the resources of the department from its other operations.
Section 24AA(2) of the FOI Act sets out certain factors which the department must consider
when determining whether providing access in relation to a request would substantially and
unreasonably divert the department's resources. The department must specifically have
regard to the resources that would have to be used for:
identifying, locating or collating the documents within the department's filing system;
deciding whether to grant, refuse or defer access to a document to which the request
relates, or to grant access to an edited copy of such a document, including resources
that would have to be used for examining the document or consulting in relation to the
request;
making a copy, or an edited copy, of the document, and
notifying any interim or final decision on the request.
PAGE 3 OF 4
Department of Human Services
Section 24AB(7) of the FOI Act provides that the request is taken to have been withdrawn
under at the end of the consultation period if:
the applicant does not consult the contact person during the consultation period in
accordance with the notice, or
the applicant does not do one of the things mentioned in subsection (6) before the
end of the consultation period.
Section 24AB(6) says that the applicant must, before the end of the consultation period, do
one of the following, by written notice to the agency or Minister:
withdraw the request,
make a revised request, or
indicate that the applicant does not wish to revise the request.
PAGE 4 OF 4
Department of Human Services
