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Information & Communication Technology

Comments on FOI Disclosure Log Discussion Paper

Published 25 March 2011
Author: Marghanita da Cruz
Telephone: (+61)0414-869-202
Post: PO Box 341 Annandale NSW 2038

The Australian Information Commissioner Act 2010 and the Freedom of Information Amendment (Reform) Act 2010 passed through the Parliament on 13 May 2010 and received Royal Assent on 31 May 2010. The Information Publication Scheme (new Part II of the FOI Act) and a requirement for agencies to publish information where access has been given under Part III of the FOI Act (new section 11C of the FOI Act) will commence on 1 May 2011; - Freedom of Information (FOI) Reform Last Updated: 9 November 2010 viewed 21 March 2011

Comments have been sought on a Disclosure Logs Discussion paper before 28 March 2011

The Disclosure Logs Discussion paper was only made available in two proprietary formats - PDF and RTF. As a result, a paper copy was posted to the Author of these comments. The publication of information in an open interoperable formats that are common to the public's choice of browsers, on their choice of device, which does not require them to download new software (which may not be available for their choice of equipment) should be inherrent to FOI and all information published on Government websites.

Concerns raised about the security of information published on websites is not valid - the format of the document whether PDF, DOC, RTF or anything else does not provide additional security. Authentication and Currency is best provided by accessing material from it source. Government Websites need to be secure. Electronic Copying of Documents, increases the chances of accurate quotation.

As the author was working from a paper copy, the Consultation questions below, have been abbreviated.

  1. Consultation Question 1 Title

    'The purpose of the "disclosure log" is to provide the public with ready access to information that has already been publicly released by an Agency or Minister' - Forward, March 2011 Discussion Paper.

    By providing information in an (RSS News FEED) (RSS) Format, the "Disclosure log" can notify, inform and enable access to information published as a result of an FOI requests.

    "FOI Publication RSS Feed" would inform subscribers about updates to a "FOI Publications Register". FOI Register and Feeds, providing FOI and non-FOI updates on to published information about the administration of agency, program or component of a program, such as the NBNCo, should be established routinely when programs are being implemented. More in comments on Consultation Questions 12,13,14,15 and 16 below.

  2. Consultation Question 2 Consultation on exceptions
  3. Consultation Question 3 IC determination personal case files
  4. Consultation Question 4 Exempted Classes of Information
  5. Consultation Question 5 Agency difficulties in providing Statistical Information

    Giving that FOI Publication of Information should be public and easily discoverable, the Information Commissioner should inform themselves and report on complying and non-complying Agencies, by monitoring both accessability and content of Agencies' performance.

    The FOI Publication Register should also publish statistical data on FOI requests that were denied and class of denial of all or part of information requested. Agencies should also publish information on whether information was required to be provided in an alternate form. Using common open formats for these reports will enable analysis tools of the data to be made available on the OAIC website to analyse/search/subscribe these reports.

    The examples provided in 2010-2011 Agency FOIA Success Stories: Creating a Culture of Transparency are educational and help establish useful performance indicators.

    US Statistical Data includes: Component,Year, Number Pending, Median No. of Days, Average No. of Days, Number Pending, Median No. of Days, Average No. of Days, Number Pending, Median No. of Days, Average No. of Days

  6. Consultation Question 6 Performance of Operation Logs
  7. Consultation Question 7 Common Template

    Consistent open format across agencies would assist the public to access and use information published across agencies. By provide a shared cloud solution to agencies the legislation can be implemented efficiently and effectively. See comment: March 17, 2011 at 10:57 am

  8. Consultation Question 8 Headings in Template

    The RSS Feed fields would be date published, title, URL and description

    The register should provide an electronic identifier to each entry, which is referenced as the URL in the RSS Feed

    Releases should be tagged against a program or legislation to enable the public to access all relevant releases.

  9. Consultation Question 9 FOI Request
  10. Consultation Question 10 How should FOI Request Info be provided
  11. Consultation Question 11 Supplementary information
  12. Consultation Question 12 Making information discoverable, understandable, machine-readable and accessible

    Adopt open standards to encode information (JPG/HTML/RSS), utilise common technology (implement a shared system) using software that can be made available to all agencies and ministers, without license fees. The software and systems should also be available to State and Local Agencies. This will facilitate the publication of information,updates, redirection to new locations and logged deletions) and possibly even result in the use of common accessible terminology.

    Having an easily recognisable icon on agency and ministerial websites may assist the public in discovering what information has been released, however, a single RSS feed, with an icon that is recognisable, to which people can subscribe and webpages that are indexed by search engines would be much more effective in ensuring discovery.

  13. Consultation Question 13 Expiry/Deletion of Information

    I do not understand the purpose or effectiveness of deletion. Information is likely to have been cached, archived, reused etc. Deletion would mean that the public may rely on a secondary source.

    A correctly configured wiki, would provide contributers with guidance on style and structure, effective version control and a history of a document to enable updates, relocation and "deletion", and RSS Feed to inform public of changes.

  14. Consultation Question 14 Should the disclosure log register indicate when information is likely to be removed from an agency's or minister's website, or the date on which information was in fact removed?

    See comments here: [LINK] Copyright questions(Fri Mar 25 10:17:52 EST 2011)

  15. Consultation Question 15 Regular or Continuous Disclosure

    Information should be disclosed continuously.

  16. Consultation Question 16 ensure consistent and suitable approach

    Implement a Shared "cloud" service available to all agencies.

    In designing the "Disclosure Log" system, existing implementations provide useful prototypes to demonstrate what features could be implemented in the system and how they would operate.

This page was last amended 2 May 2016.