OIA Res ponse Letter
9 October 2023
John Smith
By email only:
[FYI request #24094 email]
Dear Mr Smith
Official Information Act # 23.050: Official Information request - Salary band information
1.
We refer to your request received on 11 September 2023 for information about
Commerce Commission (Commission) salary bands, specifically salaries of defined
roles within our legal team.
2.
We also refer to our email dated 12 September 2023, our follow-up email on 22
September 2023 and your reply on 26 September 2023 to clarify that the relevant
time period for your request is for the 1 July 2022 – 30 June 2023 financial year.
3.
We have treated this as a request for information under the Official Information Act
1982 (OIA).
Our response
4.
Your request included asking for the following information:
4.1
The entry point salary (i.e., the lowest starting salary for the position) and the
highest available salary within the band for the following roles:
4.1.1 General Counsel;
4.1.2 Chief Legal Counsel;
4.1.3 Senior Legal Counsel;
4.1.4 Legal Counsel; and
4.1.5 Law Graduate.
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4.2
Should there not be an exact starting point for each salary band, if the
Commission can provide the lowest and highest salaries for each of the roles
above.
4.3
The average salary for each of the bands set out above and the total spent on
legal salaries for the end of the 2022 financial year. This was subsequently
clarified with you as the 1 July 2022 – 30 June 2023 financial year.
5.
We are unable to provide the information requested for the General Counsel role.
This is because we do not have a separate General Counsel role within the
Commission. The position of General Manager, Legal Services incorporates aspects of
a General Counsel role but also includes additional responsibilities above and beyond
those of a General Counsel. As there is only one holder of the General Manager,
Legal Services/General Counsel role within the Commission, we would likely decline
to provide salary information for that role on the basis of protecting the privacy of
that holder under s 9(2)(a) of the OIA.
6.
Set out below are the Commission’s salary bands for each of the roles listed at 4.1.2
to 4.1.5 above:
Position
Annual salary band for
Average annual salary for
2022/23 ($)
that role as at
30 June 2023 ($)
176,108 – 238,263
192,357
Chief Legal Counsel
122,923 – 166,307
148,500
Senior Legal Counsel
97,001 – 131,237
106,911
Legal Counsel
Law Graduate
62,908 / 69,025
62,908
Government Legal
The higher figure applies
Note: annualised salary.
Network (GLN)
once the secondee obtains
GLN rotations are of eight-
Graduate Programme
their practising certificate
month duration.
7.
The total spent on salaries for staff in these defined legal roles for the period 1 July
2022 – 30 June 2023 is $5,326,800.
Further information
8.
If you are not satisfied with the Commission's response to your OIA request, section
28(3) of the OIA provides you with the right to ask an Ombudsman to investigate and
review this response. However, we would welcome the opportunity to discuss any
concerns with you first.
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9.
Please note the Commission will not be publishing this response to your request on
its website. We have informed current Commission staff holding these roles of this
request and our response.
10.
Please do not hesitate to contact us at
[Commerce Commission request email] if you have any
questions about this response.
Yours sincerely
Chantellie Lye
OIA and Information Coordinator
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