FOI 55381
Decision and Statement of reasons issued under the Freedom of
Information Act 1982
Decision and reasons for decision of Sharmila (Position Number 62210944),
Information Access Officer, Information Access Unit, Client Access and Rehabilitation Branch,
Department of Veterans’ Affairs
Applicant:
Mr Arthur Jordan
Decision date:
10 February 2023
FOI reference number:
LEX 55381
Sent by email:
xxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Mr Jordan,
Freedom of Information Request: LEX 55381
Purpose of this notice
1.
I have made a decision to refuse access to your revised request on the basis that the
following practical refusal reasons exist:
a. To the extent that I can identify the documents falling within scope of your request,
processing your request, as best the Department can understand the terms, is likely
to result in a substantial and unreasonable diversion of the Department’s resources
from its other operations (section 24AA(1)(b) of the FOI Act).
Authority to make decision
2.
I, Sharmila (Position Number 62210944), Information Access Officer, Information Access
Unit, Client Access and Rehabilitation Branch, am an officer authorised by the Secretary of
the Department to make decisions about access to documents in the possession of the
Department in accordance with section 23(1) of the FOI Act.
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Scope of your request
3.
On 5 January 2023, you made a request for access to documents in the possession of the
Department. Your request sought access to:
'...I request all inward facing documents on the combined library of information and
knowledge (CLIK)...'
4.
On 6 January 2023, the Department acknowledged your request via email.
5.
On 25 January 2023, I formally consulted with you under section 24AB of the FOI Act. I
advised you, as is required under section 24AB of the FOI Act that I intend to refuse your
request on the basis that a practical refusal reason exists, as defined by section 24AA of the
FOI Act.
6.
On 25 January 2023, you responded to the formal section 24AB consult notice expressing
your displeasure of not having any informal consultation. In response to your email the
Department made contact with you on 31 January 2023 and discussed the practical
difficulties and substantial diversion of the Department’s resources in order to release the
requested documents. During this call you specified you will email us a revised scope to be
considered.
7.
On 1 February 2023, you emailed your suggestions to remove the practical refusal reasons as
follows:
‘…I confirm the contents and make the following suggestions so as to remove a
Practical Refusal issue raised by her.
I have raised the letters contents with various Veterans who live and breath Drupal
and know its inner workings and how to use it to its fullest. These are some
suggestions which should remove the Practical Refusal reasons.
1. In Reference to the PDF letter and its sections, responses are noted in quote
marks.
Sec 11 - The request requires exporting all internal contents to a common
acceptable format such as HTML. “The DVA has access via HTML (web base)”
It is assumed that the search will encompass CLIK in its entirety. “This could be
limited to the DVA, and this should have been the assumed access as it was to the
DVA FOI business area not Services Australia.”
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Sec 20 - A revised request may state “with no limitation on the evidence given at the
AAT by Luke Brown, and noting if all your assumptions are correct, a quick and easy
way is to set up a user profile so I have any time access to the inward facing CLIK.
This would be a username and password.”
2. Another option might be to modify the request to specify one document and one
document only; the database schema for CLIK.
This will provide us with a list of all tables that are on CLIK without providing the
documents.
Once we understand the format of the database, we can then request the contents
of a specific table. The table will be the one which holds all the files that are
displayed.
From there we can then request the specific files.
If this option doesn’t work because it’s not hosted on a database, we simply request
a sitemap which includes the full details of every page, including those only
internally available.
The IT department will be the custodians of this information.
The search should take no longer than 15 minutes.
3. A further way to resolve your issues raised is to seek a Table be produced in
accordance with Sec. 17 of the FOI Act, specifying the names and/or titles of ALL
inward facing documents in CLIK…’
8.
As an extension of time was applied to process your request in accordance with the practical
refusal process of the FOI Act, a decision on your request is due by 13 February 2023.
Material taken into account
9.
In accordance with section 26(1)(a) of the FOI Act, my findings on any material question of
fact, the material on which those findings were based and the reasons for my decision to
refuse access to your request follow.
10. I have taken the following material into account in making my decision:
the terms of your request on 5 January 2023 and as revised on 1 February 2023;
the types of information and documents that are in the Department’s possession;
the scope of your request;
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my correspondence with different business areas within the Department;
the availability of information relevant to your request, including the practicality and
time required in which the Department may create a document under section 17 of
the FOI Act;
Sections 3, 11 and 11A of the FOI Act which give the Australian community a legally
enforceable right to obtain access to information held by the Government of the
Commonwealth. I also considered the following provisions of the FOI Act relevant to
my decision:
- Section 15 Request for Access
- Section 17
Requests involving use of computers etc. (e.g. requests for the
Department to create a document)
- Section 24AB – Request Consultation Process
- Section 24AA – Practical Refusal Reasons
the Guidelines issued by the Australian Information Commissioner under section 93A
of the FOI Act (
FOI Guidelines); and
11. A full extract of all FOI Act provisions used to make my decision are provided in
Schedule 2.
Reasons for my decision
12. Section 24 of the FOI Act provides that if the Department is satisfied that a practical refusal
reason exists in relation to a request, the Department must undertake a consultation
process with you, and if, after that consultation process, the Department remains satisfied
that the practical refusal reason still exists, the Department may refuse to give you access to
the documents subject to the request.
When does a practical refusal reason exist (section 24AA of the FOI Act)
13. The practical refusal reason applicable to your request is that:
a. processing your request, as best the Department can understand the terms, is likely to
result in a substantial and unreasonable diversion of the Department’s resources from
its other operations (section 24AA(1)(a) of the FOI Act).
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Request is substantial
14. Under section 24AA(2) of the FOI Act, the Department must have regard to the resources
that would have to be used for:
identifying, locating or collating the documents within the filing system of the
agency;
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
with any person or body 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.
15. Further, the Guidelines issued by the Australian Information Commissioner under s 93A of
the FOI Act (
FOI Guidelines) identify matters that may be relevant when deciding whether
processing the request will unreasonably divert an agency’s resources from its other
functions. These include:
the staffing resources available to the agency for FOI processing;
the impact that processing a request may have on other work in the agency,
including FOI processing;
whether an applicant has cooperated in framing a request to reduce the processing
workload;
whether there is a significant public interest in the documents requested; and
other steps taken by an agency or minister to publish information of the kind
requested by an applicant.
16. Your request contains broad and undefined terms over a long date period. Services Australia
provides technical support for CLIK/Drupal. Therefore, the Department reached out to
Services Australia under our shared services arrangement regarding the feasibility of
extracting the requested information of CLIK and the following assumptions were noted:
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The request requires exporting all internal contents to a common acceptable
format such as HTML.
It is assumed that the search will encompass CLIK in its entirety.
The request poses several challenges for Services Australia:
o Services Australia will need to explore extra modules for Drupal 7 to
experiment, test the export function and implement it in Prod. There could
be weeks’ effort associated with this exercise
o There are currently no tools available to Services Australia to identify and
extract the requested pages/information.
o In the event that all pages or information
could be extracted, each individual
business area would need to review each page to advise a list of content
authors and publishers.
o Further, if Services Australia were successful in exporting the
pages/information, access control issues will need to be considered and
addressed, and business areas will be required to validate all pages and
provide approvals before consideration of release of the information.
o Given the export format will be in HTML, content owner verification
processes to identify any sensitivities will require the relevant business area
to go through the information page by page. This may be resource intensive
depending on the volume of information.
17. Your revised suggestions to the original scope still remains resource intensive and
impractical due to the restraints of software, the volume of data to be extracted, system
security limitations, resourcing and cost.
18. Your first option, of setting up a user profile, is not feasible as this is set up using the DVA HR
system and the user must have an existing profile. The Department is unable to set up an
account without a profile and adding an external party to the HR system would not be
feasible or appropriate.
19. The second option, to modify the request to specify one document and one document only;
the database schema for CLIK, is also not possible.
The business area has advised that
this, in
practice, is the same request as the original and is not feasible.
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20. The other two options, a sitemap which includes the full details of every page including
those only internally available or a table to be produced in accordance with section 17 of the
FOI Act, with names and/or titles of all inward facing documents in CLIK, will be laborious
and resource intensive. The search would take longer than 15 minutes as the Department
currently does not have the visibility and use of a tool within CLIK that could perform this
task. Even though a sitemap and table are potentially feasible, it will take time to investigate
if the requested details could be included in a sitemap and examine the options to generate
a table.
21. The Department has contacted Services Australia under our shared services arrangement
regarding the feasibility of these options and was advised that they would require a
minimum of 3-4 weeks just to conduct an analysis to prepare a report to establish if these
can be facilitated, the time required and the costings to do so.
22. Both Service Australia and DVA have resourcing constraints at present which would mean
this task could take multiple months to complete, if at all it can be completed.
23. I estimate that several months of processing time would be required to deal with this
request. The reasons for this are as follows:
From the responses of the business area and Services Australia, this request would
be resource intensive and expensive. Liaison with Services Australia will be required
and they have advised that there are costs associated with researching, developing
and implementing an extraction tool for CLIK and to conduct an analysis to prepare
sitemap or a table with the requested details. These results would then need to be
verified by the relevant business areas. Once that verification is done, the CLIK
content would have to be collated and sent to the relevant business areas for
identification of sensitive information.
From my initial review, it appears that the documents may potentially contain
material that may be considered to be exempt from release under the FOI Act (for
example, documents affecting certain operations of agencies under section 47E of
the FOI Act, etc.).
Further to the previous point, a statement of reasons will need to be provided to
you. I anticipate that it would take approximately 2 hours to draft the statement of
reason for this decision.
24. Taking these factors into account, I have concluded the request is substantial.
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Request is unreasonable
25. I have considered the suggestions/options given to revise the request during the
consultation, however they are not feasible and remains subject to a practical refusal
reason.
26. I have considered whether the substantial resource burden would be unreasonable having
regard to the following:
The anticipated significant number of hours accumulating to multiple months to
complete the tasks if it can be completed at all is, at face value, an unreasonable
burden for a single FOI request, taking into account the need to process multiple
requests at any given time, and the impact such a burden would have on
responding to other FOI applicants and for the relevant business area and officers
of Services Australia to undertake their designated duties.
Due to the broad nature of your request the relevant business areas and Service
Australia as the provider of technical support to CLIK would be required to spend a
significant amount of time and resources in document retrieval and scoping
activities.
27. Taking the above factors into account, I am of the view that the request as it currently stands
is unreasonable, as well as substantial.
Requests involving use of computers etc. (section 17)
28. In making my decision to refuse your request I also considered the application of section 17
of the FOI Act and whether a document could be created to meet the terms of your
suggestion to produce a section 17 table.
29. Subject to section 17(1)(c)(i), I decided that the department was not in a position to create a
written document, via the use of a computer or other equipment that is ordinarily available
to the department for the purposes of retrieving or collating stored information and;
30. Subject to section 17(2) I decided that the department was not in a position to create a
written document, because to do so would substantially and unreasonably diver the
resources of the Department from its other operations.
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Summary of Decision
31. In summary, I am satisfied that:
a. processing your request, as best the Department can understand the terms, is likely
to result in a substantial and unreasonable diversion of the Department’s resources
from its other operations (section 24AA(1)(a) of the FOI Act).
32. Accordingly, I have decided to refuse your request under section 24(1) of the FOI Act.
Your rights of review
33. If you are dissatisfied with my decision, you may apply for internal review or request the
Office of the Australian Information Commissioner (
OAIC) review my decision. We
encourage you to seek internal review as a first step to resolve any concerns you may have.
Internal review
34. Under section 54 of the FOI Act, you may apply in writing to the Department for an Internal
Review of my decision. The Internal Review application must be made within 30 days of the
date of this letter. Where possible please attach reasons why you believe review of the
decision is necessary. The internal review will be carried out by another officer within 30
days.
35. You can make your application for Internal Review in one of the following ways:
Post:
Information Access Unit,
Department of Veterans’ Affairs
GPO Box 9998, Brisbane QLD 4001
Email:
xxxxxxxxxxx.xxxxxx@xxx.xxx.xx
OAIC review
36. Under section 54L of the FOI Act, you may apply to the OAIC to review my decision. An
application for review by OAIC must be made in writing within 60 days of the date of this
letter, and be lodged in one of the following ways:
Online:
www.oaic.gov.au
Post:
Director of FOI Dispute Resolution
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Facsimile:
(02) 9284 9666
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Phone:
1300 363 992
Email:
xxxxx@xxxx.xxx.xx
37. More information about your review rights under the FOI Act is available in Fact Sheet 12
published by the OAIC:
https://www.oaic.gov.au/freedom-of-information/reviews-and-
complaints/information-commissioner-review/
Contact us
38. If you wish to discuss this decision, please do not hesitate to contact the Information Access
Unit using the following details:
Online:
https://www.dva.gov.au/about-us/overview/reporting/freedom-
information/access-information
Post:
Information Access Unit
Department of Veterans’ Affairs
GPO Box 9998, Brisbane QLD 4001
Phone:
1800 838 372
Email:
xxxxxxxxxxx.xxxxxx@xxx.xxx.xx
Yours sincerely,
Sharmila (Position Number 62210944)
Information Access Officer
Information Access Unit
Client Access and Rehabilitation Branch
Department of Veterans’ Affairs
10 February 2023
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FOI 55381
Schedule 1
Schedule of relevant provisions in the FOI Act
3
Objects—general
(1)
The objects of this Act are to give the Australian community access to information held by
the Government of the Commonwealth or the Government of Norfolk Island, by:
(a)
requiring agencies to publish the information; and
(b)
providing for a right of access to documents.
(2)
The Parliament intends, by these objects, to promote Australia’s representative democracy
by contributing towards the following:
(a)
increasing public participation in Government processes, with a view to promoting
better informed decision-making;
(b)
increasing scrutiny, discussion, comment and review of the Government’s
activities.
(3)
The Parliament also intends, by these objects, to increase recognition that information held
by the Government is to be managed for public purposes, and is a national resource.
(4)
The Parliament also intends that functions and powers given by this Act are to be
performed and exercised, as far as possible, to facilitate and promote public access to
information, promptly and at the lowest reasonable cost.
11
Right of access
(1)
Subject to this Act, every person has a legally enforceable right to obtain access in
accordance with this Act to:
(a)
a document of an agency, other than an exempt document; or
(b)
an official document of a Minister, other than an exempt document.
(2)
Subject to this Act, a person’s right of access is not affected by:
(a)
any reasons the person gives for seeking access; or
(b)
the agency’s or Minister’s belief as to what are his or her reasons for seeking
access.
11A Access to documents on request
Scope
(1)
This section applies if:
(a)
a request is made by a person, in accordance with subsection 15(2), to an agency or
Minister for access to:
(i)
a document of the agency; or
(ii)
an official document of the Minister; and
(b)
any charge that, under the regulations, is required to be paid before access is given
has been paid.
(2)
This section applies subject to this Act.
Note:
Other provisions of this Act are relevant to decisions about access to documents, for example the following:
(a)
section 12 (documents otherwise available);
(b)
section 13 (documents in national institutions);
(c)
section 15A (personnel records);
(d)
section 22 (access to edited copies with exempt or irrelevant matter deleted).
11
Mandatory access—general rule
(3)
The agency or Minister must give the person access to the document in accordance with
this Act, subject to this section.
Exemptions and conditional exemptions
(4)
The agency or Minister is not required by this Act to give the person access to the
document at a particular time if, at that time, the document is an exempt document.
Note:
Access may be given to an exempt document apart from under this Act, whether or not in response to a request
(see section 3A (objects—information or documents otherwise accessible)).
(5)
The agency or Minister must give the person access to the document if it is conditionally
exempt at a particular time unless (in the circumstances) access to the document at that
time would, on balance, be contrary to the public interest.
Note 1: Division 3 of Part IV provides for when a document is conditionally exempt.
Note 2: A conditionally exempt document is an exempt document if access to the document would, on balance, be
contrary to the public interest (see section 31B (exempt documents for the purposes of Part IV)).
Note 3: Section 11B deals with when it is contrary to the public interest to give a person access to the document.
(6)
Despite subsection (5), the agency or Minister is not required to give access to the
document at a particular time if, at that time, the document is both:
(a)
a conditionally exempt document; and
(b)
an exempt document:
(i)
under Division 2 of Part IV (exemptions); or
(ii)
within the meaning of paragraph (b) or (c) of the definition of exempt
document in subsection 4(1).
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Requests for access (as related to the requirements for requests)
Persons may request access
(1)
Subject to section 15A, a person who wishes to obtain access to a document of an agency
or an official document of a Minister may request access to the document.
Requirements for request
(2)
The request must:
(a)
be in writing; and
(aa)
state that the request is an application for the purposes of this Act; and
(b)
provide such information concerning the document as is reasonably necessary to
enable a responsible officer of the agency, or the Minister, to identify it; and
(c)
give details of how notices under this Act may be sent to the applicant (for
example, by providing an electronic address to which notices may be sent by
electronic communication).
(2A) The request must be sent to the agency or Minister. The request may be sent in any of the
following ways:
(a)
delivery to an officer of the agency, or a member of the staff of the Minister, at the
address of any central or regional office of the agency or Minister specified in a
current telephone directory;
(b)
postage by pre-paid post to an address mentioned in paragraph (a);
(c)
sending by electronic communication to an electronic address specified by the
agency or Minister.
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17
Requests involving use of computers etc
(1)
Where:
(a)
a request (inc
luding a request in relation to w
hich a practical refusal reason exists)
is made in accordance with the requirements
of subsection 15(2)
to an agency;
(b)
It appears from t
he request that the desire of th
e applicant is for information that
is not available in discrete form in writte
n documents of th
e agency; and
(ba)
it does not appear from th
e request that t
he applicant wishes to be provided with
a computer tape or computer disk on which the information is recorded; and
(c)
the agency could produce a writ
ten document containing the information in
discrete form by:
(i)
the use of a computer or other equipment that is ordinarily available to the
agency for retrieving or collating stored information; or
(ii)
the making of a transcript from a sound recording held in th
e agency;
the agency shall deal with
the request as if it were
a request for access to a written
document so produced and containing that information and, for that purpose, this Act
applies as if t
he agency ha
d such a document in its possession.
(2)
An agency is not required to comply
with subsection (1) if compliance would substantially and
unreasonably divert the resources of th
e agency from its other operations.
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Decisions to be made by authorised persons
(1)
Subject to subsection (2), a decision in respect of a request made to an agency may be
made, on behalf of the agency, by the responsible Minister or the principal officer of the
agency or, subject to the regulations, by an officer of the agency acting within the scope of
authority exercisable by him or her in accordance with arrangements approved by the
responsible Minister or the principal officer of the agency.
(2)
A decision in respect of a request made to a court, or made to a tribunal, authority or body
that is specified in Schedule 1, may be made on behalf of that court, tribunal, authority or
body by the principal officer of that court, tribunal, authority or body or, subject to the
regulations, by an officer of that court, tribunal, authority or body acting within the scope
of authority exercisable by him or her in accordance with arrangements approved by the
principal officer of that court, tribunal, authority or body.
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Reasons and other particulars of decisions to be given
(1)
Where, in relation to a request, a decision is made relating to a refusal to grant access to a
document in accordance with the request or deferring provision of access to a document,
the decision-maker shall cause the applicant to be given notice in writing of the decision,
and the notice shall:
(a)
state the findings on any material questions of fact, referring to the material on
which those findings were based, and state the reasons for the decision; and
(aa)
in the case of a decision to refuse to give access to a conditionally exempt
document—include in those reasons the public interest factors taken into account
in making the decision; and
Note:
Access must generally be given to a conditionally exempt document unless it would be contrary to the public
interest (see section 11A).
(b)
where the decision relates to a document of an agency, state the name and
designation of the person giving the decision; and
(c)
give to the applicant appropriate information concerning:
(i)
his or her rights with respect to review of the decision;
(ii)
his or her rights to make a complaint to the Information Commissioner in
relation to the decision; and
(iii)
the procedure for the exercise of the rights referred to in subparagraphs (i)
and (ii); including (where applicable) particulars of the manner in which an
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application for internal review (Part VI) and IC review (Part VII) may be
made.
(1A)
Section 13 of the Administrative Decisions (Judicial Review) Act 1977 does not apply to a
decision referred to in subsection (1).
(2)
A notice under this section is not required to contain any matter that is of such a nature
that its inclusion in a document of an agency would cause that document to be an exempt
document.
(see section 11A).
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Power to refuse request--diversion of resources etc.
(1)
If an agency or Minister is satisfied, when dealing with a request for a document, that a
practical refusal reason exists in relation to the request (see section 24AA), the agency or
Minister:
(a)
must undertake a request consultation process (see section 24AB); and
(b)
if, after the request consultation process, the agency or Minister is satisfied that
the practical refusal reason still exists--the agency or Minister may refuse to give
access to the document in accordance with the request.
(2)
For the purposes of this section, the agency or Minister may treat 2 or more requests as a
single request if the agency or Minister is satisfied that:
(a)
the requests relate to the same document or documents; or
(b)
the requests relate to documents, the subject matter of which is substantially the
same.
24AA When does a practical refusal reason exist?
(1)
For the purposes of section 24, a practical refusal reason exists in relation to a request for a
document if either (or both) of the following applies:
(a)
the work involved in processing the request:
(i)
in the case of an agency--would substantially and unreasonably divert the
resources of the agency from its other operations; or
(ii)
in the case of a Minister--would substantially and unreasonably interfere
with the performance of the Minister's functions;
(b)
the request does not satisfy the requirement in paragraph 15(2)(b) (identification
of documents).
(2)
Subject to subsection (3), but without limiting the matters to which the agency or Minister
may have regard, in deciding whether a practical refusal reason exists, the agency or
Minister must have regard to the resources that would have to be used for the following:
(a)
identifying, locating or collating the documents within the filing system of the
agency, or the office of the Minister;
(b)
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:
(i)
examining the document; or
(ii)
consulting with any person or body in relation to the request;
(c)
making a copy, or an edited copy, of the document;
(d)
notifying any interim or final decision on the request.
(3)
In deciding whether a practical refusal reason exists, an agency or Minister must not have
regard to:
(a)
any reasons that the applicant gives for requesting access; or
(b)
the agency's or Minister's belief as to what the applicant's reasons are for
requesting access; or
(c)
any maximum amount, specified in the regulations, payable as a charge for
processing a request of that kind.
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24AB What is a request consultation process?
Scope
(1)
This section sets out what is a request consultation process for the purposes of section 24.
Requirement to notify
(2)
The agency or Minister must give the applicant a written notice stating the following:
(a)
an intention to refuse access to a document in accordance with a request;
(b)
the practical refusal reason;
(c)
the name of an officer of the agency or member of staff of the Minister (the
contact person ) with whom the applicant may consult during a period;
(d)
details of how the applicant may contact the contact person;
(e)
that the period (the consultation period ) during which the applicant may consult
with the contact person is 14 days after the day the applicant is given the notice.
Assistance to revise request
(3)
If the applicant contacts the contact person during the consultation period in accordance
with the notice, the agency or Minister must take reasonable steps to assist the applicant
to revise the request so that the practical refusal reason no longer exists.
(4)
For the purposes of subsection (3), reasonable steps includes the following:
(a)
giving the applicant a reasonable opportunity to consult with the contact person;
(b)
providing the applicant with any information that would assist the applicant to
revise the request.
Extension of consultation period
(5)
The contact person may, with the applicant's agreement, extend the consultation period by
written notice to the applicant.
Outcome of request consultation process
(6)
The applicant must, before the end of the consultation period, do one of the following, by
written notice to the agency or Minister:
(a)
withdraw the request;
(b)
make a revised request;
(c)
indicate that the applicant does not wish to revise the request.
(7)
The request is taken to have been withdrawn under subsection (6) at the end of the
consultation period if:
(a)
the applicant does not consult the contact person during the consultation period in
accordance with the notice; or
(b)
the applicant does not do one of the things mentioned in subsection (6) before the
end of the consultation period.
Consultation period to be disregarded in calculating processing period
(8)
The period starting on the day an applicant is given a notice under subsection (2) and
ending on the day the applicant does one of the things mentioned in paragraph (6)(b) or (c)
is to be disregarded in working out the 30 day period mentioned in paragraph 15(5)(b).
Note: Paragraph 15(5)(b) requires that an agency or Minister take all reasonable steps to notify an applicant of a
decision on the applicant's request within 30 days after the request is made.
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No more than one request consultation process required
(9)
To avoid doubt, this section only obliges the agency or Minister to undertake a request
consultation process once for any particular request.
16
