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Information Publication Scheme Agency Plan

April 2011

Introduction

The Office of the Australian Information Commissioner (OAIC) is an agency subject to the Freedom of Information Act 1982 (FOI Act) and is required to comply with the Information Publication Scheme (IPS) requirements. This agency plan describes how the OAIC proposes to do this, as required by s 8(1) of the FOI Act.

The OAIC is an independent statutory agency established by the Australian Information Commissioner Act 2010 (AIC Act). It is headed by the Australian Information Commissioner, supported by two other statutory office holders: the Freedom of Information Commissioner and the Privacy Commissioner.

The Information Commissioner and the Freedom of Information Commissioner have oversight responsibilities in relation to the IPS under the FOI Act. These responsibilities are not covered in this plan. Instead, the Information Commissioner and the Freedom of Information Commissioner are generally referred to in their capacity as leaders of the OAIC, and not in their regulatory capacity under the FOI Act.

The agency plan describes how the OAIC proposes to implement and administer its IPS entry in respect of its own information holdings, by addressing:

  • establishing and administering the OAIC's IPS entry
  • information architecture
  • information required to be published
  • other information to be published
  • IPS compliance review

The OAIC will continue to build and foster a culture within the agency, in which appropriate proactive disclosure of its information holdings is embraced, leading to successful implementation and administration of its IPS entry. This is in recognition that public sector information is a national resource managed for public purposes.

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Purpose

The purpose of this agency plan is to:

  • assist the OAIC in planning and developing its IPS entry
  • facilitate public consultation about that contribution
  • show what information the agency proposes to publish, how and to whom the information will be published and how the OAIC will otherwise comply with the IPS requirements (s 8(1)).

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Objectives

The OAIC's objectives are to outline appropriate mechanisms and procedures to:

  • manage its IPS entry
  • proactively identify and publish all information required to be published (s 8(2))
  • proactively identify and publish any other information to be published (s 8(4))
  • review and ensure on a regular basis that information published as part of its IPS entry is accurate, up to date and complete (s 8B)
  • ensure that information published as part of its IPS entry is easily discoverable, understandable, machine-readable, re-useable and transformable
  • ensure satisfactory conformance with the Web Content Accessibility Guidelines (Version 2) (WCAG 2.0)
  • measure the success of the OAIC's IPS entry by reference to community feedback and compliance review processes
  • adopt best practice initiatives in implementing and administering the OAIC's IPS entry.

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Establishing and administering the OAIC's IPS entry

The Freedom of Information Commissioner is designated by the OAIC as the senior officer responsible for leading the OAIC's compliance with the IPS the OAICIPS Leader.

(a) Establishing the OAIC's IPS entry by 1 May 2011

The IPS Leader is supported by the IPS Steering Group and IPS Project Team to establish the OAIC's IPS entry by 1 May 2011.

The IPS Steering Group comprises:

  • the Assistant Commissioner, Operations
  • the Assistant Commissioner, Policy
  • the IPS Project Manager
  • the Director of Corporate and Public Affairs.

The IPS Steering Group has established other ad hoc working groups as required.

The IPS Project Team comprises:

  • a Director responsible for coordinating the establishment of the OAIC's IPS entry
  • staff with information technology expertise to publish the relevant documents
  • staff from the OAIC's Compliance, Policy and Operations branches as required.

The IPS Project Team has prepared an IPS project plan for tasks to be completed by 1 May 2011, including:

  • the OAIC's goals in relation to the IPS
  • a timetable for achieving those goals
  • how the OAIC will achieve those goals (ie tasks to be completed and responsibility for each goal).

The project team has developed an IPS information register. The IPS information register records details of documents and information required or permitted to be published under s 8(2) and 8(4).

To prepare the IPS information register, the IPS project team spent approximately three months:

  • auditing documents published on the OAIC website (http://www.oaic.gov.au/) and identifying the documents that will form part of the OAIC's IPS entry
  • creating a list of potential IPS documents (including those not already published on the OAIC website)
  • compiling a list of links to IPS documents on the OAIC's internal document management system that are not currently published on the OAIC website
  • compiling a set of hard copy IPS documents that are not published on the OAIC website and are not available on the OAIC document management system
  • identifying and reviewing any IPS documents that are not accurate, up to date or complete.

The information register facilitates conformance with WCAG 2.0 (see Objectives on page 2), as it:

  • describes the format of all IPS documents currently published on the OAIC websites
  • contains a link to an alternative format of an IPS document (preferably an RTF (rich text format) version), where the document is only available in Portable Document Format (PDF) on the OAIC website
  • contains a link to an RTF version and, if available, a searchable PDF for IPS documents that are not on the OAIC website
  • identifies any other issues that may affect publication of an IPS document on the OAIC website.

The IPS Steering Group has established a working group to consider and finalise the IPS documents to be included on the draft register. This group includes members of the steering group and a senior representative from the Compliance branch.

(b) Administering the OAIC's IPS entry from 1 May 2011

The OAIC is developing a comprehensive information asset management framework which will apply to the OAIC's IPS entry. This framework will initially comprise records management plans and policies which are currently under development. The OAIC also intends to develop plans and procedures to address other information asset issues, including intellectual property and copyright.

The OAIC will finalise its records authority and OAIC Records management policy approximately 12 months from 1 May 2011. The OAIC has sought advice from the National Archives of Australia on this process and is employing information management tools, such as the Administrative Functions Disposal Authority (AFDA).

From 1 May 2011, the OAIC's ongoing compliance with the IPS will be coordinated by an Information Champion initially the Assistant Commissioner, Policy. This role will later transition to the Assistant Commissioner, Operations.

Each branch of the OAIC will be responsible as required, for day to day tasks associated with complying with the IPS. For example the Operations branch will manage ongoing administration of the OAIC's IPS entry and will be responsible for implementing, reviewing and revising this plan.

As part of managing the ongoing administration of the OAIC's IPS entry, the Operations branch (assisted by the Policy branch) is developing a Guide to publishing information under the IPS for OAIC staff. The guide will:

  • describe processes to be followed internally to ensure the accuracy, currency and completeness of published information
  • help staff to identify on an ongoing basis any required or other information to be published as part of the OAIC's IPS entry
  • describe the process for publishing information.

The Operations branch will lead better practice initiatives to engage with the community about the OAIC's IPS entry to the IPS. These include:

  • issuing a media release announcing the launch of the OAIC's IPS entry
  • making IPS documents as easily discoverable, understandable and machine-readable as possible
  • inviting members of the public to contact the OAIC enquiries team or to use the OAIC website feedback mechanism to provide comments on the OAIC's IPS entry, particularly where documents are found not to be discoverable, understandable or machine-readable.

The Operations branch will also arrange OAICIPS documents, which are not available on the OAIC website, to be made available upon request.

The OAIC may charge a person for accessing any IPS document which it is impracticable to publish online:

  • at the lowest reasonable cost
  • to reimburse specific reproduction costs or other specific incidental costs (s 8D(4)).

The OAIC will generally not impose a charge where the reimbursement or incidental cost would be lower than $100.

The OAIC will publish on the IPS section of its website a list of any IPS documents that are impracticable to publish online and give details of how a person seeking access to any of these documents will be able to arrange access.

The list of documents will include indicative charges that may be imposed for making that information available and an explanation for the charge. These charges will be consistent with charges in the Freedom of Information (Charges) Regulations 1982 (which generally apply to access requests under Part III of the FOI Act). Annexure A lists the IPS documents which will not be available online as at 1 May 2011.

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IPS information architecture

The OAIC will publish its IPS entry on its website in accordance with the timetable at Annexure B (except where this is impracticable).

The IPS entry will be published on the OAIC website (www.oaic.gov.au) under the following headings:

Required information

  • Agency plan (s 8(2)(a)
  • Who we are (ss 8(2)(b) and 8(2)(d))
  • What we do (ss 8(2)(c) and 8(2)(j))
  • Our reports and responses to Parliament (ss 8(2)(e) and 8(2)(h))
  • Routinely requested information and disclosure log (ss 8(2)(g) and 11C)
  • Consultation arrangements (s 8(2)(f))
  • Contact us (s 8(2)(i))

Other information

  • Our priorities (s 8(4))
  • Our finances (s 8(4))
  • Our lists (s 8(4))
  • Our submissions (s 8(4))
  • Our policies (s 8(4)).

To ensure that the OAICIPS entry (and individual IPS documents) is easily discoverable, understandable and machine-readable, the OAIC has:

  • published an IPSICON on the homepage of its website, which links to the IPS section of the website
  • designed and published an IPS entry point on its website
  • put in place a plan to apply appropriate metadata to online content (AGLS Metadata Standard AS 5044-2010) as soon as reasonably practicable
  • wherever possible, provided online content in a format that can be searched, copied and transformed
  • updated the sitemap on its website, to help individuals identify the location of information published under ss 8(2) and 8(4)
  • provided URL addresses to the sitemap and agency plan from the OAIC's entry on www.directory.gov.au
  • planned to provide a search function for its website as soon as reasonably practical
  • planned to provide an alert service to notify subscribers of new publications or other developments to the OAIC's IPS entry as soon as reasonably practical
  • established a feedback channel for seeking and responding to community feedback about whether the OAIC's IPS entry (and individual IPS documents) is easily discoverable, understandable and machine-readable.

The OAIC will, so far as possible, make its IPS information holdings available for reuse on open licensing terms.

To conform to WCAG 2.0, the OAIC has:

  • Approach to accessibility by commencement of the IPS
    • ensured that all online information that is published under the IPS conforms with WCAG 2.0 in accordance with the timeframes in Annexure B
    • stated on the dedicated IPS section of its website that where a person requires an alternative accessible format of a document that it will be made available on request. This alternative may be subject to a small number of exceptions identified in Annexure B.
  • Approach to accessibility after commencement of the IPS
    • publish any new IPS documents as soon as they are available for publication from commencement of the IPS
    • ensure that all information newly published under the IPS on the OAIC website conforms with WCAG 2.0 subject to a small number of exceptions identified in Annexure B.

The OAIC engaged in public consultation about its draft agency plan in March 2011. The draft plan was published on the OAIC website and the OAIC blog, providing a mechanism for comment over a two week period. The consultation was promoted through news items on the OAIC website, OAIC govdex page, the OAIC blog and through the Information Contact Officers Network (ICON) and IPS networks. Feedback received during the consultation period has been taken into account in preparing this agency plan

The OAIC will continue to engage in public consultation about its agency plan and IPS entry through the feedback mechanism on the IPS section of its website.

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Information required to be published under the IPS

The OAIC will publish documents required to be published under the IPS (s 8(2)) in the IPS section of the website at www.oaic.gov.au/ips.

The OAIC will publish these documents in accordance with the timeframe set out in Annexure B.

The OAIC will publish these documents under the following headings:

Required information

Agency plan

Who we are

  • This will include an organisation chart, the Agency Employment Agreement and information about statutory appointments.
  • For statutory appointees, the OAIC will publish the name of the person appointed, the length or term of appointment, the position to which the person is appointed (and particulars of the position) and the provision of the Act under which the person is appointed.

What we do

  • This will outline the functions and decision making powers of the Information Commissioner, Freedom of Information Commissioner, Privacy Commissioner, the Information Advisory Committee and the Privacy Advisory Committee.
  • The OAIC will also publish rules, guidelines, practices and precedents relating to these functions and powers. This includes the OAICEnquiries line manual and Compliance complaint handling manual,.

Our reports and responses to Parliament

  • This will include the OAIC's (or the Office of the Privacy Commissioner's) recent annual reports (2008–2009 and 2009–2010) tabled in Parliament.

Routinely requested information and disclosure log

  • This will include information in documents to which the OAIC routinely gives access in response to FOI requests and information published under s 11C of the FOI Act.

Consultation arrangements

  • This will include information about how and to whom a comment may be submitted by members of the public, where the OAIC undertakes public consultation on a specific policy proposal.

Contact us

  • This will include the name, telephone number and an email address for a contact officer, who can be contacted about access to the OAIC's information or documents under the FOI Act. The OAIC has established generic telephone numbers and email addresses for this purpose that will not change with staff movements.

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Other information to be published under the IPS

The OAIC will publish on the IPS section of its website other information that it holds (in addition to the information published under s 8(2)), taking into account the objects of the FOI Act (s 8(4)).

The OAIC will publish these documents in accordance with the timeframe set out in Annexure B.

Other information will be published under the following headings:

Other information

Our priorities

  • This will include corporate and strategic plans, assessments and reviews.

Our finances

  • This will include financial information relating to pay and grading structures, procurement procedures, tendering and contracts.

Our lists

  • This will include the agency grants and appointments, and links to data sets.

Our submissions

  • This will include submissions made by the OAIC (and the OPC) to Parliamentary committees, the Productivity Commissioner, the Australian Law Reform Commission and other agencies.

Our policies

  • This will include relevant OAIC corporate policies.

In addition, in the IPS section the OAIC will publish a link to other publications not covered by these headings, including fact sheets, speeches and guidelines. A list of documents that are not practical to publish online will also be available.

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IPS compliance review

The OAIC will review and revise this agency plan at least annually, which will coincide with the OAIC's strategic planning process.

The OAIC will review the operation of its IPS from time to time and at least every five years, in accordance with the guidelines issued by the Information Commissioner about IPS compliance review (better practice guidance material to assist agencies to comply with the IPS to be published in the Information Commissioner's regulatory capacity). The OAIC will give consideration to the most appropriate way for its IPS entry to be reviewed in light of its oversight role.

The OAIC will adopt the following criteria for measuring its performance:

  • (a) agency plan has the OAIC published a comprehensive plan for its IPS compliance?
  • (b) Governance and administration does the OAIC have appropriate governance mechanisms in place to meet its IPS obligations, including a sound information management framework?
  • (c) IPS document holdings has the OAIC reviewed its document holdings to decide what information must be published under s 8(2) and information that can be published under s 8(4)? Is the OAIC's IPS entry accurate, up-to-date and complete?
  • (d) IPS information architecture does the OAIC have a publication framework in place and has it taken the necessary steps to ensure that information in its IPS entry is easily discoverable and accessible?

Agency compliance review does the OAIC have appropriate processes, systems and resources in place to monitor and review its IPS compliance and to make necessary improvements to its IPS implementation?

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Annexure A

Access charges for documents not available on the website

No.Document titleDateFormatCharges
1.

Office of the Privacy Commissioner annual reports

1988, 1989, 1989, 1990, 1990, 1991, 1991, 1992, 1992, 1993, 1993, 1994, 1994, 1995, 1995, 1996, 1996, 1997

Photocopy

10 cents per page

Copy (other than photocopy)

$4.40 per page

Copy of the document in the form of a computer tape or a computer disk

An amount not exceeding the actual costs incurred by the OAIC in producing the copy

Copy of the document to be sent to the applicant by post or delivered to the applicant

An amount not exceeding the cost of postage or delivery

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Annexure B

Indicative timetable for WCAG 2.0 conformance

The OAIC will ensure, to the extent possible, that all documents available on its website conform to WCAG 2.0 in accordance with the following timetable (subject to exceptions described below):

Indicative timetable for WCAG 2.0 conformance
No.Document categoryFormatIndicative WCAG 2.0 conformance date

1.

All documents required to be published under s 8(2)

RTF, PDF and/or HTML

1 May 2011

2.

Optional information published under s 8(4)

RTF, PDF and/or HTML

1 September 2011

The majority of documents listed on the IPS section of the OAIC website will be converted into HTML to meet accessibility requirements. A small number of exceptions may apply to:

  • PDFs made of images of scanned documents
  • Documents that are out of date, but that are provided for historical reference (these will be supplied in the formats in which they are currently available)
  • Charts, tables and forms (these can be supplied in accessible formats on request).

Where possible, documents covered by these exceptions will be published in two alternative formats.

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This page makes up a part of the OAIC Information Publication Scheme IPS