The National Disability Insurance Agency (NDIA) 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 IPS Agency Plan describes how the NDIA proposes to do this, as required by section 8(1) of the FOI Act.
Note: The information published by the NDIA under the IPS is referred to in this IPS Agency Plan as the NDIA’s ‘IPS entry’.
The NDIA is an independent statutory agency established by the National Disability Insurance Scheme Act 2013 (NDIS Act). The NDIA’s core role is to implement the National Disability Insurance Scheme (NDIS), which will support a better life for hundreds of thousands of Australians with a significant and permanent disability and their families and carers.
The NDIA is headed by the Chief Executive Officer and governed by its Board. The Board of the NDIA is advised by the Independent Advisory Council. The NDIS is a national scheme which involves the states and territories.
This IPS Agency Plan describes how the NDIA proposes to implement and administer its IPS entry in respect of its own information holdings, by addressing:
- establishing and administering the NDIA’s IPS entry
- information architecture and accessibility of information
- information required to be published
- other (optional) information to be published
- IPS compliance review.
The NDIA will continue to build and foster a culture within the NDIA, in which appropriate proactive disclosure of its information holdings is embraced, leading to successful implementation and administration of its IPS entry. This is in recognition that public sector information is a national resource managed for public purposes.
The purpose of this IPS Agency Plan is to:
- assist the NDIA in planning, developing, and implementing its IPS entry
- facilitate continuing public consultation about its IPS entry
- show what information the NDIA proposes to publish, how and to whom the information will be published and how the NDIA will otherwise comply with the IPS requirements (this fulfils the requirements of section 8(1) of the FOI Act).
The NDIA’s objectives under this IPS Agency Plan are to outline appropriate mechanisms and procedures to:
- manage the NDIA’s IPS entry
- proactively identify and publish all information required to be published (section 8(2) of the FOI Act), including this plan
- proactively identify and publish any other (optional) information to be published (section 8(4) of the FOI Act)
- review and ensure on a regular basis that information published as part of the NDIA’s IPS entry is accurate, up to date and complete (section 8B of the FOI Act)
- ensure, as far as practicable, that information published as part of the NDIA’s IPS entry 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 NDIA’s IPS entry by reference to community feedback and compliance review processes
- adopt, as fair as practicable, best practice initiatives in implementing and administering the NDIA’s IPS entry.
Establishing and administering the NDIA’s IPS entry
Corporate Counsel, Legal Services Branch is designated within the NDIA as the senior officer responsible for leading the NDIA's compliance with the IPS (the NDIA IPS Leader).
(a) Establishing the NDIA’s IPS entry as a new agency
The NDIA IPS Leader is supported by the IPS Project Team to establish the NDIA's IPS entry as soon as practicable following the establishment of the NDIA.
The IPS Project Team comprises:
- General Manager, Governance and Public Affairs Division
- Corporate Counsel, Legal Services Branch
- Special Counsel, Public Law Section, Legal Services Branch
- An FOI representative from the NDIA’s Legal Services Branch
- Staff with IT expertise to publish the relevant documents.
The IPS Project Team will work with other key areas of the NDIA and establish other ad hoc working groups as required.
The IPS Project Team prepared and implemented an IPS project plan to develop and launch the NDIA’s IPS entry.
The IPS Project Team has developed – and is continuing to develop – an IPS information register. The IPS information register records details of documents and information required or permitted to be published under sections 8(2) and 8(4) of the FOI Act.
To prepare the IPS information register, Legal Services Branch, in consultation with relevant NDIA areas, has:
- reviewed and audited documents published on the NDIA website and identified the documents that will form part of the NDIA' s IPS entry
- created a list of potential IPS documents (including those not already published on the NDIA website)
- established systems and procedures to review the IPS entry to ensure that it is kept accurate, up to date and complete.
The information register will also assist with facilitating conformance with WCAG 2.0 (see Objectives on page 2), as it:
- describes the format of all IPS documents currently published on the NDIA websites
- contains information on WCAG 2.0 compliance and alternative formats of IPS documents
- identifies any other issues that may affect publication of an IPS document on the NDIA website.
(b) Administering the NDIA' s IPS entry going forward
The NDIA's ongoing compliance with the IPS will be coordinated by the NDIA IPS Leader and IPS Project Team.
The NDIA will consider its information asset management framework in light of its IPS entry. This includes how the NDIA’s IPS entry interacts with the NDIA’s record management plans and policies.
Relevant areas of the NDIA will be responsible as required, for day to day tasks associated with complying with the IPS.
As part of managing the ongoing administration of the NDIA's IPS entry, the IPS Project Team will consider publishing a ‘Guide to publishing information under the IPS for NDIA staff’. The guide may:
- 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 other information to be published as part of the NDIA' s IPS entry
- describe the process for publishing information.
The NDIA will lead better practice initiatives to engage with the community about the NDIA's IPS entry to the IPS. These include:
- making IPS documents as easily discoverable, understandable and machine-readable as possible
- inviting and encouraging members of the public to contact the NDIA to provide comments on the NDIA' s IPS entry, particularly where documents are found not to be discoverable, understandable or machine-readable.
The NDIA will also arrange, where possible, for NDIA IPS documents, which are not available on the NDIA website, to be made available upon request.
The NDIA may charge a person for accessing any NDIA IPS document which is impracticable to publish online:
- at the lowest reasonable cost
- to reimburse specific reproduction costs or other specific incidental costs (section 8D(4) of the FOI Act).
These charges will be consistent with charges in the Freedom of information (Charges) Regulations 1982 (external) (which generally apply to access requests under Part III of the FOI Act).
IPS information architecture and accessibility of information
IPS Information architecture
The IPS entry will be published on the NDIA website and will include the following headings and sub-headings:
- Information required to be published under the IPS (section 8(2) of the FOI Act)
- IPS Agency Plan (section 8(2)(a)
- Who we are (sections 8(2)(b) and 8(2)(d))
- What we do (sections 8(2)(c) and 8(2)(j))
- Our reports and responses to Parliament (sections 8(2)(e) and 8(2)(h))
- Routinely requested information and FOI disclosure log (sections 8(2)(g) and 11C)
- Consultation arrangements (section 8(2)(f))
- Contact us about FOI or IPS (section 8(2)(i))
- Other (optional) information (section 8(4) of the FOI Act)
Accessibility of information
The NDIA will ensure, to the extent possible, that all IPS documents available on its website conform to WCAG 2.0.
The majority of documents listed on the IPS section of the NDIA website will be available in 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.
To ensure that the NDIA IPS entry (including individual IPS documents) is easily discoverable, understandable and machine-readable, the NDIA will:
- consider publishing an IPS ICON on the homepage of its website, which links 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
- provide a search function for its website
- establish a feedback channel for seeking and responding to community feedback about whether the NDIA' s IPS entry (and individual IPS documents) is easily discoverable, understandable and machine-readable.
The NDIA will, so far as possible, make its IPS information holdings available for reuse on open licensing terms in accordance with Australian Government policy.
The NDIA will continue to engage in public consultation about its IPS Agency Plan and IPS entry through the feedback mechanism on the IPS section of its website. Any comments on the NDIA’s IPS entry are welcomed by emailing FOI@ndis.gov.au.
Information required to be published under the IPS (section 8(2) of the FOI Act)
IPS Agency Plan
- A link will be provided to this IPS Agency Plan.
Who we are
- This will include general information about the NDIA an organisational chart (when it has been developed and finalised) and information about statutory appointments.
- For statutory appointments, the NDIA will publish the name of the person appointed, the length or term of appointment, the position to which the person is appointed and the provision of the NDIS Act under which the person is appointed.
What we do
- This will outline the core functions and decision-making powers of the NDIA. It will also mention the NDIA’s incidental functions and decision-making powers (such as freedom of information, financial, and personnel decision-making).
- The NDIA will also publish operational information relating to those functions and powers.
Our reports and responses to Parliament
- The NDIA will publish its first annual report in 2014. A link will be added once that report has been published.
- A link to the Department of Social Services’ 2012/2013 annual report will be provided. This annual report contains information relevant to the NDIA.
- Links to other information provided to Parliament (such as information provided under Senate orders and through other processes) will also be published as required.
Routinely requested information and FOI disclosure log
- This will include information on documents to which the NDIA routinely gives access in response to FOI requests (as this information becomes available) and information published under section 11C of the FOI Act.
- This will include information about how and to whom a comment may be submitted by members of the public, where the NDIA undertakes public consultation on a specific policy proposal.
Contact us about FOI or IPS
- This will include the contact details of FOI contact officers, who can be contacted about access to the NDIA' s information or documents under the FOI Act. The NDIA has established generic officer positions and an email address for this purpose that will not change with staff movements.
Other (optional) information
The NDIA will continue to proactively consider what other (optional) information it may publish in its IPS entry under section 8(4) of the FOI Act.
This information will be published under appropriate sub-headings on the NDIA’s IPS entry.
IPS compliance review
The NDIA will review and revise this IPS Agency Plan at least annually.
The NDIA 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). The NDIA will give consideration to the most appropriate way for its IPS entry to be reviewed in light of its oversight role.
The NDIA will adopt the following criteria for measuring its performance:
(a) IPS Agency Plan - has the NDIA published a comprehensive plan for its IPS compliance?
(b) Governance and administration - does the NDIA have appropriate governance mechanisms in place to meet its IPS obligations, including a sound information management framework?
(c) IPS document holdings - has the NDIA reviewed its document holdings to decide what information must be published under section 8(2) and information that can be published under section 8(4)? Is the NDIA's IPS entry accurate, up-to-date and complete?
(d) IPS information architecture - does the NDIA have a publication framework in place and has it taken the necessary steps to ensure that information in its IPS entry is easily discoverable and accessible?
(e) Agency compliance review - does the NDIA have appropriate processes, systems and resources in place to monitor and review its IPS compliance and to make necessary improvements to its IPS implementation?