Our reference: FOI 24/25-1368
10 June 2025
Bob Buckley
By email: foi+request-12862-d110c351@righttoknow.org.au
Dear Bob Buckley
Freedom of Information request — Request consultation process
Thank you for your correspondence of 23 February 2025, in which you requested access under the Freedom of Information Act 1982 (FOI Act) to documents held by the National Disability Insurance Agency (NDIA).
Scope of your request
You have requested access to the following documents:
“Dear National Disability Insurance Agency, Please provide, in accordance with the requirements of the Freedom of Information ACT: a) the data model documentation for the NDIS’s PACE computer system that shows the form of the data describing NDIS participants, their goals, disabilities & impairments, and information used in developing, monitoring and reviewing their plans; b) information about carers and associates of NDIS particpants; [sic] and c) the full meta-data description of the fields in the NDIS’s PACE data model.”
Practical refusal
I am authorised to make decisions under section 23(1) of the FOI Act.
I am writing to advise that the work involved in processing your request in its current form would substantially and unreasonably divert the resources of the NDIA from its other operations due to its size. This is called a ‘practical refusal reason’ under section 24AA of the FOI Act.
On this basis, I intend to refuse your request. However, before I make a final decision, I am writing to provide you with an opportunity to revise your request. This is called a ‘request consultation process’ as set out under section 24AB of the FOI Act. You have 14 days to respond to this notice in one of the ways set out below.
Why I intend to refuse your request
I have consulted with staff in the Technology Services division who conducted a preliminary search for documents which are likely to be relevant to your request. This search has revealed that the NDIA is in possession of more than 3200 individual documents matching the scope of your request, not including any attachments which may be contained within those documents.
On my reasonable estimate, I consider that there is more than 3700 pages worth of material that falls within the scope of your request as currently worded. At a conservative estimate of 1 minute per page, this would take an FOI officer more than 61 hours to simply review and collate the documents.
The documents that are assessed as being within scope of the request will then need to be reviewed for any sensitivities and possible exemption under the FOI Act and scheduled, we will need to consider any consultations and carry these out if required, a decision will need to be made on each document, and a decision letter prepared. This will significantly increase the hours that it will take an FOI officer to process your request.
As a result, I am of the view that the work involved in the processing of this request would substantially and unreasonably divert the resources of the NDIA from its other operations.
Request consultation process
You now have an opportunity to revise your request to enable it to proceed.
Revising your request can mean narrowing the scope of the request to make it more manageable or explaining in more detail the documents you wish to access. For example, by providing more specific information about exactly what documents you are interested in, the NDIA will be able to pinpoint the documents more quickly and avoid using excessive resources to process documents you are not interested in.
Please find below details of the documents located by the relevant business area that fall within the scope of your request:
- Consolidated Data Model (17 documents – 166 pages)
- Salesforce Data Dictionary Tables (2 documents – 358 pages)
- Metadata (approximately 3200 documents – 3200 pages)
After reviewing the information, we believe either the Data Model or Data Dictionary documents would be most relevant to the scope of your request. Please note that a request including both sets of these documents would still be excessive, and we ask that you limit your request to only one.
Therefore, to reduce the scope of your request, you might like to consider:
- Caveating the request to narrow the scope of your FOI request to exclude the documents located under the folder ‘Metadata’
- Selecting either documents under the title Consolidated Data Model or Salesforce Data Dictionary
You have 14 days from the date you receive this letter to contact me and do one of the following: a. withdraw your request b. make a revised request c. indicate that you do not wish to revise the request.
During this period, you are welcome to seek assistance to revise your request. If you revise your request in a way that adequately addresses the practical refusal reason outlined above, we will recommence processing it.
You can contact me by email at foi@ndis.gov.au.
Alternatively, you can reply in writing to the following address:
Freedom of Information Section Information Release, Privacy and Legal Operations Branch Reviews and Information Release Division National Disability Insurance Agency GPO Box 700 CANBERRA ACT 2601
Please do not hesitate to contact me if you have any questions.
Yours sincerely
Kate (KIM627) A/ Assistant Director – Freedom of Information Information Release. Privacy and Legal Operations Branch Reviews and Information Release