The Australian Charities and Not-for-profits Commission (ACNC) is established by the Australian Charities and Not-for-profits Commission Act 2012 (Cth).
We are subject to the Freedom of Information Act 1982 (Cth) (FOI Act) and must comply with the requirements of the Information Publication Scheme (IPS). This Agency Plan has been prepared in accordance with subsection 8(1) of the FOI Act and describes how the ACNC intends to comply with the IPS.
We are committed to building a pro-disclosure culture in keeping with the objects of the FOI Act, in which we manage government-held information as a national resource and seek to increase public participation in government processes. In doing so, we demonstrate the transparency and accountability that we expect from the charities we work with.
The purpose of this Agency Plan is to:
- comply with section 8(1) of the FOI Act
- assist the ACNC in planning and developing appropriate procedures to comply with the IPS
- show the public what information the ACNC proposes to publish, how and to whom the information will be published, and how the ACNC will otherwise comply with the requirements of the IPS, and
- facilitate consultation with stakeholders about the ACNC's compliance with the IPS and disclosure of information generally.
The objective of this Agency Plan is to outline the mechanisms and procedures that the ACNC will put in place to:
- manage its IPS entry
- identify and publish the information required to be published
- actively identify other information that can be published
- regularly review information published under the IPS to ensure it is accurate, up-to-date and complete
- ensure that information published under the IPS is easily discoverable, understandable, accessible and reusable
- aim to meet the Web Content Accessibility Guidelines (Version 2) (WCAG 2.0)
- measure the success of the ACNC’s IPS entry by reference to community feedback and annual review processes
- promote greater understanding of the objects of the FOI Act across the ACNC and encourage a pro-disclosure culture in accordance with government policy.
Establishing and administering the ACNC's IPS entry
The FOI contact officer (under the supervision of the Director of Legal) is responsible for leading the agency’s work in relation to the IPS requirements. The role of the FOI contact officer in relation to the IPS is set out in more detail in OP 2015/05 Operational Procedure: Publishing Information under the Information Publication Scheme. This Procedure, together with OP 2013/01 Operational Procedure Identifying documents for the IPS, explains the process for publishing information on the IPS.
On an ongoing basis, each directorate will have designated responsibilities for ensuring that the IPS is accurate, up-to-date and complete. OP 2013/01 specifies which directorate has been allocated responsibility for particular categories of required information.
In addition, the ACNC will develop an internal IPS Information Register which will identify documents for publication on the IPS and allocate responsibility for ensuring that the document contains information which is accurate, up-to-date and complete. The IPS Information Register will also record decisions made in relation to publication of documents as set out in OP 2015/05. Further, a quarterly standing agenda item will be added to the monthly management meeting which is attended by each director and the Executive. This will ensure that there is a designated time for management to discuss any matters relating to the IPS.
Prior to the relevant management meeting, the FOI contact officer will send an email to each director to request consideration of whether the IPS should be updated, with particular reference to each director’s area of allocated responsibility, and any relevant documents on the IPS Information Register which are ‘owned’ by or allocated to that director.
Each year, the ACNC will conduct a full review of the IPS entry (including the Agency Plan) and consult with stakeholders at this time to ensure that the IPS entry is user-friendly and contains the information that stakeholders require. This review will be conducted in accordance with OP 2013/02 Operational Procedure: Review of the Information Publication Scheme.
As the ACNC is a small agency, there are no specific resources allocated to maintaining the IPS. However, as outlined above, responsibility for maintaining the IPS has been allocated to various staff at the ACNC as part of their general duties.
As the purpose of the IPS is to make the maximum amount of information readily available at minimum inconvenience and cost to the public, the ACNC will endeavour to make information available online free of charge. The ACNC may charge a person for accessing any IPS document that is impracticable to publish online at the lowest reasonable cost. Details of charges will be made available on our IPS page.
IPS information architecture
The ACNC plans to take the following steps to ensure that its information is easily discoverable and useable:
- publish its IPS entry to the general community on its website in accordance with the timeline outlined below
- investigate opportunities to publish datasets to data.gov.au as they become available
- use the Office of the Australian Information Commissioner (OAIC) IPS and Disclosure Log icons on its homepage to direct users to those resources
- aim to publish all online information with regard to WCAG 2.0 requirements
- to the extent practicable, publish information in html with other formats (including printed documents) available on request
- to the extent practicable, publish under an open licence (usually CC-BY, the licence from the Creative Commons suite with the fewest restrictions, to encourage reuse of the ACNC's information)
- apply AGLS Metadata (AS 5044-2010, the standard mandated for use on Australian Government websites) to online content
- provide a sitemap to help individuals locate information on the ACNC website
- investigate ways to allow individuals to receive notifications of updates, including through the use of social media and an email subscription list
- encourage public comment on any aspect of the IPS site or the information published on it by providing contact details.
Information required to be published under the IPS (s 8(2))
The ACNC will publish the information required by part 2 of the FOI Act under the following headings. In some cases, the entries will consist of links to this information elsewhere on the ACNC website.
- IPS Agency Plan
Timeframe: at commencement of the ACNC
- an organisation chart setting out the structure of the organisation and the lines of accountability. Information about the functions of each part of the organisation will also be provided
- information about our leaders
- details of appointments made under our Act – such as the appointment of our Commissioner and membership of our Advisory Board
Timeframe: at commencement of the ACNC
- details of our functions, including decision-making powers and other powers affecting members of the public
- our annual reports
- our operational information insofar as it extends to our exercising functions and powers in making decisions or recommendations which affect members of the public – for example, any rules, guidelines, practices or precedents relating to those decisions or recommendations
- details of functions and powers to be available at commencement
- reports to be available from first annual report
- operational information to be published from commencement with quarterly and annual reviews to ensure that required information is available
Routinely requested information and disclosure log
- information which the ACNC routinely or regularly releases in response to FOI requests
- information which the ACNC routinely provides to the parliament in response to requests and orders
- disclosure log of documents released in response to FOI requests
- documents routinely released in response to FOI requests to be published as patterns of FOI requests emerge
- documents routinely supplied to parliament to be published as they are identified during quarterly or annual reviews
- where a document is required to be published on the disclosure log, within 10 working days after the document has been released in response to an FOI request
- although the ACNC is not responsible for specific policy proposals, we will provide details of arrangements for members of the public to comment generally or in relation to specific matters (for example, to provide comments on proposed Commissioner’s Interpretation Statements)
- details of officers who can be contacted about access to information or documents under the FOI Act
Timeframe: contact details to be available at commencement. Details of specific consultations to be made available as they arise.
Other information to be published (s 8(4))
The ACNC will seek to identify and publish other information that may assist our stakeholders to understand our work and engage with us. This may include:
- statistics relating to our work and our workforce
- information about our internal governance structures and our compliance with other Acts
- information about our compliance with website accessibility guidelines
- our corporate and strategic plans
- internal policies
- public submissions that we make and receive (unless authors request confidentiality)
- reports and research on the sector
- financial information relating to pay and grading structures, procurement processes and contracts
- memoranda of understanding.
This information will be published, where appropriate, as it becomes available. The quarterly reviews will monitor the progress of publication in this category.
IPS compliance review (s 8F)
The ACNC will conduct a limited review of the IPS each quarter for at least the first 12 months after commencement. It will then conduct a more comprehensive review each year after commencement to ensure that all appropriate information is included and that the processes for ensuring that information is complete, accurate and up-to-date are effective. At this time, the ACNC will seek feedback from stakeholders on the usability of the information architecture and whether the site provides the information that they need.
In addition, the ACNC will conduct a review in conjunction with the Information Commissioner within the five year review period.
The success of the IPS will also be gauged by public feedback and the volume of FOI requests for general information received.