In effect from: 1 July 2025

Agencies and Ministers must process a compliant RTI application and give the applicant a decision notice of a considered decision before the end of the processing period.

This page explains how the timeframes in the RTI Act work and how to undertake the various steps involved in processing an application.

In some circumstances, it may be open to an agency to refuse to deal with the application, but the applicant must still receive a decision notice before the processing period ends.

If the applicant does not receive a decision before the end of the processing period, the application will become deemed.

Note: references to an agency on this page include a Minister.

Timeframes under the RTI Act

The processing period

The processing period is the time a decision maker has to give the applicant a considered decision. It is the main time period in the RTI Act. Under section 18 of the RTI Act, it starts at 25 business days and is the total of that period and any additional periods that apply when the agency takes certain actions.

When does the processing period start?

The processing period runs from the valid application day, which is day zero. Valid application day is defined in section 18(4) as the day the application complies with all relevant application requirements.

If the application is compliant when it arrives, the processing period starts on the next business day. If it is noncompliant when it arrives, the processing period starts on the business day after it is made compliant.

If the application is a referral from the Information Commissioner for additional documents located during an external review, the valid application day will be the day of referral.

If the application results from a ‘remittal’ by the Commissioner, so that the agency may make a decision about access or amendment, the valid application day will be 21 days after the Commissioner gives the agency notice of this.

How do RTI Act timeframes work?

There is no clock-stopping in the RTI Act. The length of the processing period is calculated by adding the Act's various time periods to the processing period's minimum 25 business days.

For example: If a decision maker issues a notice of intention to refuse to deal (NIRD), they add the 10 business days of the prescribed consultation period to the initial 25 business days, extending it to 35 business days. If the applicant rectifies their application and the decision maker consults with a third party, they will add another ten business days to the processing period, extending it to 45 business days.

The processing period does not stop until the agency makes a considered decision, or the application is deemed because the agency ran out of time. All of the time an agency spends working on an application is part of the processing period. This means that a Charges Estimate Notice (CEN) can be issued at any point before the processing period ends and an agency is always entitled to the various additional times if it takes certain actions, e.g., the agency will be entitled to the prescribed consultation period if it takes the action of issues a NIRD.

Business days

Timeframes in the RTI Act are calculated in business days. A business day is a day which is not a weekend or a holiday (declared under the Holidays Act 1983: a special, bank or public holiday) in the place where the agency is making their RTI decision. This can differ between agencies, e.g., they may have different public holiday show days.

If the agency is shut down on a day which is not a weekend or holiday, the day counts as a business day. This includes unplanned closures, for example due to extreme weather events, and planned closures, such as days other than public holidays over the Christmas/New Year shut down.

A business day ends at midnight, but agencies should allow at least a few minutes for an email to be delivered if it needs to be received by midnight.

Extending the processing period

The actions that extend the processing period are set out in the table in section 18. They are:

  • Postal address only: the processing period is extended by five business days if the applicant only provides a postal address by the valid application day. The agency is entitled to those five business days even if the applicant later provides, for example, an email address. Once the application is compliant with only a postal address, the five business days are locked in.
  • Issuing a NIRD: the processing period is extended by the prescribed consultation period, which cannot be less (but can with agreement be more) than ten business days.
  • Transferring an application: the processing period is extended by 10 business days or the actual number of business days it takes to transfer, whichever is shorter.
  • Issuing a CEN: the processing period is extended by the number of business days between the date the CEN was issued and either the day the applicant confirms the original or narrowed application or the day the agency gives the applicant a decision to waive the charges.
  • Consultation: the processing period is extended by 10 business days if the agency seeks the views of a concerned third party.
  • Requesting a further specified period: the processing period is extended by the number of business days requested.

Requesting extra time – the further specified period

At any time before the end of the processing period, the decision maker can ask the applicant for more time to work on the application. This is the further specified period. There is no limit on the length of a further specified period or how many an agency can request.

Agencies should request extensions in business days. This allows those business days to simply be added to the processing period, and makes calculation of the total as simple as possible.

The applicant does not need to agree to the request. Asking for a further specified period extends the processing period by the length of the further specified period unless the applicant brings it to an end.

Ending the further specified period

The applicant can bring the further specified period to an end by refusing an extension or applying for external review.

If the applicant refuses an extension request, the processing period ends when the agency receives the refusal. The applicant can refuse the request at any time, even if they previously agreed to it.

The applicant can also end the further specified period by applying for external review under section 86A if the processing period has been extended by a further specified period and the agency is relying on this further specified period.

If this occurs, section 86A(3) provides that the agency's principal officer or Minister is taken to have made a deemed decision as if the further specified period had never been requested, ie on the last day of the processing period minus the further specified period.

Example

If the processing period was 80 business days, and the agency asked for a further specified period of 30 business days, the applicant could not apply for external review on day 75 of the procession period, because the agency was not yet relying on the extra days from further specified period.

The applicant could, however, apply for external review on day 85 of the processing period. As a result of section 86A(3) the deemed decision would be taken to have been made on day 80 of the processing period.

Transferring applications

Access and amendment applications made to one agency under the RTI Act for access to documents can be transferred under section 38 of the RTI Act to another agency if they meet certain criteria. An application transferred from one agency to another is taken to have been made to the other agency.

When can an application be transferred?

An application can only be transferred if:

  • the original agency does not have any or all of the documents applied for
  • the original agency knows that another agency has some or all of the documents applied for; and
  • the other agency consents to the transfer.

The application does not need to be compliant to be transferred.

Applications sent to the wrong agency

Where an application is simply sent to the wrong agency it does not have to be transferred under the transfer provisions. An application is sent to the wrong agency when the other agency’s name is written at the question ‘Which agency are you applying to’.

For example, if the Department of Dogs receives an application form that clearly states the applicant is applying to the Department of Cats, they can return it to the applicant and advise them of the correct address for the Department of Cats. Depending on the circumstances, they may wish to contact the Department of Cats and check if they are happy to have it forwarded to them.

This can't apply to applications made using the online form, because the agency selected from the drop down box at 'Which department are you applying to?' is the agency to which the application is made. If the agency doesn't hold the documents, it will need to consider transferring the application to the agency that does.

The other agency must consent to the transfer

An application can only be transferred from the original agency to the other agency if the other agency consents to the transfer. Generally, the other agency would agree to accept the transfer unless there are unusual circumstances. For example, if it is being transferred at the end of the processing period or the other agency does not hold the documents.

If the other agency declines to accept the transfer, and the applicant will not withdraw or alter the application and apply directly to the correct agency, the original agency must make a reviewable decision on the application.

This may be a noncompliance decision or other decision related to a defect in the application or, if the application was defect free, it may be a decision to refuse access to some or all of the documents on the grounds that they are nonexistent or unlocatable, because they are not in the original agency’s possession or control.

Full or part transfer: the other agency has some or all of the documents

Transferring an application in full

If the original agency has no documents within the scope of an application, but it knows another agency does, it can transfer the entire application to that agency if they consent.

It’s important to be careful when deciding the agency has no documents, particularly during or after a Machinery of Government change. Even where business unit documents are transferred to another agency, corporate records relating to that business unit may have been kept, such as internal audit or ethical standards documents.

Any application fee must be transferred with the application, along with any evidence of identity and/or agent authority documents.

Part-transfer of an application

Where the original agency only has some documents in scope of the application, but it knows another agency has other documents in scope, the application can be part-transferred if the other agency consents.

When an RTI application is part-transferred the applicant will need to pay a further application fee to the other agency, unless all of the documents held by the other agency will contain the applicant’s personal information. This is because their single RTI application has become two RTI applications. It may be worth discussing this with the applicant before attempting to part-transfer the application, as the applicant may prefer to remove those documents from their scope.

If the part of the application retained by the original agency is limited to documents containing the applicant’s personal information, the application fee must be transferred to the other agency.

If the part of the application transferred to the other agency relates only to documents containing the applicant’s personal information, the applicant will not need to pay a further application fee.

The applicant will not need to provide new evidence of identity and/or authority documents (if relevant) as copies can be provided by the original agency.

Timeframes for transferred applications

When an agency agrees to accept a transferred application, they get extra time to make a decision. This is ten business days or the period starting on the day the original agency receives the application and ending on the day it is transferred to the other agency. It can never be longer than ten business days.

Advice to applicant

As a matter of good practice, the original agency should advise the applicant:

  • that their application has been transferred, in full or in part
  • which agency or agencies their application has been transferred to, including contact details
  • if a further application fee may be payable; and
  • the date their application was transferred.

Searching for documents

When an agency has a compliant access application the decision maker must make inquiries with the relevant business units about the existence of documents within the scope of the application.  There are various measures an agency can take to ensure that reasonable and thorough searches for documents are conducted and properly recorded.

Keeping accurate records

Written records of all searches should be kept on file to show that all reasonable steps were taken to locate the documents. These templates should assist decision makers with search process record keeping:

Charging for time spent searching

Processing charges associated with applications made under the RTI Act can include the time taken to search for and retrieve relevant documents.

Informing the applicant

A decision notice should contain detailed information about the searches.  Providing details of searches, for example the names of business units, databases or email accounts searched and if necessary a short explanation of their relevance to the scope of the access application, helps applicants to fully understand the extent of searches undertaken and, if relevant, the reasons why any documents cannot be located.

Searches of backup systems

Searches of a backup system are only mandatory in the circumstances set out in section 52(2) of the RTI Act. In all other cases, they are not required unless the agency considers the search appropriate.

Electronic devices/email accounts

Where an agency has a ‘bring your own device’ policy, allowing agency officers to use their own devices for agency business, it will be particularly important to ensure those devices are captured in any search requests.

Where agency policies specifically allow the use of private email accounts for agency business, for example where officers are travelling or working from home, decision makers may need to consider accounting for this in their search processes.

Off-site storage

Documents stored off-site remain documents of an agency and must be retrieved if they are in scope of an application.

State Archives

If an in-scope document has been stored at Queensland State Archives it must be retrieved and processed, unless it is no longer in the control of the agency, for example if it has passed into the open access period under the Public Records Act 2023 (Qld) (PR Act).

When are searches not required?

Searches for documents will not be required in some circumstances. For example, searches are not necessary when it is appropriate to neither confirm nor deny the existence of documents under section 55 of the RTI Act.

Retention and disposal of public records

The PR Act sets out legislative requirements for the creation, retention and disposal of public records. Where an agency cannot locate documents sought in an access application, the decision maker should determine whether the documents have been destroyed under an approved schedule. If the records have been destroyed under an approved schedule, this needs to be set out in the reasons for decision.

Where documents cannot be located

Section 47(3)(e) of the RTI Act provides that an agency can refuse access to a document that is nonexistent or unlocatable as mentioned in section 52.

Charges Estimate Notices

Under the RTI Act and Right to Information Regulation 2009, an access applicant may need to pay processing and/or access charges. Where charges are payable, the agency must give the applicant a charges estimate notice (CEN).

Requirements of a CEN

A CEN must include:

  • the estimated processing and/or access charges and the basis on which the estimate was made
  • the date the decision that a charge was payable was made and the name and designation of the person making the decision; and
  • any rights of review for the decision, how to exercise the right, and the time within which it must be exercised.

For the first CEN, it must also include:

  • that the applicant can consult with the agency about narrowing their application to reduce the charge; and
  • that if the applicant does not confirm, narrow or withdraw by the end of the prescribed period, they will be taken to have withdrawn the application.

For the second CEN, it must also include that if the applicant does not confirm or withdraw their narrowed application by the end of the prescribed period, they will be taken to have withdrawn the application.

The amount of the charge cannot be reviewed. However, applicants have the right to seek a review of the decision that any charge is payable.

CEN Timeframes

The RTI Act has two CEN timeframes: one for the agency and one for the applicant.

The agency's timeframe is the number of business days between when it issued a CEN and when:

  • the applicant confirms a CEN; or
  • if the applicant applies for financial hardship after receiving a CEN, on the day the agency gives them a decision to waive the charges.

The total number of business days are added to the processing period, extending it.

The applicant's timeframe is a ‘prescribed period’, which sets the time they have to respond to a CEN. It has no effect on the processing period and can be extended if the agency and applicant agree.

Outcomes of issuing a CEN

There can be several outcomes after a CEN is issued.

Applicant does not respond

If the applicant does not respond to a CEN by the end of the prescribed period, they are taken to have withdrawn their application and the agency can close its file. This is not a decision by the agency, it happens automatically, and no decision notice is required, but agencies could consider advising the applicant to prevent future confusion.

Applicant asks for more time

The applicant's prescribed period is 20 business days from the date of the CEN, but it can be extended if the agency and applicant agree. There is no limit on how long an extension can be or how many times it can be extended, but the extension must be agreed to before the prescribed period ends.

There can be no extension after the end of the prescribed period, because at this point the application is taken to be withdrawn, and the agency no longer has a valid application.

Applicant accepts

If the applicant accepts the amount of the charge by confirming the application, the revision period ends. The agency can process the application and include the total final charge in their decision notice.

Applicant narrows

If the applicant narrows their application, the agency will need to consider the narrowed scope, estimate the total amount of processing and access charges payable for the narrowed application, and issue a second CEN to the applicant.

Agencies should issue the second CEN as soon as is reasonably practicable, but there are no time limits for this process. The agency's CEN timeframe does not end until the applicant accepts a CEN or receives a decision to waive charges.

The applicant can only narrow their application in response to the first CEN. They cannot change or expand it.

Applicant applies for financial hardship

If the applicant applies for financial hardship after receiving a CEN, the agency must consider the evidence provided by the applicant and make a decision whether or not to waive the charges.

The agency should give notice of their decision to the applicant as soon as is reasonably practicable. If waiver has been refused, the agency should consider extending the prescribed period, so the applicant has the option to respond to the CEN, eg by narrowing their application.

If the applicant is a non-profit organisation which applies to the Information Commissioner for financial hardship after the agency has issued a CEN, the agency will need to consider whether it is appropriate to extend the prescribed period so the Information Commissioner can make a decision on their application.

The agency is not required to extend the prescribed period in these circumstances, but outside of unusual circumstances or unreasonable conduct, doing so is compatible with the objects of the Act.

Consulting with a relevant third party

If an agency decision maker decides to give access to information that would reasonably be of concern to a third party if it was released, they must take reasonable steps to consult with that third party.

An agency may consult during the initial processing of the application or during an internal review.

Consultation, not permission

Under section 37 of the RTI Act, an agency is consulting with a third party to seek their views about whether:

  • the document is not subject to the RTI Act; and/or
  • the information is exempt or contrary to the public interest to release.

When consulting, the decision maker is not asking for a third party's permission to release the information. Any relevant views provided by the third party must be taken into account but it is up to the decision maker if those views change their proposed decision about giving access to the document.

Reasonable expectations

The views of a third party only need to be sought if it is reasonable to expect that they would be concerned about information being disclosed. This is an objective test that must be approached from the viewpoint of the reasonable decision-maker who must make a judgement about whether it is reasonable to expect the disclosure to be of concern, rather than that being an irrational, absurd or ridiculous outcome (Leech v Sydney Water Corporation [2010] NSWADT 298 citing Neary v State Rail Authority [1999] NSWADT 107; Attorney-General’s Department v Cockcroft (Cockcroft) (1986) 64 ALR 97 at 106).

The expectation of concern must arise from the disclosure itself, not from other circumstances (Murphy and Treasury Department (1995) 2 QAR 744), and there must be more than a mere risk of the third party being concerned about the disclosure (Neary and State Rail Authority [1999] NSWADT 107). An expectation of an occurrence that is merely a possibility (ie speculative, conjectural or hypothetical) is unreasonable (Murphy and Treasury Department (1995) 2 QAR 744).

Generally, disclosure of information may reasonably be expected to be of concern to a third party for the purposes of section 37(1) if the information is important to, or has an important bearing upon, the relevant third party.

When a decision maker consults with a third party or third parties, ten business days (referred to in this guideline as ‘the consultation period’) are added to the processing period or to the internal review processing period.

If the consultation does not actually take place, eg because the decision maker changed their mind or the applicant altered the scope, the decision maker is not entitled to add ten business days to the processing period or internal review processing period for consultation.

Decision makers should consider advising applicants that the due date of the decision has changed to enable consultation with third parties. This will help manage their expectations and prevent them from thinking the agency has run out of time to make a decision.

Internal agency consultation

Decision makers will often need to consult with business units inside their agency. This is not third party consultation under the Act and does not trigger the consultation period.

Officers in their private capacity

If a decision maker needs to consult with an officer of the agency in their private capacity, ie not as an officer but instead representing their own, personal views that is third party consultation under the Act. This may occur, for example, in applications for witness statements or in employment matters.

Agencies and government

When consulting with other agencies, or with governments from other jurisdictions, contact should be made with the Right to Information unit or equivalent. Consultation will generally be undertaken through that unit.

Former Ministers

If you need to consult with a former Minister who is still a Member of Parliament, you can contact them through their electorate office. Alternatively, and for former Ministers who are not currently Members of Parliament, Queensland Parliamentary Services may be able to facilitate consultation with the former Minister.

Deceased people

Section 37 provides that if disclosure of information could reasonably be expected to be of concern to a person but for the fact that they are deceased, the requirement to consult applies to the deceased persons representative.

Depending on how long the person has been deceased, and the nature of the agency's documents, it may be difficult to find their representative.

Third parties should only be provided with the information they are being consulted on. This may require redacting the document to remove other information.

If you can't send the actual document

Wherever possible, the document containing the information subject to consultation should be given to the third party. However, if it is not possible, then the third party can be provided with a detailed description of the information.

This may be necessary in circumstances where, practically, the document cannot be redacted (see below re video footage), where the third party may not know the document exists and there are sound reasons for them not to know, or it is not appropriate, considering the content, for them to be given a copy.

Video footage

Consulting on video footage can be challenging. Depending on the location of the camera, the footage may capture many individuals who may not be identifiable.

If the identity of an individual cannot be determined, or the details of individuals in the footage cannot be obtained, there may be no reasonably practicable steps a decision maker can take to consult.

If the third party or parties can be identified and located, it may not be possible to give them a copy of the footage, due to privacy or practical issues. In that case, the decision maker can provide the third party with a description of the footage, including date, time and location it was taken. In some circumstances, inviting them to view the video may be a suitable alternative.

If the applicant is an individual, the Queensland Privacy Principles (QPPs) will apply to the consultation. Under these principles, disclosure of the applicant's identity to the third party will generally not be permitted, unless one of the exceptions to the non-disclosure rule applies. These would usually be where:

  • the agency has sought the individual’s consent and they have agreed to the disclosure of their identity; or
  • disclosure is authorised or required by law.

Section 37 of the RTI Act does not authorise or require disclosure of the applicant's identity, but if it is necessary to proactively disclose it in order to consult, or consultation will reveal their identity, it will be impliedly authorised or required by law, and therefore permissible under the QPPs.

If the applicant objects

If the applicant objects to their name being given to the third party then the decision maker will have to carefully consider whether it is necessary to disclose the applicant's identity in order to properly consult with the third party. For example, if an agency has to consult with another agency in relation to Crime and Corruption Commission investigation documents, the identity of the applicant will generally be a necessary part of the consultation, as the application of the relevant exempt information provision turns on whether or not the applicant was the investigated party.

Providing context to the third party

Providing context to the third party about who the applicant is can often reassure a third party. For example, telling the third party that the applicant is, or is not, part of a class of people, eg a local resident or member of the media. This would generally not reveal the applicant's identity but could provide enough context to assist the third party.

If the applicant is not an individual

Where the applicant is not an individual (for example, a company) the QPPs do not apply, because only an individual can have personal information. It will be up to the decision maker whether they tell the third party who the applicant is. It is good practice, however, to have a consistent policy that applies across all non-individual applications.

Before sending consultation correspondence, it is a good idea to contact the third party to explain the process and answer any questions.

When writing to the third party to seek their views, the consultation letter should include:

  • details of the consultation provisions of the RTI Act
  • a brief explanation of the consultation process
  • a copy of the information which they are being consulted about
  • details about what they are being consulted on
  • a copy or details of the exempt information provisions and the public interest factors or the relevant provision relating to documents to which the Act does not apply
  • an explanation of the provisions of the RTI Act dealing with disclosure logs
  • the decision maker’s contact details, in case the third party has any queries
  • a date by which the third party must provide a response to the consultation; and
  • what happens if they do not respond.

Consulting where documents concern a child

When preparing for and conducting consultations involving children consider the following:

  • the age of the child and their capacity to understand the consultation
  • the ability of the child to make a ‘mature judgement’ in relation to the consultation
  • guardianship and custody issues
  • whether it is appropriate for the consultation to be undertaken through an independent third party (such as a health care professional); and
  • the presence of a parent or guardian during the consultation process.

Consulting with adults with impaired capacity

Consulting with adults that have impaired capacity can raise similar issues to consulting with children. The decision maker should consider whether it is appropriate to consult directly with the individual or whether the consultation should be with someone who has authority to act on that person’s behalf.

Timeframe for third party to respond

The decision maker must give the third party a reasonable opportunity to respond to the consultation. This will not necessarily be ten business days. To work out how long a reasonable opportunity will be, decision makers should consider:

  • how long it will take for correspondence to be exchanged (eg is the consultation being conducted by post or email)
  • the number of documents and complexity of the information; and
  • any accessibility concerns of the third party.

If the end of the processing period is approaching, decision makers may need to seek an extension from the applicant in order to complete the consultation.

After a consultation, the third party may:

  • have no objections to the release of information
  • not respond to the consultation; or
  • object to the release of all or part of the information.

If the third party has no objections

If the third party does not object to release of the information, the decision maker can release the documents without having to further consider the third party. Once the applicant receives their decision, they can access the documents upon payment of any applicable processing and/or access charges.

If the third party does not respond

If the third party does not respond to the consultation, a decision must be made on access without the benefit of their views. This does not automatically mean the decision maker should decide to release, but they will not have any new information to consider.

If they decide to release, they can do so without having to further consider the third party, because they did not make a decision contrary to views expressed by a consulted third party, as long as the decision maker is satisfied all reasonably practicable steps were taken to seek the views of the third party. Once the applicant receives their decision, they can access the documents upon payment of any applicable processing and/or access charges.

If third party objects to release

If the third party objects to the release of all or part of the information they were consulted on, the decision maker must consider them and make a decision about whether to give access to the document.

If access is given over third party objection

If the decision maker decides to give access over the third party's objections, they must:

  • give a prescribed written notice of their decision to release over their objections to the third party; and
  • defer giving the applicant access to the entire document consulted on until the third party has exhausted their review rights or they have expired.

Defer access to the whole document

It does not matter how much or how little of the document the third party was consulted on, the whole document must be held back from release until the third party has exhausted their review rights or they have lapsed.

The third party decision notice must include reasons for the decision and the third party's review rights.

Give prescribed written notice to the applicant

The decision notice to the third party does not replace the requirement to give a prescribed written notice to the applicant. The decision maker must still deliver a notice of decision to the applicant by the end of the processing period or internal review processing period. These notices should be sent at the same time or, if not possible, the applicant's decision should be sent first.

When access is no longer deferred

When access to the documents is no longer deferred, the decision maker must give the applicant written notice, informing the applicant that the documents can now be accessed. If there are no outstanding charges, the documents could be included with the notice.

Check for an external review

Before releasing deferred documents because the third party's review rights have expired, decision makers should contact the Office of the Information Commissioner's Registry Team on administration@oic.qld.gov.au, to make sure the third party has not lodged an external review.

If access is refused because of third party objection

If the third party objects to release, and the decision maker decides to refuse access to the information they were consulted on, the reasons for refusal must be included in the applicant's notice of decision. There is no need to specifically refer to the third party in these reasons.

In these circumstances, the decision maker does not give a decision notice to the third party, because they are essentially upholding the third party's objections, but it is good practice to tell them the information is not going to be released.

If a third party objects to release after being consulted during the initial processing of an application, and the decision maker decided to release the information over their objections, they may apply for an internal review.

The internal review decision maker must make a new decision on the documents as if the original decision on the document had not been made. If the internal review decision maker changes the original decision and decides to refuse access to information the third party was consulted on, they must give prescribed written notice of their decision to:

  • the third party who sought the review; and
  • the original access applicant, setting out their right to seek an external review, because their right of access has been changed by the internal review decision.

While access applications cannot be made to an agency for RTI processing documents, and this exclusion includes external review correspondence from the Office of the Information Commissioner (OIC), other documents from the OIC can be applied for if they are held by an agency. These could include OIC correspondence sent to an agency during a performance audit or privacy complaint, or material circulated during Privacy Awareness Week.

OIC's view is that consultation with OIC about releasing these documents will generally not be required because OIC considers the professional opinion of a public sector employee given in a professional capacity to be routine personal work information, the disclosure of which would generally not be of concern to that person. The harm that could result from its disclosure would, in most circumstances, be minimal or none.

In addition, OIC supports the pro-disclosure bias of the RTI Act and promotes agency openness wherever possible. The release of documents that record information provided by OIC officers about the Acts will generally not be of concern.

However, if disclosure would not enhance government accountability or provide additional substantive information, and staff involvement was limited to an administrative role, the public interest in disclosure of staff identities may be low, and outweighed by the privacy and personal information factors against disclosure. In these circumstances, an agency considering release may need to consult with the OIC.

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