2. Implementing the Information Publication Scheme
The Assistant Secretary, Domestic Legal Branch (AS DLB) is responsible for leading DFAT's implementation of the FOI reforms, including establishment of the IPS.
Establishing DFAT's IPS contribution by 1 May 2011
DFAT is committed to providing information to the public about its functions and activities that is useful, relevant, up to date and accurate. DFAT currently provides:
- responses to information requests from the public
- responses to FOI requests
- information published on the agency website
- printed reports and other material available to the public
DFAT's IPS will proactively identify and publish information that will assist the public to understand and engage with the activities and decisions of the agency.
Roles and responsibilities
The Assistant Secretary, Domestic Legal Branch is supported by the IPS Working Group, the Freedom of Information and Privacy Law Section, the Website Management Section and by officers across the Department to establish DFAT's contribution to the IPS by 1 May 2011.
The IPS working group has developed a draft spreadsheet of information required or permitted to be published under s8(2) and 8(4).
To prepare the draft spreadsheet, the IPS working group spent approximately two months:
- auditing documents currently published on the DFAT website (www.dfat.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 DFAT website)
- compiling a spreadsheet of links to IPS documents on DFAT's internal intranet site that are not currently published on the DFAT website
- identifying any IPS documents that are not accurate, up to date or complete
- nominating suitable staff members to take responsibility for ensuring particular IPS documents which are not accurate, up to date or complete, are revised by 1 May 2011.
The draft spreadsheet facilitates compliance with WCAG 2.0 (see Objectives on page 2), as it:
- describes the format of all IPS documents currently published on the DFAT 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 DFAT website
- contains a link to an RTF version and, if available, a searchable PDF for IPS documents that are not on the DFAT website
- identifies any other issues that may affect publication of an IPS document on the DFAT website.
In the context of the IPS, the Freedom of Information and Privacy Law Section has the following roles:
- initial consultation within the agency to assist other areas in identifying information covered by the FOI reforms
- preparation of the Agency plan for executive endorsement and public consultation
- responding to public feedback and considering changes in the planning and administration of DFAT's IPS
- liaison with DFAT Divisions to assist them to identify and forward documents for publication
- leading the IPS working group
- creation and publication of an information register, which includes the disclosure log for information released under FOI requests
- control and maintenance of the information register to ensure information is up to date and accurate
- setting up a system for fulfilling requests for information that are covered by the IPS but not available electronically, including information in other formats such as hardcopies or on disc. This service may attract a charge for time and materials.
The Website Management Section has the following roles:
- design and development of the DFAT website that meets the requirements of the FOI Act, guidelines of the Office of the Australian Information Commissioner (OAIC), DFAT's commitments and obligations to accessibility standards and the DFAT website design
- preparation of documents for publication with special responsibility for accessibility standards
- publication of information identified under the scheme
- maintenance of the IPS website
- assistance with the development of other systems such as the information register
- responsible for implementation of government compliance and accessibility requirements such as the Web Accessibility National Transition Strategy based on recommendations from the Government 2.0 Taskforce.
- Prior to 1 May, identify, update and arrange for all operational information held by the Department to be made available through the IPS.
- Beyond 1 May, each Division that holds information that is covered by the IPS will be asked to nominate an IPS coordinator for that Division
- IPS coordinators will form the IPS Reference Group under the leadership of the Director Freedom of Information and Privacy Law Section and the Director, Website Management Section
- Further detail on the roles of IPS representatives will be established. However, broadly they will:
- Liaise internally to identify information in their Division covered by the IPS including mandatory and optional information
- clear this information for publication as appropriate
- follow relevant Departmental policies for upload of information to the internet.
- respond to requests for reviews and update new information to maintain the currency of the IPS
Public consultation on the Agency Plan will be welcomed from the time of its publication. Details of this consultation will be available at the time of publication of the Agency Plan.
Expected information upload by 1 May 2011 deadline
DFAT is committed to meeting its obligations under the IPS. For reasons including that certain documents are currently undergoing major revision, not all operational information will be available for download by 1 May. In each case, alternative arrangements for obtaining or discussing the relevant information will be in place and will be publicised on the IPS site. Dates by which it is expected to publish this additional information will be identified and DFAT will continue to identify and publish information into the future.
From 1 May 2011, DFAT's ongoing compliance with the IPS will be coordinated by the Freedom of Information and Privacy Law Section, Website Management Section and Divisions which have responsibility for documents on the IPS website.
Each Division within DFAT will be responsible for day to day tasks associated with complying with the IPS regarding the information relating to their Division. The Freedom of Information and Privacy Law Section will continue to advise on the application of the FOI Act to documents being identified by Divisions for uploading, 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 Department will develop a Guide to publishing information under the IPS for DFAT 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 information to be published under the IPS
- describe the process for publishing information.
The Department will engage in better practice initiatives to engage with the community about DFAT'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 DFAT website with comments on the IPS information holdings, particularly if any documents are found not to be discoverable, understandable or machine-readable
The Department will also put in place a system to enable DFAT IPS documents, which are not available on the DFAT website, to be made available upon request.
DFAT 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 costs (s 8D(4)).
DFAT 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 the relevant Division which owns the document 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).
DFAT will publish its IPS information holdings on its website in accordance with the timetable at Annexure A (except where this is impracticable).
To enhance consistency for public users of the IPS, DFAT's IPS will be accessed via the IPS logo link from the DFAT home page and links for other agency websites.
The IPS information to be published on the DFAT website under the scheme, will be published under the following headings:
Under s8(4), DFAT may also publish other information held by the agency. If so, appropriate headings to capture this information will be utilised in addition to the above.
To ensure that the IPS information holdings (and individual IPS documents) are easily discoverable, understandable and machine-readable, DFAT 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
- establish links to this agency plan
- seek and respond to community feedback about whether the IPS information holdings (and individual IPS documents) are easily discoverable, understandable and machine-readable.
DFAT will make its IPS documents available on the IPS section of the website either through a link from the IPS section or published in the IPS section directly.
DFAT will, so far as possible, make its IPS information holdings available for reuse under a Creative Commons Attribution 3.0 Australia licence, unless otherwise noted as detailed on the DFAT copyright page.
Information required to be published
DFAT will publish documents required to be published under the IPS (s 8(2)) in the IPS section of the DFAT website.
DFAT will publish these documents in accordance with the timeframe set out in Annexure A.
DFAT will publish these documents under the following headings:
- Agency plan
- Who we are
- this will include an organisational chart and information about statutory appointments
- for statutory appointees, DFAT 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 Department
- DFAT will also publish rules, guidelines, practices and precedents relating to these functions and powers.
- Our reports and responses to Parliament
- this will include the full text of DFAT's recent annual reports (2008-2009 and 2009-2010) tabled in Parliament.
- Routinely requested information
- this will include information in documents to which the Department routinely gives access in response to FOI requests
- the Department will clearly identify these documents in its disclosure log, published under s11C of the FOI Act - which requires agencies to publish information contained in documents to which the agency has provided access under the FOI Act.
- this will include information about how and to whom a comment may be submitted by members of the public, where DFAT undertakes public consultation on a specific policy proposal.
- Contact information
- this will include an email address for a contact officer, who can be contacted about access to DFAT's information or documents under the FOI Act. DFAT will establish a generic email address for this purpose that will not change with staff movements.
DFAT 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)). DFAT will publish these documents in accordance with the timeframe set out in Annexure A.
Administering the agency Information Publication Scheme
DFAT's primary mechanism for maintaining its IPS will be the IPS Information Register. The IPS register will record each document as it is identified for publication with the following information:
- Document Name
- Document Type (from the identified categories)
- Country (if relevant)
- Author (DFAT or external author in the case of external research of analysis)
- Clearance information (when and by whom)
- Date Authored
- Update Date (if the information is to be kept up to date)
- Expiry Date (if the information relates to a point in time. It is expected that most documents will be kept for no more than two years, except where they continue to reflect up-to-date operational information).
It is proposed that the IPS Reference Group will meet periodically to review the administration of the scheme, advise and participate in improvements and identify and prepare for publication additional mandatory and optional information.
DFAT'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 accessible format on request, by contacting the relevant Division which owns the document. This may be subject to a small number of exceptions identified in Annexure A.
Approach to accessibility after commencement of the IPS
From commencement of the IPS, DFAT will publish any new IPS documents as soon as they are available for publication.
DFAT will ensure that all information newly published on the DFAT website confirms with the WCAG 2.0 as soon as possible.
DFAT will review and revise this agency plan as required.
DFAT 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 by the Information Commissioner at a later date).