Information Publication Scheme Draft Agency Plan

The Office of the Australian Information Commissioner has issued a "Information Publication Scheme Draft Agency Plan" for comment by 28 March 2011. The document describes how the OAIC proposes to provide details of its own information. The document discusses information architecture, what information is to be published including that required by the FOI Act, accessibility, compliance review and how to promote community engagement. The OAIC clearly is intending to set an example for other agencies to follow. Unfortunately the good information and intentions of the OAIC have been let down by the poor way the document has been formatted. I suggest OAIC adopt Australian Government standard document formats, and so set a good example to other agencies.

This is a 19 page document supplied in PDF (449kbytes) and RTF (20Mbytes) formats. Clearly there is a fault in the formatting of the RTF file, resulting an excessively sized document (about 10 times larger than it need be).

When saved as an ODF text document (the format used by National Archives of Australia) for long term preservation of government documents, the files is 747 kbytes. An examination of the contents of the ODF file indicate that most of the file size is due to incorrectly formatted logos. The factual content of the document is only about 25 kbytes.

I suggest the OAIC abandon the use of PDF and RTF for publishing documents and instead provide accessible, well structured web pages (in HTML). Such documents will be easier top maintain and read.

More generally I suggest that the OAIC and agencies providing FOI Disclosure Logs and other information for the public adopt the metadata standards and document formats recommended by the National Archives of Australia (NAA) for the long term preservation of government records. The documents which are required to be provided under FOI legislation are a subset of those held by government agencies. Eventually those documents will be required to be transferred to the NAA, along with metadata describing them. NAA has established technical standards for the metadata and documents, in accordance with international records management standards. NAA has also produced free open source software to aid this process.

Rather than have OAIC and other government agency create documents in one format and then some time later have them converted for archiving, I suggest agencies use the standard metadata and formats for storage of the documents internally. These then can be provided to the public without the need for conversion and eventually transferred to NAA.

I suggest OAIC abandon the use of PDF and RTF for providing documents. Instead documents can be provided as web pages. This will make the files supplied much smaller and easier to read. In supplying metadata about documents, such as in a document log, I suggest the OAIC use the same metadata standards issued by NAA for records management. This data can be supplied in the form of automatically generated web pages, as well as machine readable formats.

For an overview of the technology and techniques behind this approach see the notes for the postgraduate course COMP7420 "Electronic Document and Records Management,", for the Graduate Studies Select program, College of Engineering & Computer Science, the Australian National University, 2011.

To demonstrate how documents can be provided is web format, here is the text of the OAIC's paper, created by coping and pasting from the RTF version:

Information Publication Scheme

Draft agency plan

March 2011

Contents

• Introduction
• Purpose
• Objectives
• Establishing and administering the OAIC's IPS contribution
• Establishing the OAIC's IPS contribution by 1 May 2011
• Administering information published under the IPS from 1 May 2011
• IPS information architecture
• Information required to be published under the IPS
• Agency plan
• Who we are
• What we do
• Our reports and responses to Parliament
• Routinely requested information
• Consultation
• Contact us
• Optional information to be published under the IPS
• Our priorities
• Our finances
• Our lists
• Our submissions
• Our policies
• Accessibility under the IPS
• Approach to accessibility by commencement of the IPS
• Approach to accessibility after commencement of the IPS
• IPS compliance review
• Annexure A
• Access charges for documents not available on the website
• Annexure B
• Indicative timetable - WCAG 2.0 conformance

Introduction

The Office of the Australian Information Commissioner (OAIC) is an agency subject to the Freedom of Information Act 1982 (FOI Act) and is required to comply with the Information Publication Scheme (IPS) requirements. This agency plan describes how the OAIC proposes to do this, as required by s 8(1) of the FOI Act.

The OAIC is an independent statutory agency established by the Australian Information Commissioner Act 2010. It is headed by the Australian Information Commissioner, supported by two other statutory office holders: the Freedom of Information Commissioner and the Privacy Commissioner.

The Information Commissioner and the Freedom of Information Commissioner have oversight responsibilities in relation to the IPS under the FOI Act. These responsibilities are not covered in this plan. Instead, the Information Commissioner and the Freedom of Information Commissioner are generally referred to in their capacity as leaders of the OAIC, and not in their regulatory capacity under the FOI Act.

The agency plan describes how the OAIC proposes to implement and administer the IPS in respect of its own information holdings, by addressing:

• establishing and administering the OAIC's IPS contribution

• information architecture

• information required to be published

• other information to be published (optional information)

• accessibility to information published

• compliance review

• better practice initiatives including promoting community engagement.

The OAIC will continue to build and foster a culture within the agency, in which appropriate proactive disclosure of its information holdings is embraced, leading to successful implementation and administration of the IPS. This is in recognition that public sector information is a national resource managed for public purposes.

Purpose

The purpose of this agency plan is to:

• assist the OAIC in planning and developing its contribution to the IPS

• facilitate public consultation about that contribution

• show what information the agency proposes to publish (referred to as the IPS information holdings), how and to whom the information will be published and how the OAIC will otherwise comply with the IPS requirements (s 8(1)).

Note: in this plan, information to be published by the OAIC under the IPS is referred to as the IPS information holdings, or as the IPS documents when referring to individual documents.

Objectives

The OAIC's objectives are to outline appropriate mechanisms and procedures to:

• manage the IPS information holdings

• proactively identify and publish all information required to be published (s 8(2))

• proactively identify and publish any optional information to be published (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 easily discoverable, understandable, machine-readable, re-useable and transformable

• ensure satisfactory conformance with the Web Content Accessibility Guidelines (Version 2) (WCAG 2.0)

• measure the success of the OAIC's IPS contribution by reference to community feedback and compliance review processes

• adopt best practice initiatives in implementing and administering the OAIC's contribution to the IPS.

Establishing and administering the OAIC's IPS contribution

The Freedom of Information Commissioner is designated by the OAIC as the senior officer responsible for leading the OAIC's compliance with the IPS - the OAIC IPS Leader.

(a) Establishing the OAIC's IPS contribution by 1 May 2011

The IPS Leader is supported by the IPS Steering Group and IPS Project Team to establish the OAIC's contribution to the IPS by 1 May 2011.

The IPS Steering Group comprises:

• the Assistant Commissioner, Operations

• the Assistant Commissioner, Policy

• the IPS Project Manager

• the Director of Corporate and Public Affairs.

The IPS Steering Group will set up other ad hoc working groups as required.

The IPS Project Team comprises:

• a Director, retained on a temporary basis, to establish the OAIC's IPS contribution (among other responsibilities)

• staff with information technology expertise to publish the relevant documents

• staff from the OAIC's Compliance, Policy and Operations branches as required.

The IPS Project Team has prepared an IPS project plan for tasks to be completed by 1 May 2011, including:

• the OAIC's goals in relation to the IPS

• a timetable for achieving those goals

• how the OAIC will achieve those goals (ie tasks to be completed and responsibility for each goal).

The project team has developed a draft register of information required or permitted to be published under s 8(2) and 8(4) (the draft Register).

To prepare the draft register, the IPS project team spent approximately two months:

• auditing documents currently published on the OAIC website (www.oaic.gov.au) and identifying the documents that will form part of the IPS from 1 May 2011

• creating a list of IPS documents (including those not already published on the OAIC website)

• compiling a list of links to IPS documents on the OAIC's internal document management system that are not currently published on the OAIC website

• compiling a set of hard copy IPS documents that are not published on the OAIC website and are not available on the OAIC document management system

• identifying any IPS documents that are not accurate, up to date or complete

• nominating a staff member responsible for ensuring a particular IPS document which was not accurate, up to date or complete, is revised by 1 May 2011.

The draft register facilitates compliance with WCAG 2.0 (see Objectives on page 2), as it:

• describes the format of all IPS documents currently published on the OAIC websites

• contains a link to an alternative format of an IPS document (preferably an RTF (rich text format) version), where the document is only available in Portable Document Format (PDF) on the OAIC website

• contains a link to an RTF version and, if available, a searchable PDF for IPS documents that are not on the OAIC website

• identifies any other issues that may affect publication of an IPS document on the OAIC website.

The IPS Steering Group has established a working group to consider and finalise the IPS documents to be included on the draft register. This group includes members of the steering group and a senior representative from the Compliance branch.

The IPS Project Team has arranged for public consultation on the Agency Plan in March 2011. This will take place by publishing the draft agency plan on the OAIC website and on the OAIC blog (http://govspace.gov.au/) to seek comments on the plan over a two-week period. The OAIC will promote consultation through news items on the OAIC govdex page (http://www.govdex.gov.au/), on the OAIC website, the OAIC blog and through the Information Contact Officer and IPS networks.

(b) Administering information published under the IPS from 1 May 2011

The OAIC will develop a comprehensive information management framework which will apply to OAIC information published under the IPS. This framework will initially comprise records management plans and policies which are currently under development. The OAIC also intends to develop plans and procedures to address other information asset issues, including intellectual property and copyright.

The OAIC will finalise its records management plans and policies as follows:

• Records management plan (a project plan for the development of an OAIC Records disposal authority and OAIC Records management policy) - to be finalised within six months

• OAIC Records authority and OAIC Records management policy - to be finalised in approximately 12 months.

From 1 May 2011, the OAIC's ongoing compliance with the IPS will be coordinated by an Information Champion - initially the Assistant Commissioner, Policy. This role will later transition to the Assistant Commissioner, Operations.

Each branch of the OAIC will be responsible as required, for day to day tasks associated with complying with the IPS. For example the Operations branch will manage ongoing administration of the IPS information holdings and will be responsible for implementing, reviewing and revising the agency plan.

As part of managing the ongoing administration of the IPS information holdings, the Operations branch (assisted by the Policy branch) will develop a Guide to publishing information under the IPS for OAIC staff. The guide will:

• describe processes to be followed internally to ensure the accuracy, currency and completeness of published information

• help staff to identify on an ongoing basis any required or optional information to be published under the IPS

• describe the process for publishing information.

The Operations branch will lead better practice initiatives to engage with the community about the OAIC's contribution to the IPS. These include:

• issuing a media release announcing the launch of the IPS

• making IPS documents as easily discoverable, understandable and machine-readable as possible

• inviting members of the public to contact the FOI contact officer via the OAIC website with comments on the IPS information holdings, particularly where documents are found not to be discoverable, understandable or machine-readable

• publishing a feedback form on the IPS section of the OAIC website inviting users' comments.

The Operations branch will also arrange OAIC IPS documents, which are not available on the OAIC website, to be made available upon request.

The OAIC may charge a person for accessing any IPS document which it is impracticable to publish online:

• at the lowest reasonable cost

• to reimburse specific reproduction costs or other specific incidental costs (s 8D(4)).

The OAIC will publish on its website a list of any IPS documents that are impracticable to publish online. The website will state that a person seeking access to any of these documents may contact a Corporate and Public Affairs Officer to arrange access.

The list of documents will include indicative charges that may be imposed for making that information available and an explanation for the charge. These charges will be consistent with charges in the Freedom of Information (Charges) Regulations 1982 (which generally apply to access requests under Part III of the FOI Act). Annexure A lists the IPS documents which will not be available online as at 1 May 2011.

IPS information architecture

The OAIC will publish its IPS information holdings on its website in accordance with the timetable at Annexure B (except where this is impracticable).

The IPS information holdings that are available on the OAIC website, will be published under the following headings:

• Agency plan (ss 8(2)(a)

• Who we are (ss 8(2)(b) and 8(2)(d))

• What we do (ss 8(2)(c) and 8(2)(j))

• Our reports and responses to Parliament (ss 8(2)(e) and 8(2)(h))

• Routinely requested information and disclosure log (ss 8(2)(g) and 11C)

• Consultation arrangements (s 8(2)(f))

• Our priorities (s 8(4))

• Our finances (s 8(4))

• Our lists (s 8(4))

• Contact us (s 8(2)(i)).

To ensure that the IPS information holdings (and individual IPS documents) are easily discoverable, understandable and machine-readable, the OAIC will:

• publish an IPS icon on the homepage of its website, which will link to the IPS section of the website

• design and publish an IPS entry point on its website

• wherever possible, provide online content in a format that can be searched, copied and transformed

• publish a sitemap for its website, to help individuals identify the location of information published under ss 8(2) and 8(4)

• provide a search function for its website

• provide an alert service to notify subscribers of new publications under the IPS or other developments in relation to the OAIC's contribution to the IPS

• establish links to this agency plan and to the sitemap at www.directory.gov.au

• seek and respond to community feedback about whether the IPS information holdings (and individual IPS documents) are easily discoverable, understandable and machine-readable.

The OAIC will make its IPS documents available on the IPS section of the website in two ways:

• documents that were published on the OAIC website before 1 April 2011 will be made available through a link from the IPS section

• documents that were published on the OAIC website on or after 1 April 2011 will be published in the IPS section.

The OAIC will, so far as possible, make its IPS information holdings available for reuse on open licensing terms.

Where the OAIC has deposited or published IPS documents under a scheme such as the Commonwealth Library Deposit, the National Sound and Film Archive or www.data.gov.au, the OAIC will publish on its website information about the deposits (including links where available).

Information required to be published under the IPS

The OAIC will publish documents required to be published under the IPS (s 8(2)) in the IPS section of the website at www.oaic.gov.au/ips/.

The OAIC will publish these documents in accordance with the timeframe set out in Annexure B.

The OAIC will publish these documents under the following headings:

Agency plan

Who we are

• This will include an organisation chart, the Agency Employment Agreement and information about statutory appointments.

• For statutory appointees, the OAIC will publish the name of the person appointed, the length or term of appointment, the position to which the person is appointed (and particulars of the position) and the provision of the Act under which the person is appointed.

What we do

• This will outline the functions and decision making powers of the Information Commissioner, Freedom of Information Commissioner, Privacy Commissioner, the Information Advisory Committee and the Privacy Advisory Committee.

• The OAIC will also publish rules, guidelines, practices and precedents relating to these functions and powers. This includes guidelines issued under s 95AA of the Privacy Act 1988, the OAIC Enquiries line manual, guidelines in relation to determinations under s 52 of the Privacy Act 1988, Compliance complaint handling manual, Compliance freedom of information assessment template and Commonwealth spent convictions scheme exclusions.

Our reports and responses to Parliament

• This will include the full text of the OAIC's (or the Office of the Privacy Commissioner's) recent annual reports (2008-2009 and 2009-2010) tabled in Parliament.

Routinely requested information

• This will include information in documents to which the OAIC routinely gives access in response to FOI requests.

• The OAIC will clearly identify these documents in its disclosure log, published under s 11C of the FOI Act - which requires agencies to publish information contained in documents to which the agency has provided access under the FOI Act.

Consultation

• This will include information about how and to whom a comment may be submitted by members of the public, where the OAIC undertakes public consultation on a specific policy proposal.

Contact us

• This will include the name, telephone number and an email address for a contact officer, who can be contacted about access to the OAIC's information or documents under the FOI Act. The OAIC will establish generic telephone numbers and email addresses for this purpose that will not change with staff movements.

Optional information to be published under the IPS

The OAIC will publish on the IPS section of its website other information that it holds (in addition to the information published under s 8(2)), taking into account the objects of the FOI Act (s 8(4)).

The OAIC will publish these documents in accordance with the timeframe set out in Attachment B.

Optional information will be published under the following headings:

Our priorities

• This will include corporate and strategic plans, assessments and reviews.

Our finances

• This will include financial information relating to pay and grading structures, procurement procedures, tendering and contracts.

Our lists

• This will include agency contracts, grants and appointments, and links to data sets.

Our submissions

• This will include submissions made by the OAIC (and the OPC) to Parliamentary committees, the Productivity Commissioner, the Australian Law Reform Commission and other agencies.

Our policies

• This will include the OAIC's procurement, email and internet usage, harassment, maternity leave and workplace diversity policies.

In addition, in the IPS section the OAIC will publish a link to other publications not covered by these headings, including fact sheets, speeches and guidelines.

Accessibility under the IPS

(c) Approach to accessibility by commencement of the IPS

The OAIC will ensure that all online information it is required to publish under the IPS (s 8(2)) conforms with the Web Content Accessibility Guidelines (Version 2) (WCAG 2.0) on commencement of the IPS (1 May 2011).

The OAIC will ensure that optional information published on its website conforms with WCAG 2.0 in accordance with the time frames in Annexure B.

The OAIC's dedicated IPS section of its website will state that where a document is not yet available in an accessible format, it will be made available in an accessible format on request, by contacting the Corporate and Public Affairs Officer (whose contact details will be provided). This may be subject to a small number of exceptions identified in Annexure B.

(d) Approach to accessibility after commencement of the IPS

From commencement of the IPS, the OAIC will publish any new IPS documents as soon as they are available for publication.

The OAIC will ensure that all information newly published on the OAIC website conforms with the WCAG 2.0 as soon as possible.

IPS compliance review

The OAIC will review and revise this agency plan at least annually, which will coincide with the OAIC's strategic planning process.

The OAIC will review the operation of its IPS from time to time and at least every five years, in accordance with the guidelines issued by the Information Commissioner about IPS compliance review (better practice guidance material to assist agencies to comply with the IPS - to be published in the Information Commissioner's regulatory capacity).

Annexure A

Access charges for documents not available on the website

No.	Document title	Date	Format	Charges
1.	Office of the Privacy Commissioner annual reports	1988-1989, 1989-1990, 1990-1991, 1991-1992, 1992-1993, 1993-1994, 1994-1995, 1995-1996, 1996-1997	Photocopy	10 cents per page
			Copy (other than photocopy)	$4.40 per page
			Copy of the document in the form of a computer tape or a computer disk	An amount not exceeding the actual costs incurred by the OAIC in producing the copy
			Copy of the document to be sent to the applicant by post or delivered to the applicant	An amount not exceeding the cost of postage or delivery

Annexure B

Indicative timetable - WCAG 2.0 conformance

The OAIC will ensure, to the extent possible, that all documents available on its website before 1 April 2011 conform with WCAG 2.0 in accordance with the following timetable (subject to exceptions described below):

No.	Document category	Format	Indicative WCAG 2.0 conformance date
1.	All documents required to be published under s 8(2)	RTF, PDF and HTML	18 April 2011
2.	Optional information published under s 8(4)	RTF, PDF and HTML	1 September 2011

The majority of documents listed on the IPS section of the OAIC website will be converted into HTML to meet accessibility requirements. A small number of exceptions may apply to:

• PDFs made of images of scanned documents

• Documents that are out of date, but that are provided for historical reference (these will be supplied in the formats in which they are currently available)

• Charts, tables and forms (these can be supplied in accessible formats on request).

Where possible, documents covered by these exceptions will be published in two alternative formats.

The OAIC will use an automatic word converter and PDF converter to convert a document into HTML. These documents will be proof read and new metadata applied.

The OAIC will ensure that all new documents to be published in the IPS section after 1 April 2011 conform with WCAG 2.0 as soon as possible.

From: Information Publication Scheme Draft Agency Plan, Office of the Australian Information Commissioner, March 2011