Compliance Review – Council of the City of Gold Coast
This report details the findings of a review of the Council of the City of Gold Coast’s (COCGC) compliance with key obligations in the Right to Information Act 2009 (Qld) (RTI Act) and the Information Privacy Act 2009 (Qld) (IP Act). In most areas, OIC considers the Council is meeting its legislative obligations well. Key findings were that COCGC:
- had strong governance of community engagement through policies, procedures and organisational responsibility, particularly in dealings with industry, community and research stakeholders
- could take steps to improve general community perceptions about COCGC’s openness and transparency
- had drafted a new information governance framework, strategic plan and performance measures, which if adopted, would provide a strong governance structure with clear leadership and operational roles, appropriately including right to information and information privacy in COCGC’s information governance
- developed a website abundant in provision of information to the community in an accessible format and through administrative access arrangements
- could improve provision of training to staff on privacy obligations and responding to requests for information
- operated the publication scheme generally in accordance with legislative requirements, but could publish more information to the disclosure log consistent with the push model
- evidenced a positive intention and concerted efforts to release information in response to formal applications in accordance with the principles of the right to information legislation, however, applied the legislation unevenly, resulting in non-compliance, and creating inefficiency and unmanaged risk for COCGC; and
- had generally addressed the Information Privacy Principles assessed in this audit in its management of personal information, including camera surveillance footage.
Opportunities for improvement are discussed in greater detail throughout the remainder of the report. Recommendations have been made to assist COCGC in taking up these opportunities to meet right to information and information privacy obligations and adopt good practices. OIC will monitor COCGC’s progress in implementing these recommendations, through provision of six-monthly progress reports from COCGC and a follow-up review.