Information Publication Plan
The International Air Services Commission (IASC) is an agency subject to the Freedom of Information Act 1982 (FOI Act) and is required to comply with the Information Publication Scheme (IPS) set out in Part II of the FOI Act. This plan describes how the IASC proposes to comply with those obligations as required by subsection 8(1) of the FOI Act.
Information Publication Scheme requirements
Under Part II of the FOI Act, the IASC must publish the information specified in s 8(2), as set out below. It may also publish additional information under s 8(4). Information published under the IPS must be kept accurate, up to date and complete.
Information required to be published
Subsection 8(2) of the FOI Act requires the following information to be published:
- the agency's plan of how it will comply with the IPS (which is this document);
- details of the agency's structure;
- as far as practicable, details of the agency's functions, including its decision-making powers and other powers affecting the public;
- details of statutory office holders appointed to the agency;
- the information in the agency's annual reports laid before Parliament;
- details of arrangements for the public to comment on specific policy proposals that the agency is responsible for;
- information in documents that the agency routinely gives access in response to FOI requests, except certain personal and business information;
- agency information that is routinely provided to Parliament in response to requests and orders from Parliament;
- the agency's FOI contact officer details; and
- the agency's operational information. Operational information is information held by the agency to assist it in performing or exercising its functions or powers in making decisions or recommendations affecting the public.
The purpose of this plan is to:
- describe what information the IASC proposes to publish, how and to whom the information will be published and how the IASC will otherwise comply with the IPS requirements;
- facilitate public consultation regarding these proposals; and
- comply with s 8(1) of the FOI Act.
The objectives of this plan are to outline appropriate mechanisms and procedures to:
- manage the information holdings relevant to the IPS;
- proactively identify and publish all information required to be published, including this plan (s 8(2));
- proactively identify and publish any optional information (s 8(4));
- review and ensure on a regular basis that information published under the IPS is accurate, up-to date and complete (s 8B);
- ensure that information published under the IPS is easy to find, understandable and re-useable;
- ensure that the format of online content conforms with the Web Content Accessibility Guidelines (Version 2); and
- measure the success of the IASC's IPS.
Establishing an Information Publication Scheme
Recent changes have been made to the FOI Act to make it easier to access and obtain government documents. All government agencies are required to implement mechanisms and systems to enable them to comply with those changes to the FOI Act from 1 May 2011.
Steps taken to ensure compliance with the IPS
To meet the legislative requirements, the IASC has established on its website a dedicated FOI page that enables:
- information required to be published under s.8(2) to be made publicly available; and
- IASC operational information (eg, procedures, instructions, guidelines) to be made publicly available.
Much of the IASC's operational information is already published by the IASC on its website (www.IASC.gov.au). The IASC's operational information that has already been published on the main IASC website will continue to be hosted there, with links to this information provided on the IASC's FOI page.
In order to ensure that the information published under the scheme is discoverable, understandable, machine-readable, accessible and useable, the IASC's FOI page has been set out in a user friendly manner; the search functionality provided on each page will search both titles and text of documents; the content is written in plain English and provided in machine readable formats where possible.
A ‘Disclosure Log’ has been incorporated into the IASC's FOI page to house and allow easy access to documents released in response to FOI requests from 11 May 2011.
Information published on the IASC's FOI page
Under the IPS, certain information is required to be published as specified under s 8(2) of the FOI Act. In accordance with s 8(2), the IASC has published on its FOI page the following information:
- the IASC Information Publication Plan for the IPS [s 8(2)(a)] which is this document;
- who we are [s 8(2)(b)] including biographical notes of the members of the Commission;
- what we do [s 8(2)(c) and s 8(2)(j)], including information about the IASC's functions, decision making powers and operational information including rules and guidelines that assist the IASC to make decisions or recommendations affecting members of the public;
- statutory appointments [s 8(2)(d)] including a list of past and present statutory public office holders of the IASC;
- annual reports and responses to Parliament [s 8(2)(e) and s 8(2)(h)];
- decisions and determinations/ completed cases/ legislative framework and procedures/ client service charter which form part of the IASC's operational information [s 8(2)(j)];
- consultation arrangements [s 8(2)(f)];
- details of the FOI Contact Officer ([[(s 8(2)(i)]; and
- disclosure log listing information released under FOI requests from 1 May 2011.
Administering the IASC's IPS
The IASC will continue to meet its IPS obligations by:
- maintaining a robust information management framework;
- regularly reviewing its website to check content accuracy and relevancy to ensure it meets the requirements of this plan;
- maintaining an internal information register and disclosure log;
- performing ongoing maintenance of information that is required to be published under s 8(2) (information that must be published) via regular website content reviews;
- ensuring the information published continues to be discoverable, accessible, useable, as well as accurate, up-to-date and accessible by regularly reviewing content and staying apprised of developments in accessibility technology and continuing to offer documentation in accessible formats;
- ensuring the information about any charges to be imposed and how they will be calculated continues to be published (ss 8D(4) and 8D(5) of the FOI Act); and
- ensuring information published under the IPS complies with WCAG 2.0 guidelines for accessibility.
The IASC will publish freely accessible information on its website as much as possible. However in some circumstances the IASC may need to apply charges in order to be reimbursed for specific reproduction costs, or other specific incidental costs, incurred in giving access to particular information (s8(D)(4) of the FOI Act).
In determining whether or not to charge for information made available under the IPS, the IASC will take account of the ‘lowest reasonable cost' objective of the FOI Act (s3(4)). The amount or rate of any charge applied by the IASC will be informed by the Freedom of Information (Charges) Regulations 1982.
The IASC's approach to imposing charges and how these will be calculated (under ss8D(4) and 8D(5) of the FOI Act) are as follows:
- the IASC may charge 10 cents per page plus postage costs to produce a hard copy of documents, or in certain circumstances the actual cost incurred of reproducing a document;
- charging on a full cost recovery basis will reflect the cost of the resources used in producing the service. For example, where it is appropriate to fix a charge for producing a document by computer, the actual cost where the IASC uses its own computer facilities will include:
- the cost of labour directly; that is, readily and specifically associated with the production of an output;
- the cost of materials and services directly consumed in the production process;
- an appropriate share of indirect labour costs, both cash and accruing;
- accommodation costs;
- a share of indirect materials and services; and
- capital costs, including depreciation, imputed interest on working capital and a return on non-current assets employed, based on current values.
- if the IASC has to use outside computer facilities, the amount charged for production will be based on actual costs. For example, the time spent by employees when making arrangements for an applicant to hear a recording or view a film or videotape (or making copies of a recording, film CD-ROMs or videotape) will be charged. That amount will be calculated on an hourly rate (pro rata) based on the salary of the employee performing the task, plus any additional cost for overheads;
- applicants will be formally informed of this cost prior to the commencement of the request for information being processed.
Charges for access to the information published under the IPS will only apply to hardcopy documentation and will cover only the cost of production and delivery.
As required by s.9 of the FOI Act, the IASC will review the operation of its Information Publication Scheme, in conjunction with the Information Commissioner, as appropriate from time to time and in any case within 5 years.
The IASC will review and revise this plan, if necessary, at least annually. This will be facilitated by the FOI Officer in conjunction with bi-annual checks of the FOI website content.
The IASC will measure the success of its FOI Website via feedback collected from internal and external users, as well as anonymous data collected on website traffic, in addition to any feedback from the Office of the Australian Information Commissioner, if any.