Australian Principles on Open Public Sector Information

Australian Information Commissioner, Professor John McMillan AO, will formally launch the Australian "Principles on Open Public Sector Information" in Canberra on 25 May 2011. This will be during the Meta 2011 Conference, at University House, the Australian National University. I have been teaching the draft principles to students in the ANU course COMP7420 and am speaking along with with Senator Lundy at the conference the next day on "Designing for Democratic Dialogue".

Institute of Metadata Management

Press Release

Contact: Michele Berkhout
Phone: +61 415 875 132
E-mail: press(a)metalounge.org

13 May 2011

Information Commissioner to launch
“The Principles on Open Public Sector Information” at Meta 2011

The Institute of Metadata Management is delighted to announce that the Australian Information Commissioner, Professor John McMillan, will be formally launching the Principles on Open Public Sector Information at Meta 2011 to be held at University House, ANU, Canberra, from Wednesday 25th May 2011 to Friday 27th May, 2011.

“The Open Public Sector Information Principles present a core vision for government information management in Australia. They mark a shift in thinking about public sector information. There is now greater recognition that government information is a national resource that should be published for community access and use,” Professor McMillan said.

“The Principles set out the central values of open public sector information: that it be freely available, based on open standards, easily discoverable, understandable, machine-readable, and freely reusable and transformable.” As well as the formal launch there will be a practical demonstration of the benefits of the Principles in a workshop jointly facilitated by the Commissioner’s Office and linked data experts, Dr Armin Haller from the CSIRO and Dr Tudor Groza from the University of Queensland. This workshop will clearly show how, by adopting best practice in the publication of data according to the Principles, the power of linked data and semantic technologies can be leveraged to provide new insights and business intelligence for government, business and the community.

IMM President Mel Taylor is delighted with the collaboration between the IMM and the OAIC as it demonstrates the joint objectives of promoting both the capability and expertise around better information management within the Australian government and, in particular the Metadata community of practice more broadly.

Meta2011 is the fourth conference to be held in Australia and is themed Business Realities and Implications. The 3 days conference will cover topics such as Business intelligence and analytics; Technology solutions; Data integration; Management, governance and stewardship and more.

By attending this conference, delegates are expected to go away with knowledge which can be shared and implemented in their businesses. Registration is still open and there are a range of sponsorship opportunities available. Contact us here to find out how to be part of the IMM community.

For more information related to IMM and Meta2011 please visit http://www.metalounge.org

Information Awareness Month

Greetings from the launch of Information Awareness Month 2011 in the Brindabella Room of the National Library of Australia in Canberra. The Director General of the library opened proceedings by mentioning the need to keep access to information for the public and the excellent way the NLA helps this with the Trove system.

One of the less well known bodies involved in Information Awareness Week, is Disaster ACT (DISACT) , which helps protect cultural materials. Better known are NLA, IIM, AIIA, ACS, RIMPA, ALIA, ACTKM, AGLIN, HIMAA, PROV and ASA.

The official launch was by the Australian Information Commissioner, Professor John McMillan AO. He mentioned three dimensions of information:

1. Information is valuable: The FOI act identifies government information as a public resource. Agencies are now required to publish details of what they do and what information they have.
2. Legal Obligations with Information: Organisations have obligations to keep personal information private. The Commissioner gave examples of companies which have "learnt" from failures to keep information private. But from the long list of recent examples, it appears that corporations have not learnt, or they have learnt there are few penalties for failure.
3. Managing Information Professionally: The commissioner pointed out that while there are numerous organisations involved with information, there is limited coordination between them. Many government organisations now use the FOI recommended icon on their front page.

ps: I will be speaking at the Meta 2011 Conference, as part of information awareness month.

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

Effect of FOI reforms on ICT systems of government

The last talk I attended at the ACS Canberra Conference was Dr. James Popple, Australian Freedom of Information Commissioner, talking about the FOI reforms of government and what this requires of the information systems government uses.

The Office of the Australian Information Commissioner commenced 1
November 2010. This integrates information management, privacy and FOI functions of government.

The new approach is pro-disclosure, treating government information as a national resource. FOI requests can now be submitted by email with no application charges and lower processing charges. The AOIC can investigate complaints about FOI was well help agencies with their
processes.

The first review was "Crowe and NBN Co Ltd". This was a journalist complaining that NBN Co did not provide documents. The decision was that NBN Co. is not subject to the FOI act, as it is not a government agency.
The results are published on the AOIC web site and AustLii.

There are fewer exemptions under the new FOI Act. The seniority and potential embarrassment to senior government officials are specifically not allowed as reasons not to supply documents under FOI.

Documents relating to contract work by private companies are subject to the FOI act.

A disclosure log must be kept by each agency listing documents released (except ones which relate to personal information about individuals). Entries must be included in the log within ten days of release by the document. AOIC is seeking comment on how to do this and have a blog.

Also all agencies must publish information about the agency on their web site (IPS).

IPS may require agencies to publish hundreds of thousands of documents as of 1 May 2011. As Dr. Popple pointed out, agencies are required documents in an accessible format. But agencies may only have some documents on paper, which would need to be scanned in. The image format of the documents are not accessible. Dr. Popple indicated that the AOIC will expect agencies to set realistic timetables as to when and how they will make information available.

Dr. Popple pointed out that the new FOI requirements will require integration between previously separate FOI, records management and web publishing systems.

John Hilvert asked if the AOIC would have an FOI feed, the response was that they were looking at it.

I asked if the penalties in the FOI were sufficient to provide an incentive for staff in agencies to comply. Dr. Popple pointed out there was no penality to the agency, apart from being reported to their minister. However, there was a "no prejudice" provision to be inserted
as 1 May. This will mean that a member of the public can't be disadvantaged by something which should have been published but was not.

Dr. Popple pointed out that agencies could take the opportunity to streamline their operational and other documents. If agencies have a lot of cumbersome separate documents used internally, it might be worth combining them into a more logical structure before public release.

Dr. Popple pointed out that the FOI act uses the terms "document" and "information" almost "interchangeably". So the act most likely applies to collections of electronic data in databases, which are not structured as traditional documents. He suggested that agencies might take the opportunity to ensure information is understandable, but I wonder if some agencies may decide to make the information as unintelligible as possible. ;-)

Dr. Popple pointed out that there is no definitive list of agencies which are subject to the FOI act. So it is not possible for AOIC to have a definitive list.

ps: Dr. Popple is helping with the course COMP7420 Electronic Document and Records Management Technology, in his role as an Adjunct Lecturer at the Austrlaian National Unviersity

Privacy Act Declaration of Emergency

A little known aspect of Australia's Privacy Act (1998) is provision for Declaration of emergency. The Prime Minister or the Attorney General can make a declaration so that the usual restrictions on collection and use of personal information can be relaxed. The Department of Prime Minster and Cabinet website has a page to list emergency declarations. There are currently two listed, for the Queensland 2011 floods and Victorian 2009 brushfires.

Principles for Open Public Sector Information

The Australian Information Commission proposed ten Draft Principles on Open Public Sector Information. Comments are invited via a blog by 1 March 2011:

1. Open access to information - a default position

Information held by the Australian Government is a valuable national resource. As recommended by the Government 2.0 Taskforce, unless there are compelling reasons to the contrary, access to that information should be open, that is:

• free
• based on open standards
• easily discoverable
• understandable
• machine-readable, and
• freely reusable and transformable.

This places a proactive and pro-disclosure obligation on agencies to:

• use information technology to disseminate public sector information, particularly by publishing information online
• maximise the amount of information that is published voluntarily, rather than waiting for specific requests under the FOI Act, and
• apply a presumption of openness when deciding whether and how to publish public sector information.

2. Effective information governance

Information held by Australian Government agencies is a core strategic asset that should be managed effectively by:

• a senior executive information champion, such as a Chief Information Officer within the agency, who is responsible for agency information, management and governance, and
• an information governance body with responsibility for:
  • maximising the integrity, security and availability of the agency's information
  • establishing and maintaining strategic planning processes for information resources management
  • providing leadership and direction in the preparation of the agency's plan for complying with Part II of the FOI Act under s 8(1)
  • ensuring the agency's information management policies incorporate open access principles and authorise the routine and proactive disclosure of information, and
  • ensuring that the agency engages appropriately with stakeholders about access to information.

3. Robust information asset management frameworks

Effective management of information throughout its life cycle can be achieved by:

• developing and maintaining inventories or registers of an agency's key information assets
• identifying the custodians of those assets and defining the custodians' responsibilities
• adequately describing information assets using appropriate metadata
• documenting known limitations on data quality and caveats on data use
• deciding in advance whether information is suitable for publication
• preserving the agency's information assets for appropriate periods of time
• training staff in information management, and
• protecting information commensurate with the risk of harm that could result from the loss, misuse, or unauthorised access to or modification of such information.

4. Findable information

In keeping with the principle that public sector information is a valuable national resource, potential users should be readily able to discover the information an agency has published, and identify assets the agency holds but has not published. This can be achieved by:

• ensuring that published information has high quality metadata through implementation of the Australian Government Locator Service (AGLS) Metadata Standard
• applying search engine optimisation strategies to ensure that all published information can be indexed by search engines, and
• publishing the agency's information asset register to enable both internal and external users of information to identify the available information resources from a single source.

5. Sound decision-making processes

Sound agency decision-making in relation to open access to public sector information can be achieved by:

• ensuring clear lines of authority to make information publication decisions
• establishing mechanisms for potential users of information to apply for release of unpublished information outside of the FOI Act
• making timely decisions
• embedding the presumption that agency information should be published free, on open licensing terms, unless there are compelling reasons to the contrary
• identifying where relevant appropriate alternatives to not publishing information, such as publishing subject to caveats or disclaimers, and
• imposing controls to avoid personal information being published inappropriately or inadvertently in a data set.

6. Transparent complaints processes

Agency decision making about information publication should be transparent. This can be supported, within the agency's information governance framework, by an internal complaints procedure to handle complaints from the public about agency publication decisions outside the requirements of the FOI Act. A transparent complaints procedure will:

• be published
• explain how complaints will be handled
• set timeframes for resolving complaints
• identify possible remedies and outcomes of complaints, and
• require decision makers to provide written reasons for all decisions.

7. Open and accessible formats online

The economic and social value of public sector information is enhanced when it is published online in formats that are human-readable and compatible with the Web Content Accessibility Guidelines endorsed by the Australian Government in February 2010. Information should so far as possible be published in a format that is:

• open
• machine-readable, and
• searchable and indexable by commonly used web search applications.

8. Appropriate charging for access

The principle of open access to public sector information requires that the cost of access to individuals is not unreasonably restrictive. Appropriate charging for access to information can be achieved by:

• not charging more than the additional marginal cost of providing access to published information, and in particular excluding from calculation cost associated with producing the information
• using methods of publication, particularly online publication, that minimise the cost to the agency of providing individual access to the information
• not imposing charges except as authorised by law, including the FOI Act, and
• supporting any charges that are imposed for agency publications or information in an agency policy that explains the basis for charges and is published and regularly reviewed.

9. Clear reuse rights

The economic and social value of public sector information is enhanced when it is made available for reuse on open licensing terms. The Statement of Intellectual Property Principles for Australian Government Agencies requires government agencies subject to the Financial and Management Accountability Act 1997 to consider licensing public sector information, upon release, under an open access licence.

10. Engaging the community

In keeping with Australian Government policy that agencies embrace online engagement in policy design and service delivery, the community can participate in agency decision making in relation to publication of public sector information. This can be done by:

• consulting with the community in deciding which information an agency will
• prioritise for publication
• encouraging the community to identify errors in published information, to give feedback to the agency about the quality, completeness and usefulness of published information, and to tell the agency about productive reuse of the information, and
• responding, either individually or in a public statement, to any comment received from the community.

From: Towards an Australian Government Information Policy, Australian Information Commissioner, November 2010.

Australian Government Information Policy

The Australian Information Commissioner has invited comment on "Towards an Australian Government Information Policy" by 1 March 2011. The paper provides a very comprehensive overview of Australian and overseas policies and initiatives for information access and discussion of the issues. It is 65 pages and is provided as a very efficiently formatted 226 Kbytes web page and a 818 Kbyte PDF file. The document is issued under a Creative Commons Attribution 2.5 Australia licence.

Table of Contents

• Foreword
• Executive summary

1. Introduction
   • About this paper
2. Major reports and initiatives on government information policy in Australia
   • Engage: Getting on with Government 2.0
   • Declaration of Open Government
   • Information Policy and e-governance in the Australian Government
   • Australia's Digital Economy: Future Directions
   • Venturous Australia: Building Strength in Innovation
   • National Government Information Sharing Strategy
   • Ahead of the Game: Blueprint for the Reform of Australian Government Administration
   • Empowering Change: Fostering Innovation in the APS
   • Review of the Australian Government's use of Information and Communication Technology
   • Relevant Reports of the Australian Law Reform Commission
3. Freedom of Information reforms
   • Establishment of the Office of the Australian Information Commissioner and Information Advisory Committee
   • Reform of the Freedom of Information Act 1982
   • Information Publication Scheme
4. Australian Government agencies with a responsibility for government information policy
   • Office of the Australian Information Commissioner
   • Department of the Prime Minister and Cabinet
   • Australian Government Information Management Office
   • Attorney-General's Department
   • National Archives of Australia
   • Australian Bureau of Statistics
   • Defence Signals Directorate
5. Developments in other jurisdictions
   • Developments in Australian States and Territories
   • Developments overseas
6. Examples of public sector information publication, use and reuse in Australia
7. Key issues for Australia
   • Pursuing a more coordinated approach to government information management
   • Ensuring smooth interaction of key information policy agencies and committees
   • Helping agencies implement new information policy
   • Keeping pace with international developments
   • Driving the momentum on open and reusable public sector information
8. Public Sector Information Principles in a National Information Policy
• List of acronyms
• Commenting on this Issues Paper

From: Towards an Australian Government
Information Policy, Office of the Australian Information Commissioner, November 2010