Australian Government

Department of Education and Training

Dr Jen Tsen Kwok

National Policy and Research Officer
National Tertiary Education Union

By email: jtkwok@nteu.org.au
Dear Dr Kwok
1.

I refer to your correspondence received by the Department of Education and Training (the
department) on 30 May 2016, in which you revised your request for access under the Freedom of
Information Act 1982 (the FOI Act) to the following documents:
I/

a range o f documents previously identified by the Department as including:

two question time briefs,
six "hypothetical scenarios"
an assessment o f the impact of deregulation on regional higher education,
modelling relating to graduates in 2019, and
34 other spreadsheets.[the Rovere documents]"

That is, these are the documents that were in dispute before the AAT in Rovere and Secretary,
Department o f Education and Training [2015] AATA 462 (Rovere). By the time of the AAT decision,
only the documents exempted either in part or in full under section 47C of the FOI Act were in
dispute'.
2.

On 31 May 2016, the department advised you that the preliminary estimate of the charge for
processing your request was $846. The department received full payment of the charge on 2 June
2016.

3.

I am authorised to make decisions under the FOI Act and my decision regarding your request and
the reasons for my decision are set out below. The Schedule of Documents at Attachment A
summarises my decision as it applies to the documents covered by your request.

Documents
The documents within the scope of your request include:
4.
two question time briefs containing proposed talking points to allow the Minister to respond to
questions and other background information.
six "hypothetical scenarios" which were prepared for the advice of the Minister to inform him of
the potential impact of indexing HELP debts by the bond rate.

Paragraph 9 of the Rovere decision.

2
an assessment of the impact of deregulation on regional higher education. This document was
prepared for the Minister to assist with informing his thinking in advance of any further
discussions regarding higher education reform.
2019 graduate modelling. These documents were prepared to illustrate the effect of the
proposed indexation of HELP loans by the bond rate on average graduates, including where
graduates took time out of the workforce. These documents were developed to inform the
Minister's thinking, and in turn the Government's, on the impact of the proposed higher
education reforms.
34 other spreadsheets. These spreadsheets were created to estimate a variety of matters
including fees, average student contributions and the reduction in Commonwealth Grant
Scheme funding. These were prepared on a variety of assumptions informed by departmental
analysis and research. These spreadsheets were developed to advise the Minister, and in turn
the Government, about how the reforms may eventuate.

Decision on access to documents

5.
I am advised that the department has in its possession 7884 pages that fall within the scope of your
request.
6.

Having considered these documents, I have decided to refuse access to all 7884 pages.

7.

I have decided that certain pages contain material that is:

conditionally exempt under subsection 47C(1)(a) of the FOI Act because disclosure would
disclose matter in the nature of advice or recommendation recorded, or consultation or
deliberation that has taken place, in the course or, or for the purpose or, the deliberative
processes involved in the functions of the an agency;

conditionally exempt under paragraph 47J(1)(a) of the FOI Act because disclosure would, or
could reasonably be expected to, have a substantial adverse effect on Australia's economy by
giving a person (or a class of persons) an undue benefit or detriment, in relation to business
carried on by the person (or class) by providing premature knowledge of proposed or possible
action or inaction of a person or entity; and

pursuant to subsection 11A(5) of the FOI Act, is not required to be disclosed because
disclosure at this time would, on balance, be contrary to the public interest.

Evidence
8.
In reaching my decision, I took the following material into account:
your correspondence received on 30 May 2016 outlining the revised scope of your request;
documents falling within the scope of your request;
the FOI Act;
factors relevant to my assessment of whether or not disclosure of certain pages would be in
the public interest;
consultations with departmental officers about:
o the nature of the documents falling within the scope of your request; and
o the department's operating environment and functions; and
o the impact that release of the material is likely to have; and
the AAT's reasons for decision in Rovere; and
the guidelines issued by the Australian Information Commissioner under section 93A of the
FOI Act.

Reasons for Decision

Deliberative processes section 47C of the FO! Act:
9.

Section 47C of the FOI Act provides that:

General rule
(1) A document is conditionally exempt i f its disclosure under this Act would disclose matter
(deliberative matter) in the nature of, or relating to, opinion, advice or recommendation
obtained, prepared or recorded, or consultation or deliberation that has taken place, in the
course of, or f o r the purposes of, the deliberative processes involved in the functions of:
(a) an agency; or
(b) a Minister;

Exceptions
(2) Deliberative matter does not include either o f the following:
(a) operational information (see section 8A);
(b) purely factual material.
10.

I have decided that the documents within the scope of your request which as noted above, are the
same as those considered by the AAT in Rovere contain deliberative matter.

11.

I note that in Rovere, Senior Member Popple agreed that the documents contained 'deliberative
matters f o r the purposes o f section 47C(1). They contain material that relates to the opinions, advice
and recommendations about higher education policy. They contain material that relates to
deliberation and (to a lesser extent) consultations about that policy2'.

12.

I also note that subsection 47C(2) of the FO! Act provides that 'operational information' and 'purely
factual material' is not deliberative matter. The documents within the scope of your request contain
factual material. Section 22 of the FOI Act requires that an edited copy of the document to be
prepared only if it is reasonably practicable, having regard to the nature and extent of modification
and the resources available. I do not consider that it is reasonably practicable to produce an edited
copy of the documents as the purely factual material is so closely integrated within the document
that it forms part of the deliberative material. Senior Member Popple in Rovere also came to this
conclusion3.

13.

On this basis, I have decided that the documents referred to in the Schedule of Documents are
conditionally exempt under subsection 47C(1) of the FOI Act as the disclosure of these documents
would disclose deliberative matter.

Paragraph 28 of the Rovere decision.

Paragraph 32 of the Rovere decision

4
The economy section 47J of the FO! Act
14.

Section 47J of the FOI Act provides that:

(1) A document is conditionally exempt i f its disclosure under this Act would, or could be reasonably
expected to, have a substantial adverse effect on Australia's economy by:
(a) influencing a decision or action o f a person or entity; or
(b) giving a person (or a class o f persons) an undue benefit or detriment, in relation to business
carried on by the person (or class), by providing premature knowledge o f the proposed or
possible action or inaction of a person or entity.
(2) For the purposes o f subsection (1), a substantial adverse effect on Australia's economy includes
substantial adverse effect on:
(a) a particular sector o f the economy; or
(b) the economy o f a particular region of Australia.

15.

The FOI Guidelines provide that the words 'would or could reasonably be expected to' requires 'the
decision maker to assess the likelihood of the predicted forecast event, effect or damage occurring
after disclosure of a document' (paragraph 5.13).

16.

Additionally, the FOI Guidelines provide that the words 'substantial adverse effect' broadly means
'an adverse effect which is sufficiently serious or significant to cause concern to a properly
concerned reasonable person' (paragraph 5.17).

17.

I have decided that the release of the documents could reasonably be expected to have a
substantial adverse impact on the higher education sector of Australia's economy by influencing
pricing decisions of Australian universities in relation to any future deregulated courses.

18.

I also note that Senior Member Popple in Rovere stated that for similar reasons to those that led
him to conclude the documents were conditionally exempt under section 47C he would have also
found the documents to be conditionally exempt under section 47.14.

19.

On this basis, I have decided that the documents referred to in the Schedule of Documents are
conditionally exempt under subsection 47J(1) of the FOI Act.

Public interest
20.

Under subsection 11A(5) of the FO! Act, the department must give you access to conditionally
exempt documents unless in the circumstances it would be, on balance, contrary to the public
interest to do so.

21.

When weighing up the public interest factors for and against disclosure under subsection 11A(5) of
the FOI Act, I have taken into account the following factors in favour of disclosure and the extent to
which disclosure would:

promote the objects of the FOlAct;

inform debate on a matter of public importance;
promote effective oversight of public expenditure; and

Paragraph 66 of the Rovere decision.

5
allow a person to access his or her own personal information.

22.

In considering factors in favour of disclosure, I have placed considerable weight on the extent to
which disclosure may further inform public debate on the issue of higher education reforms in
Australia; and promote the objects of the FOl Act.

23.

I have also given weight on the extent to which release of the material may enhance the broader
principle of government accountability, namely:

24.

the public interest in the Australian public being informed of the rationale behind government
decision making in this context; and
the potential of the material to enhance public scrutiny of government decisions and processes.

However, I have determined in this instance, the above factors do not outweigh the harm that is
likely to result from the release of the material. In particular:

The disclosure of government modelling could be taken by the market as an endorsement by

the Australian Government of particular fee levels. This could in turn distort the operation of a
future partially deregulated market as universities may use fee modelling to inform their own
course fee decisions. I note that Senior Member Popple acknowledged this potential risk in
Rovere5. This would in turn undermine the key objective of market deregulation being pricing
competition amongst universities.

Whilst the Government is not pursuing full fee deregulation, the Government is nevertheless
still considering reforms to higher education, which may include the deregulation of fees in a
select number of courses, the identity of which is yet to be determined. The Government has
sought feedback on how such an initiative could be implemented. Until such time as higher
education reforms have been settled and are implemented, the disclosure of these documents
still has the potential to impact on the operation of a future higher education market. In
particular, these documents contain information relevant to courses that may be subject to
deregulated fees in the future. Releasing this information in advance of a finalised higher
education reform package could influence university decisions on which courses may be subject
to deregulated fees in the future and/or what level these fees may be.
I note that Senior Member Popple in Rovere agreed with this view. He stated "once fees have
been set, knowledge of the Government's views about what those fees might have been will
cause little or no damage"6. The department considers this statement as impliedly accepting
that knowledge of the Government's views about what the fees might be, prior to the setting of
those fees, would cause damage to a future partially deregulated higher education market.

the disclosure of the documents also has the potential to:

o

undermine the confidential relationship between the department and Minister and affect
the content of future briefings. In the recent case of Dreyfus and the Secretary o f the
Attorney General's Department [2015] AATA 962, the AAT recognised that the relationship
of trust and confidence was important to the content of deliberative material prepared for
the Minister.

Paragraph 45 of the Rovere decision.

Paragraph 47 of the Rovere decision.

6
o

prejudice the department's ability to continue to undertake this type of policy

development process in the future.

impede the effectiveness of the evaluation and decisionmaking process of the

department.

25.

In light of the above, I have decided that in the circumstances of this particular request, the public
interest in disclosing the information in the abovementioned documents is outweighed by the
public interest against disclosure; and that release of the material at this time would, on the
balance, be contrary to the public interest. Accordingly, I have decided not to release this
information to you.

26.

I have not taken into account any of the irrelevant factors set out in subsection 11B(4) of the FOI Act
in making this decision.

Rights of review
27.

I have set out your rights to seek a review of my decision at Attachment B.

28.

Should you have any enquiries concerning this matter, please do not hesitate to contact me on 02
6240 8775 or via email at foi@education.gov.au.

Yours sincerely

Genevieve Fiot
Senior Government Lawyer
Schools, Child Care and Corporate Legal Branch
People, Communication and Legal Group
20 June 2016

7
Attachment A
Schedule of Documents
Doc
1

Page
number
12

Date

Description of documents

Exemptions

30/04/14

Minister for Education QTB No: BRO3

Research Training Scheme (RTS) Student
Contributions

Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).

Question time brief for Minister on

permitting RTS student contributions,
2

34

06/05/14

Hypothetical HELP Repayment scenarios

Various HELP repayment scenarios
considering different incomes, interest rates
and student contributions.

56

07/05/14

Hypothetical HELP Repayment scenarios

With voluntary repayments
Various HELP repayment scenarios
considering different incomes, interest rates
and student contributions,

78

Undated

Hypothetical HELP Repayment scenarios

With voluntary repayments
Various HELP repayment scenarios
considering different incomes, interest rates
and student contributions,

910

07/05/14

Hypothetical HELP Repayment scenarios

Various HELP repayment scenarios
considering different incomes, interest rates
and student contributions.

1112

Undated

Hypothetical HELP Repayment scenarios

Various HELP repayment scenarios
considering different incomes, interest rates
and student contributions.

7*

1314

Undated

Hypothetical HELP Repayment scenarios

Various HELP repayment scenarios
considering different incomes, interest rates
and student contributions.

Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under

8
8

15

Undated

Impact o f deregulation on regional higher

education
Overview of possible consequences of fee
deregulation on regionally headquartered
universities,

16

Undated

2019 Graduate deregulated fees time off

f o r parenting
Modelling of scenarios for HELP repayments,
given different assumptions for fees, income,
time off work.

10

17

Undated

2019 Graduate deregulated fees

Modelling of scenarios for HELP repayments,
given different assumptions for fees, income,
time off work.

11

18 22

05/05/14

Excel spreadsheet Pages 73 77

Possible fees f o r cameos 050514
Spreadsheet used to calculate potential fees,
includes enrolment statistics by field and
course and fee modelling.

12

23 27

05/05/14

Excel spreadsheet Pages 102 106

Possible fees f o r cameos 050514 v2
Spreadsheet used to calculate potential fees,
includes enrolment statistics by field and
course and fee modelling,

13

28 45

12/05/14

Minister for Education QTB No: BWO2

Commission o f Audit Post Budget
Draft of question time brief for Minister on
implications of Commission of Audit.

14

46 137

Undated

Excel spreadsheet
Costing: Expansion o f DDS A1
grandfathered deregulation
Costing for one version of CGS reforms, with
new tiers and demanddriven expansion.

15

138 156

Undated

Excel spreadsheet
Costing: Expansion o f DDS A2

subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed

9
grandfathered deregulation
Costing for one version of CGS reforms, with
new tiers and demanddriven expansion.
16

157 263

Undated

Excel spreadsheet
Costing: Expansion o f DDS A3 sub
bachelor places
Costing for one version of CGS reforms, with
new tiers and demanddriven expansion,

17

264 272

Undated

Excel spreadsheet
Possible fees (all three options)
Spreadsheet used to calculate potential fees,
includes enrolment statistics by field and
course and fee modelling,

18

273 279

Undated

Excel spreadsheet
Ave fees cameos
Modelling of possible fees and repayment
scenarios.

19

280
286

Undated

Excel spreadsheet
Ave fees cameo v2
Modelling of possible fees and repayment
scenarios

20

287
302

06/05/14

Excel spreadsheet
Ave fees scenarios
Modelling of possible fees and repayment
scenarios.

21

303 316

07/05/14

Excel spreadsheet
Ave fees scenarios
Modelling of possible fees and repayment
scenarios.

22

317
329

Undated

Excel spreadsheet
Ave fees scenarios
Modelling of possible fees and repayment
scenarios.

under subsection 47C(1):

deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 471(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
.under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).

10
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
Modelling of possible fees and repayment
subsection 47J(1): the economy;
scenarios.
contrary to the public interest under
subsection 11A(5).
Excel spreadsheet
Exempt in full
Conditional
fees
voluntary
exemption claimed
scenarios
Ave
payments
w
under subsection 47C(1):
deliberative processes and
Modelling of possible fees and repayment
subsection 47J(1): the economy;
scenarios.
contrary to the public interest under
subsection 11A(5).
Excel spreadsheet
Exempt in full
Conditional exemption claimed
Average person query
under subsection 47C(1):
deliberative processes and
Modelling of possible fees and repayment
subsection 47J(1): the economy;
scenarios.
contrary to the public interest under
subsection 11A(5).
Excel spreadsheet
Exempt in full
Conditional
fees
exemption claimed
International
Ave
under subsection 47C(1):
deliberative processes and
International enrolments and average fee by
subsection 47J(1): the economy;
discipline in 2012.
contrary to the public interest under
subsection 11A(5).
Excel spreadsheet
Exempt in full
Change in funding by institution static fees Conditional exemption claimed
under subsection 47C(1):
Agreed finance subsidies 20% cut
deliberative processes and
subsection 47J(1): the economy;
Modelling of various CGS and student
contribution revenue scenarios on
contrary to the public interest under
subsection 11A(5).
institutions.

23

330 341

07/05/14

24

342 357

Undated

25

358 370

07/05/14

26

371

Undated

27

372375

Undated

28

376 377

Undated

Excel spreadsheet
Exempt in full
Change in funding by institution static fees Conditional exemption claimed
under subsection 47C(1):
Agreed finance subsidies
deliberative processes and
subsection 47J(1): the economy;
Modelling of various CGS and student
contribution revenue scenarios on
contrary to the public interest under
subsection 11A(5).
institutions.

29

378 379

Undated

Excel spreadsheet
Change in funding by institution, static fees
(20% cut)

30

380 389

30/04/14

Excel spreadsheet
Ave fees scenarios w voluntary payments

Modelling of various CGS and student

contribution revenue scenarios on
institutions.

Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).

Excel spreadsheet
T &L Summary o f Est 1 April 2014 (Apr 2014

Exempt in full
Conditional exemption claimed

11
Price) Budget 2014 Updated HELP data
Detailed budget estimates for higher
education teaching and learning,
31

390 398

24/04/14

Excel spreadsheet
Costing Al (5 tier grandfathered CPI)
24042014
CGS and HELP costings for one scenario with
new funding rates.

32

399 406

Undated

Excel spreadsheet
Estimated resourcing by group
Enrolment data, average international fees by
university, discipline group and alliance in
2012.

33

407 411

Undated

Excel spreadsheet
Grandfather by institution
Calculation of students commencing in 2005
who were still studying in later years.

34

412

Undated

Excel spreadsheet
Grandfathering calc (inc 2nd semester)
Calculation of students commencing in 2005
who were still studying in later years.

35

413

Undated

Excel spreadsheet
Individual Impact reduced
Modelling of various CGS and student
contribution revenue scenarios on
institutions,

36

414 415

Undated

Excel spreadsheet
KB Total Resourcing by Institution
2012 enrolment data and modelling of
various CGS and student contribution
revenue scenarios on institutions,

37

416 448

Undated

Excel spreadsheet
Modelling o f student debt
Modelling of various HELP repayment
scenarios.

under subsection 47C(1):

deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under

12

38

449
450

Undated

Excel spreadsheet
Fees
Average international fees in various
scenarios.

39

451

Undated

Excel spreadsheet
new Cwth student share
Calculation of overall
Commonwealth/student share according to
one scenario,

40

452
475

Undated

Excel spreadsheet
PM0 costings 2019
Modelling of various HELP repayment
scenarios.

41

476
1957

Undated

Excel spreadsheet
Final 2016 rates CGS & SCA
2012 detailed enrolment data and modelling
of CGS and student contribution revenue by
institution under one scenario,

42

1958
3439

Undated

Excel spreadsheet
Institutional funding Agreed finance
subsidies
2012 detailed enrolment data and modelling
of CGS and student contribution revenue by
institution under one scenario.

43

3440
4921

Undated

Excel spreadsheet
Institutional funding Agreed finance
subsidies 20% cut
2012 detailed enrolment data and modelling
of CGS and student contribution revenue by
institution under one scenario.

44

45

4922
6402

6403

Undated

Undated

Excel spreadsheet
Institutional Funding Loss o f CGS with static
fees (20%cut)

subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).
Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).

2012 detailed enrolment data and modelling

of CGS and student contribution revenue by
institution under one scenario.

Exempt in full
Conditional exemption claimed
under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).

Excel spreadsheet

Exempt in full

13
7884

Copy o f Ave fees cameos KB

2012 detailed enrolment data and modelling
of CGS and student contribution revenue by
institution under one scenario,

Conditional exemption claimed

under subsection 47C(1):
deliberative processes and
subsection 47J(1): the economy;
contrary to the public interest under
subsection 11A(5).

14
Attachment B
Your rights of review
Internal review
Section 54 of the Freedom o f Information Act 1982 (F01 Act) gives you the right to apply for an internal review
of this decision. The review will be conducted by a different person to the person who made the original
decision.
If you wish to seek an internal review of the decision you must apply for the review, in writing, within 30 days
of receipt of this letter.
No particular format is required but it will help the new decisionmaker if you state clearly why you consider
the decision should be reviewed. Please send your application by post or email as follows:
Post:

The FOI Coordinator

Schools, Child Care and Corporate Legal Branch
People, Communication and Legal Group
Department o f Education and Training
Location Code: C50MA10
GPO BOX 9880
CANBERRA ACT 2601

Email:

foi@education.gov.au

External Review by the Australian Information Commissioner

Section 54L of the FOI Act gives you the right to apply directly to the Australian Information Commissioner (AIC)
to seek a review of this decision.
If you wish to have the decision reviewed by the AIC you must apply for the review, in writing or by using the
online merits review form available on the AIC's website at www.oaic.gov.au, within 60 days of receipt of this
letter. To assist the AIC your application should include a copy of this decision and your contact details. You
should also clearly set out why you are objecting to the decision.
You can also complain to the AIC about how an agency handled an FOI request, or other actions the agency
took under the FOI Act.
Applications
Online:
Post:
Fax:
Email:
In person:

for review or complaint can be lodged in one of the following ways:

www.oaic.gov.au
GPO Box 5218 Sydney NSW 2001
+61 2 9284 9666
enquiries@oaic.gov.au
Level 3, 175 Pitt Street
Sydney, NSW 2000

For general enquiries, please call 1300 363 992 or +61 2 9284 9749 for international.
The Commonwealth Ombudsman
You can complain to the Commonwealth Ombudsman concerning action taken by an agency in the exercise of
powers or the performance of functions under the FOI Act.
A complaint to the Commonwealth Ombudsman may be made orally or in writing. The Ombudsman may be
contacted for the cost of a local call from anywhere in Australia on telephone 1300 362 072.