Agencies should designate a freedom of information officer (s 30(b), s 94(f)(i)) and publish clear information statements under s 96 within 12 months of establishment and annually thereafter. The statement must describe structure, functions, public participation arrangements, document types, access procedures, and amendment procedures (s 94). Internal manuals (s 95) must be available for inspection and purchase, with exempt matter deleted where practicable (s 97(1)).
Upon receiving an application, immediately check compliance with s 12. If deficient, take reasonable steps to assist the applicant to correct it (s 11(3)). Acknowledge receipt, determine whether the documents are held, whether transfer is required (s 15), and whether the request is for personal information (triggering s 21 and potential s 28 considerations).
Calculate any charges strictly in accordance with s 16 principles: only routine search time on an hourly basis, no charge for personal information about the applicant, waiver for impecuniosity, and prescribed maximum. Provide estimates if requested or if likely to exceed the prescribed threshold (s 17). Deposits may be required (s 18) but alternatives must be discussed (s 18(2)).
Search thoroughly; if documents cannot be found after reasonable steps, issue a notice under s 26, which is treated as a refusal. For identified documents, assess each exemption in Schedule 1 methodically, starting with the least controversial. Where cl 3 or 4 matter is involved, consult third parties in writing, giving them an opportunity to make submissions (ss 32-33). If consultation yields opposition but release is still intended, notify the third party of the decision, reasons, and review rights, and defer access until the decision is final (s 34).
Prepare notices under s 30 that contain every required element: date, decision-maker's name and designation, reasons, findings on material facts, reference to evidence, charge calculations, and full advice on review rights. If giving edited access, explain the deletions. If deferring, state the period.
For internal review applications under s 39 or s 54, ensure the reviewer is senior to and independent of the original decision-maker (s 41). Treat the review as a fresh access or amendment application (s 42, s 54(3)). No charge is payable (s 44).
Maintain detailed records for the annual s 111 report: numbers of applications, decisions by type, exemptions claimed, internal reviews, amendments, complaints, appeals, fees collected, and waivers. Provide this data to the Information Commissioner as required.
When dealing with Commissioner complaints, produce all requested documents (s 75) but ensure the Commissioner puts in place protective measures (s 74). Agencies are parties to every complaint (s 69(1)) and must give third parties or applicants notice of complaints in appropriate cases (s 68).
For amendment applications, focus on factual accuracy rather than policy disagreement. If refusing, advise of the right to request a notation (s 49(5)(c)). If a notation is made, ensure it travels with the information (s 51). Never obliterate information without Commissioner certification and, where required, State Records Commission notification (s 48(4)).
Train officers on the offence provisions. Implement document retention policies that prevent inadvertent destruction. Ensure decision-makers document their good-faith belief when releasing potentially sensitive material.
Regularly review and update the agency's information statement and internal manuals. Consider proactive release of non-exempt material beyond the Act's requirements, as encouraged by s 3(3). When contracting with service providers, ensure contracts identify a principal officer for FOI purposes and allocate compliance responsibilities.
By embedding these procedures in administrative systems, agencies minimise deemed refusals, reduce complaint volumes, and demonstrate the accountability the Act seeks to promote. Compliance is not merely reactive response to applications but an ongoing obligation to publish, assist, and maintain accurate records.