Our reference: FOI 24/25-1368
24 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).
I apologise for the delay in processing your request.
The purpose of this letter is to provide you with a decision on your request.
Scope of your request
You have requested access to the following documents held by the NDIA:
“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.”
Request Consultation
On 10 June 2025, I sent you an email/letter initiating a consultation process under section 24AB of the FOI Act. I advised I intended to refuse access to your request on the grounds that in its current form would substantially and unreasonably divert the resources of the NDIA from its other operations due to its size.
On 21 June 2025, you responded disputing that processing of this request would substantially and unreasonably divert the resources of the NDIA from its other operations.
Decision on access to documents
As you have not removed the practical refusal reason, I have decided to refuse your request pursuant to section 24 of the FOI Act, on the basis that a practical refusal reason exists under section 24AA(1)(a)(i) of the FOI Act.
I made this decision as a delegated decision maker under section 23(1) of the FOI Act.
Reasons for decision
A detailed statement of reasons for my decision can be found at Attachment A.
Rights of review
Your rights to seek a review of my decision, or lodge a complaint, are set out at Attachment B
Should you have any enquiries concerning this matter, please do not hesitate to contact me by email at foi@ndis.gov.au.
Yours sincerely
Kate (KIM627)
A/ Assistant Director – Freedom of Information Information Release, Privacy and Legal Operations Branch Reviews and Information Release Division
Attachment A
Statement of Reasons
FOI 24/25-1368
Practical refusal reason
Relevant law A practical refusal reason exists in relation to a request for documents if the work involved in processing the request would substantially and unreasonably divert the resources of the agency from its other operations¹
In determining whether processing the request would substantially and unreasonably divert the agency’s resources, I am required to have regard to the resources that would have to be used for the following:
- identifying, locating or collating the documents within the Agency
- deciding whether to grant, refuse or defer access to a document including resources used for examining the document and consulting with any person or body in relation to the request
- making a copy or an edited copy of the document
- notifying the decision on the request
As mentioned in the consultation letter, 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.
I provided the following suggestions to help narrow the scope of your request:
- 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
Your response to the consultation disputed the determination that processing the request would substantially and unreasonably divert the agency’s resources.
Accordingly, I am satisfied that a practical refusal reason still exists and that the work involved in processing the request would substantially and unreasonably divert the resources of the agency from its other operations.
Further options for requesting documents
You are welcome to submit further freedom of information requests in the future. In doing so, you may wish to contact the FOI Team directly on foi@ndis.gov.au or advise a convenient time for us to contact you, to engage assistance in developing a scope that does not attract a practical refusal reason under the FOI Act.
¹ 24AA(1)(a) of the FOI Act.
Attachment B
Your review rights
Review by the Office of the Australian Information Commissioner
The FOI Act gives you the right to apply to the Office of the Australian Information Commissioner (OAIC) for a review of this decision.
If you wish to have the decision reviewed by the OAIC, you may apply for review within 60 days of receiving this letter.
You can apply to the OAIC for review in the following ways:
- Online: www.oaic.gov.au
- Post: GPO Box 5218, Sydney NSW 2001
- Email: enquiries@oaic.gov.au
- Phone: 1300 363 992 (local call charge)
Complaints to the Office of the Australian Information Commissioner or the Commonwealth Ombudsman
You may complain to either the Commonwealth Ombudsman or the OAIC about actions the NDIA took in relation to your request. The Ombudsman will consult with the OAIC before investigating a complaint about the handling of an FOI request.
You can make a complaint to the OAIC using the contact details identified above, or to the Ombudsman by:
- Phone: 1300 362 072 (local call charge)
- Email: ombudsman@ombudsman.gov.au
Your complaint should set out the grounds on which you consider the OAIC or the Ombudsman should investigate the NDIA’s handling of your FOI request.