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Effective Date: 26 Jan 2025
Canberra Commerce Group Pty Ltd, as a private company, is committed to fostering transparency, accountability, and openness in its operations. While we are not subject to the Australian federal government’s Freedom of Information (FOI) Act, we believe in the importance of being responsive to information requests from stakeholders. This policy establishes a framework for handling requests for information and demonstrates our commitment to openness, provided that the requested information does not conflict with business interests, confidentiality agreements, or legal obligations.
1. Purpose and Scope
The purpose of this Freedom of Information Policy is to provide a framework for handling requests for information within the company. While we are not bound by FOI laws, we are dedicated to maintaining transparency and responding to information requests in a manner that aligns with our values of openness, fairness, and responsibility. This policy applies to all requests made by individuals, organisations, or other parties seeking access to the company’s records or information.
2. Commitment to Transparency
Canberra Commerce Group Pty Ltd is committed to providing public access to information where appropriate and within legal limits. Our goal is to be as transparent as possible while protecting the confidentiality of sensitive business matters, including proprietary information, personal data, and other legally protected content. We will disclose information where it is in the public interest or in accordance with relevant company policies.
3. Types of Information Available
The following categories of information are generally available to the public or upon request:
- Public Reports and Publications: Annual financial reports, public statements, and other corporate publications.
- Corporate Policies and Procedures: Documents that pertain to the general operation and management of the company.
- Employee and Organisational Information: Details of organisational structure, staffing policies, and non-sensitive employee-related information.
- Non-sensitive Contracts and Agreements: Publicly available contracts or memorandums of understanding (MOUs).
Requests for information beyond these categories will be considered on a case-by-case basis, with careful consideration of any confidentiality, legal, or commercial sensitivities.
4. Requests for Information
Any individual or organisation wishing to request information from Canberra Commerce Group Pty Ltd should submit a formal written request. The request should specify the information or records being sought, with sufficient detail to assist in locating the documents. Requests can be made by messaging us.
The company will acknowledge receipt of the request and provide an estimated timeline for the response. We aim to respond to all requests promptly and will ensure that we comply with our internal procedures.
5. Response Times
Canberra Commerce Group Pty Ltd will endeavour to respond to requests within a reasonable timeframe. While not subject to statutory requirements of the FOI Act, we aim to provide a response within 30 days of receiving the request. If additional time is required due to the complexity or volume of the request, the company will inform the requestor of any delays and provide an updated timeline.
6. Exemptions and Restrictions
Certain information may not be disclosed due to legal, commercial, or security considerations. Information that is exempt from disclosure may include, but is not limited to:
- Personal Information: Information related to an individual’s privacy, including sensitive personal data, unless the individual has provided consent for disclosure.
- Commercially Sensitive Information: Trade secrets, proprietary business information, or any data that could harm the company’s competitive position or violate confidentiality agreements.
- Legal Privilege: Documents subject to legal professional privilege or ongoing legal proceedings.
- Confidential Contracts or Agreements: Certain business agreements or contracts that contain confidential terms.
In cases where information is withheld, we will provide a clear explanation for the decision and may offer alternative solutions, such as redacted versions of documents or summaries of the information.
7. Fees and Charges
Canberra Commerce Group Pty Ltd may charge fees for processing information requests to cover the cost of retrieving, copying, and preparing documents. The fee schedule will be communicated to the requester prior to processing. In certain circumstances, fees may be waived or reduced, such as when the information requested serves a public interest or when the requester demonstrates financial hardship.
8. Review of Decisions
If a requester is dissatisfied with the outcome of their information request, they may seek an internal review of the decision. A senior officer within the company will conduct this review to ensure the decision was made in accordance with company policies and practices. Should the requester remain dissatisfied following the internal review, they may consider seeking independent advice or escalating the matter as appropriate.
9. Staff Responsibilities
All employees at Canberra Commerce Group Pty Ltd are expected to cooperate with the Freedom of Information Officer or designated staff responsible for handling information requests. Employees must ensure that requested information is accurate, provided in a timely manner, and complies with relevant confidentiality and legal standards.
10. Continuous Improvement
Canberra Commerce Group Pty Ltd is committed to improving its processes for handling information requests. Feedback from requesters will be used to refine and enhance our approach to information transparency and accessibility. The company will review and update this policy regularly to ensure it reflects best practices and any changes to relevant laws or regulations.
Conclusion
Canberra Commerce Group Pty Ltd remains dedicated to transparency, ensuring that we provide access to information wherever possible and appropriate. While not bound by the FOI Act, we encourage the public to make requests for information and will respond in a manner that reflects our commitment to openness, fairness, and accountability. By adhering to this policy, we aim to maintain the trust and confidence of our stakeholders and the broader community.
