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Disclosure log audit

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DOCUMENT 3 FOI 24/25-0861OFFICIAL Standard Operating Procedure

For Internal Use Only

The contents of this document are OFFICIAL.

Disclosure log audit

This document is designed to help staff audit the National Disability Insurance Agency’s

(NDIA) Freedom of Information (FOI) disclosure log. Any person in the team could be

delegated this task. It is usually done quarterly but can be done at any time as required.

  1. Background

The National Disability Insurance Agency is required under section 11C of the Freedom of Information Act 1982 (FOI Act) to publish a disclosure log on the website. The disclosure log

lists information released in response to non-personal FOI requests. The publication of such

documents must be done within 10 working days of the applicant being given access to the

document(s). FOI decision makers email the NDIA’s online team each time they want an entry

added to the disclosure log.

Our external regulator, the Office of the Australian Information Commissioner (OAIC) does periodic audits of agency disclosure logs. In response to these audits, the NDIA aims to do

quarterly audits of its disclosure log. The purpose of this audit it to ensure that all relevant non -

personal requests are listed in the disclosure log, and that the information on the disclosure log

is correct.

  1. Procedure

  2. Access the NDIA’s disclosure log.

  3. Identify all entries on the disclosure log with a date access granted that falls into the period you are checking (for example, during the previous quarter of the financial year).

  4. Download a copy of the FOI database from SharePoint in this folder 4. FOI APP12

PIA Dataases

  1. Cross reference each entry on the disclosure log with the information recorded in the

database’s disclosure log columns BI (Update with direct link) to BL (Date of update). If

a matter has been published on the disclosure log with a note to email foi@ndis.gov.au,

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there should be a 1 in column BK (updating alt. access) and a date in column BL (date

of update). If either of these details are missing, take a note of the reference number

(column F) and name (column G) of the request, and the decision maker’s name

(column BO) in a table.

  1. Then, filter the columns in the FOI database (use your downloaded copy) to show only non-personal requests (column R), released during the last financial quarter (column L),

with an outcome of full or partial (column AD).

  1. Check the disclosure log date of update column (column BL) for notes. If the decision

maker chose not to release the documents, column BL should have a note such as “no

update,” “no” or “not required.”

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  1. If there is no such note in column BK (updating alt. access) or column BL (date of

update). If either of these details are missing, take a note of the reference number

(column F) and name (column G) of the request, and the decision maker’s name

(column BO) in a table.

  1. Go to the FOI Internal Reviews tab of the FOI database. Filter the date of decision column (column G) to show all internal reviews (IRs) released during the quarter. Then

filter the predominately non-personal information column (column J) to show only

non-personal requests. The filter the outcome columns (columns K through R) to show

matters where greater access was given. Check the disclosure log columns (column U

and V). If either of these details are missing, take a note of the reference number (column A) and name (column B) of the request, and the decision maker’s name

(column T) in a table.

  1. Create a table of all the incorrect entries you have found. Include a note stating what

was missing from each matter.

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  1. Email the table to all Assistant Directors in the FOI team. Ask them to follow up with the

team to resolve the inconsistencies and respond back in 7 days. The inconsistencies

could be resolved in multiple ways. These ways include adding missing data to the

database (if a matter is already on the disclosure log); contacting the online team with a

request publish a missing entry on the disclosure log (and then adding the required information to the database); or correcting data on the spreadsheet (for example, if the

request was not a non-personal request or was not a full or partial release).

  1. Seven days later, check all the entries you identified on the FOI database again to

confirm that the inconsistencies have been rectified.

Version Amended Brief Description of Change Status Date by

0.1 LDP633 Initial Version DRAFT 2024-01-29

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