Table 2 Document Pack.pdf

1
From:
Gareth Derby
To:
Moore-Jones, Anna
Cc:
Yu-Lina George; Connell, Elisha; Tom Nelson
Subject:
RE: OIA exceptions in legislation
Date:
Tuesday, 21 November 2023 2:17:17 pm
Attachments:
image001.jpg
image002.jpg
image003.jpg
Hi Anna
ACT 1982
Apologies for not getting in touch sooner, I only got back from holiday last week and had a lot to catch up on.
I’d be very happy to meet with you sometime next week, and have time on most days except Monday. I d likely be
accompanied by Tom Nelson of my team, and have copied him in accordingly. If you can possibly send through a few
times/dates and we can check our joint availability, perhaps?
I recall that the Chief Ombudsman expressly considered Commitment 7 and the matter of OIA exemptions in his
submission on the draft Fourth National Action Plan, which was published by PSC here
https://ogp.org.nz/assets/New-Zealand-Plan/Fourth-National-Action-Plan/Part-1-Collation-of-public-submissions-
received-for-New-Zealands-Fourth-National-Action-Plan-draft-8-March-2023.pdf See pages 46 through 47 for the
relevant part of the Chief Ombudsman’s submission. Hopefully that’s a useful starting point for discussion.
Otherwise, very happy to meet with you to work through the various examples, etc.
Kind regards
INFORMATION
Gareth Derby
Principal Advisor Strategic Advice
Office of the Ombudsman | Tari o te Kaitiaki Mana Tangata
DDI s9(2)(a)
| Phone s9(2)(a)
| Fax s9(2)(a)
Email [email address] | www.ombudsman.parliament.nz
PO Box 10152, Level 7, SolNet House, 70 The Terrace, Wellington
IMPORTANT: The information contained in this email may be confidential or legally privileged. It is intended solely
for the recipient or recipients named in this message. Please note that if you are not the intended recipient you are
not authorised to use, copy or distribute the email or any information contained in it. If you have received this email
in error, please advise the sender immediately and destroy the original message and any attachments.
From: Moore-Jones, Anna <[email address]>
Sent: Monday, 20 November 2023 3:10 pm
To: Gareth Derby <[email address]>
Cc: Yu-Lina George <[email address]>; Connell, Elisha <[email address]>
Subject: RE: OIA exceptions in legislation
Kia ora Gareth,
I hope that you are well. I am just following up on the below in relation to Commitment 7 of the Fourth Open
Government Action Plan which looks at strengthening the scrutiny of legislative clauses that override the disclosure
requirements of the OIA.
We would be interested in speaking with you at the end of this week or sometime next week, if possible?
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We have recently completed some research on laws that include OIA exemptions, particularly to examine the
rationale for exemptions being added and also to test how easy it is to find this information. It would be helpful to
get your thoughts on what we’ve found through this work so far and to learn more about the guidance provided by
your office around this topic.

We look forward to hearing from you.

Ngā mihi nui,
ACT 1982
Anna

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Electoral and Constitutional Team | Policy Group
DDI s9(2)(a)  | Ext s9(2)(a)

Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz  |  electoralreview.govt.nz

From: Moore-Jones, Anna
INFORMATION
Sent: Wednesday, 8 November 2023 1:29 pm
To: 'Gareth Derby' <[email address]>
Cc: Connell, Elisha <[email address]>
Subject: RE: OIA exceptions in legislation

Kia ora Gareth,

I hope that you are well. I just wanted to follow up on my colleague Elisha’s email below.

We would be interested in speaking with you when convenient over the next few weeks. We would find it helpful to
get your thoughts on what we’ve found through our research on OIA exemptions so far and to learn more about the
guidance provided by your office around this topic.

Is there a time/day in the next few weeks that might be most suitable for you?

We look forward to hearing from you

Ngā mihi nui,
Anna

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Electoral and Constitutional Team | Policy Group
DDI s9(2)(a)  | Ext s9(2)(a)

Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz  |  electoralreview.govt.nz

From: Connell, Elisha <[email address]>
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Sent: Wednesday, 1 November 2023 1:41 pm
To: Gareth Derby <[email address]>
Cc: Moore-Jones, Anna <[email address]>
Subject: RE: OIA exceptions in legislation

Kia ora Gareth,

Thanks for meeting with Adam Carter and I back in June to discuss our work on Commitment 7 of the Fourth Open
ACT 1982
Government Action Plan which looks at strengthening the scrutiny of legislative clauses that override the disclosure
requirements of the OIA.

I wanted to circle back to see if you might have time to meet in the coming few weeks to discuss our progress with
this work and potential next steps?

Since we met, Adam Carter has left the Ministry and Anna Moore-Jones has joined our team as an Advisor and will
be taking over this work. Anna has recently been on secondment at the Electoral Commission, but will be returning
next week and we would both be pleased to meet with you at a convenient time.

We have recently completed some research on laws that include OIA exemptions  particularly to examine the
rationale for exemptions being added and also to test how easy it is to find th s information. It would be helpful to
get your thoughts on what we’ve found through this work so far and to lea n more about the guidance provided by
your office around this topic.

We look forward to being in touch.
INFORMATION

Ngā mihi,
Elisha


Elisha Connell (she/her)
Senior Policy Advisor | Electoral and Constitutional
Civ l and Constitutional Unit | Policy Group
Ministry of Justice | Tāhū o te Ture
P s9(2)(a)
| Ext s9(2)(a)
[email address] | justice.govt.nz

From: Gareth Derby <[email address]>
Sent: Wednesday, 14 June 2023 10:07 am
To: Carter, Adam <[email address]>
Cc: Connell, Elisha <[email address]>; Yu-Lina George <[email address]>
Subject: RE: OIA exceptions in legislation

Hi Adam

Thank you for explaining the next steps and the matters in respect of which you anticipate wanting the
Ombudsman’s views. I’d be very happy to chat next week about the degree of the Ombudsman’s involvement.

While I note your wish not to leap into the substance too quickly, it nevertheless might help if I point out two
additional resources that seem to sit neatly alongside the publicly available material you’ve already identified as
relevant:

Chief Ombudsman’s submission to the Ministry on its consultation on whether to conduct an OIA review. The
Chief Ombudsman made some relevant comments  on pages 6-8.
Guidance on when to engage the Ombudsman in law reform proposals, in particular the section on official
information jurisdictions (paragraphs 8-10).

It hopefully adds some context on what kind of matters the Ombudsman considers might trigger the expectation to
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consult in line with the LDAC guidelines and Cabinet Manual. Very happy to supplement this in further discussions,
of course!

Kind regards
Gareth Derby
Principal Advisor Strategic Advice
Office of the Ombudsman | Tari o te Kaitiaki Mana Tangata
ACT 1982

DDI s9(2)(a)
| Phone s9(2)(a)
| Fax s9(2)(a)
Email [email address] | www.ombudsman.parliament.nz
PO Box 10152, Level 7, SolNet House, 70 The Terrace, Wellington

IMPORTANT: The information contained in this email may be confidential or legally p ivileged. It is intended solely
for the recipient or recipients named in this message. Please note that if you are not the intended recipient you are
not authorised to use, copy or distribute the email or any information contained in  t. If you have received this email
in error, please advise the sender immediately and destroy the original message and any attachments.

INFORMATION

From: Carter, Adam <[email address]>
Sent: Wednesday, 14 June 2023 9:39 am
To: Gareth Derby <[email address]>
Cc: Connell, Elisha <[email address]>
Subject: RE: OIA exceptions in legislation

Kia ora Gareth,

As mentioned below, we have begun work on commitment 7 of the OGP action plan.  Commitment 7 is about
strengthening scrutiny of Official Information Act exemptions in legislation.

We have done some initial work to identify current scrutiny mechanisms and guidance. These include:
·    the obligation to consult the Ombudsman in the Cabinet manual on proposals impacting access to official
information
·    the LEG paper template
·    LDAC guidelines
We have also reviewed commentary on the use of secrecy clauses such as in Law Commission report from 2012 on
the OIA.

However, we are still very much in the planning stages and keen to get a better understanding from the
Ombudsman about:
·    Any reflections in providing feedback to agencies on proposals which limit disclosure in legislation outside
the OIA.
·    Reflections on the effectiveness of the current prompts (such as the LEG paper template reminding
agencies to contact the ombuds where a proposal impacts the OIA)
·    Any other resources such as guidance that the Ombudsman provides to agencies.
·    Some technical questions such as what kinds of provisions meet the s 18(c)(i) and 52(3) tests.

Perhaps before we get into these questions you would be available for an initial discussion next week about how the
Ombudsman would like to be involved in this project?

Ngā mihi

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ACT 1982
INFORMATION
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Open Government Partnership Fourth National Action Plan. Commitment number 7 is about strengthening scrutiny
of Official Information Act exemptions in Legislation.
At this stage we were hoping just to have a chat about how the Ombudsman would like to be involved in this
project.
Would be great if you could direct me to the relevant team/person.
ACT 1982
Ngā mihi
Adam Carter
Policy Advisor | Electoral and Constitutional Policy
Civil and Constitutional | Policy Group
Ministry of Justice | Tāhū o te Ture
P s9(2)(a)
| Ext s9(2)(a)
National Office | Justice Centre | 19 Aitken Street
DX Box SX10088 | Wellington
[email address] | justice.govt.nz
IMPORTANT: The information contained in this email may be confidential or legally privileged. It is intended solely
for the recipient or recipients named in this message. Please note that if you are not the intended recipient you are
INFORMATION
not authorised to use, copy or distribute the email or any information contained in it. If you have received this email
in error, please advise the sender immediately and destroy the original message and any attachments.
IMPORTANT: The information contained in this email may be confidential or legally privileged. It is intended solely
for the recipient or recipients named in this message. Please note that if you are not the intended recipient you are
not authorised to use, copy or distribute the email or any information contained in it. If you have received this email
in error, please advise the sender immediately and destroy the original message and any attachments.
IMPORTANT: The information contained in this email may be confidential or legally privileged. It is
intended solely for the recipient or recipients named in this message. Please note that if you are not the
intended recipient you are not authorised to use, copy or distribute the email or any information contained in
it. If you have received this email in error, please advise the sender immediately and destroy the original
message and any attachments.
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ACT 1982
INFORMATION
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Sent: Tuesday, January 23, 2024 5:27 PM
To: s9(2)(a)
@parliament.govt.nz>; s9(2)(a)
s9(2)(a)
@Parliament.govt.nz>
Cc: Connell, Elisha <[email address]>; Marques, Erika <[email address]>;
Kerkin, Sarah <[email address]>
Subject: RE: A query - research around exemptions to the OIA

ACT 1982
Kia ora koutou,

I hope that everyone has had a lovely start to the year.

As Sarah explained below, we have been doing some research on exemptions to the Official Information
Act 1982. This is for a commitment that the Ministry is leading within the Fourth National Action Plan
under the Open Government Partnership.

I attach a draft paper summarising this project and the research we have carried out.
We have also been talking to several different agencies to consider how different mechanisms could be
improved to assist with public transparency of the rationale for OIA exemptions in legislation.

The start of the year has passed quickly, and busily, so I understand we have little time now before s9(2)(a)
leaves. Would you both have time to meet with us sometime over the next week or so? For example,
maybe a time Thursday afternoon or Friday this week.
INFORMATION
We can try to be flexible to when would be most suitable for you to chat briefly.

I look forward to hearing from you.

Ngā mihi nui,
Anna

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Electoral and Constitutional Team | Policy Group

Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address] nz
Pae tukutuku: justice.govt.nz | electoralreview.govt.nz

From: Kerkin, Sarah <[email address]>
Sent: Tuesday, 12 December 2023 10:13 am
To: s9(2)(a)
@Parliament.govt.nz>; s9(2)(a)
s9(2)(a)
@parliament.govt.nz>
Cc: Moore-Jones, Anna <[email address]>; Connell, Elisha
<[email address]>
Subject: RE: A query

Thank you both. Mid to late January would work well for me. I’m taking off at the end of the week, and am
away for a month (hurrah!)

The issue the team has been working on is clauses excluding the application of part or all of the Official
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ACT 1982
INFORMATION
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s9(2)(a)
From: Kerkin, Sarah <[email address]>
Sent: Monday, 11 December 2023 12:10 PM
To: s9(2)(a)
@parliament.govt.nz>
Subject: A query
ACT 1982
Kia ora s9(2)(a)
Long time no hear – hope life in the standing orders committee is treating you well.
Some colleagues here at Justice have been doing some work that may align quite neatly with the advice
on bills that select committee clerks put together for the committees when a bill is first referred to them. I
thought it might be helpful if we brought this to someone’s attention and was hoping you could point me
in the right direction.
Ngā mihi
Sarah
INFORMATION
Sarah Kerkin (Dr/she/her)
Kaitohutohu Matua | Chief Advisor
Office of the Deputy Secretary Policy
Te Rōpū Kaupapa Here | Policy Group
DDI: s9(2)(a)
| Ext s9(2)(a) | Mob s9(2)(a)
www.justice.govt.nz
Please note I don’t work Wednesdays
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The cont nt of this email, including any attachment, is intended for the named recipient only and is not necessarily the official view or communication of the
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3
Meeting with Ombudsman 13/12/2023
1pm-1.40pm
Attendees: Gareth Derby (Principal Advisor, Ombudsman), Anna Moore-Jones (Advisor, E+C), Elisha
Connell (Senior Adviser, E+C)
ACT 1982
Meeting purpose – for MOJ to report back on work so far and to better understand the guidance
Ombudsman provide and to explore further how they could support this work.
Initial outline of issue
Gareth was interested in our terms of reference for this work.
Anna shared details about the scope of the commitment and work so far and provided an update on
the research that has been completed to date for the OGP commitment Also noted details about the
disclosure statement template and guidance and how this doesn’t appear to be a viable way to
strengthen guidance.
Advised that we’l be putting together an options paper and talking with civil society in the New Year.
Select Commitee
INFORMATION
Gareth also enquired if there would also be potential for us to consult with select committees. He
noted that sometimes things had arisen during the select committee stage around OIA exemptions.
Gareth noted that Select Commitee stage is also a typical place for OIA exemptions to arise and there
is little scrutiny of it from that stage. Pondered what potential there is to provide better
guidance/scrutiny here. Anna advised this hadn’t been part of our next steps
Gareth also discussed that in some cases OIA exemptions are created accidentally and are not
considered at all by the agencies. Also sometimes it is simply that old legislation is modernised
without change or by adopting a similar legacy Act so problem of OIa exemption remains. Sometimes
agencies may accidentally carve out the OIA.
Agencies that are looking to update legislation sometimes just wholesale adopt previous regimes
that had OIA carve outs. E.g. civil aviation bill s9(2)(g)(i)
. Gareth
to look for further examples and share.
Ombudsman
Gareth noted that many times the Ombudsman is only notified at a late stage in the process.
Guidance – Gareth to look at guidance offered by Ombudsman and will share.
Guidance around OIA is front and centre for Ombudsman. They see the issue of OIA carve
outs/exemptions as an important issue. Ombudsman see that curtailing OIA wouldn’t be justified
without good reason.
Gareth also noted that the Chief Ombudsman (and the Solicitor-General) have made strong
comments on the inappropriateness of curtailing the OIA especially during a national emergency as
was proposed during peak COVID era. Ombudsman has a continued interest in the issue of OIA
exemptions (especial y as improving this issue may reduce workload for Ombudsman and
prevent/mitigate issues from arising). They are keen to be kept informed. They would like to know
1
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about the research and see if they were consulted on the legislation. May also be helpful for us to
document whether the ombudsman was consulted on these Acts.
OIA exemption should only be for a clear demonstrable need. Discussed links to BORA and
constitution.
ACT 1982
Discussed the difference between OPC as an independent crown entity with strong consultation
requirements vs the Ombudsman as an Officer of Parlaiment with no legislative requirement to
consult. This was seen as one reason that OPC has clear provision to indicate where issues are not
appropriate and provide advice where the Ombudsman may not necessarily have the same pathway
as must maintain independence as a different arm of government.
Vetting things with the Privacy Commissioner is an established process, why doesn’t this same
process exist for the OIA re. the Ombudsman? What is the justification for the Privacy Commissioner
being consulted – because there’s a statutory requirement. The Ombudsman role has become a bit
blurry. Suggested there could be potential for gov agencies to consult Ombudsman more
regularly/systematically.
INFORMATION
Next steps:
• Gareth to share details about examples of legislation where agencies have adopted previous
legislative regimes with OIA carve outs and Ombudsman has provided advice.
• Gareth to share guidance offered by Ombudsman on OIA/OIA exemptions.
• MOJ to provide research so can compare and add additional knowledge as to whether
Ombudsman was consulted on the exemption and the context to that conversation and
eventual decision on the exemption
• Ombudsman keen to remain informed of this work and provide assistance/support where
useful.
2
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ACT 1982
INFORMATION
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To: Jenny Vickers [DPMC] <[email address]>
Cc: Connell, Elisha <[email address]>; Diana Hawker [DPMC]
<[email address]>
Subject: RE: Assistance with CabGuide connection - Open Government Partnership NAP4

Kia ora koutou,

ACT 1982
Thank you - I appreciate you getting back to me.

Yes, we would be interested in speaking with you, Jenny, sometime over the coming few weeks,
as suits you, to consider a potential update to the CabGuide.
We are working through various mechanisms to try to improve the references that are made to
the Official Information Act 1982. We have spoken with Treasury about disclosure statements
and will also soon be talking to LDAC.

Would you be available to chat on the morning of either Wednesday or Thursday next week? We
have flexibility, however, so please let me know if another day/time suits better.

Ngā mihi nui,
Anna
INFORMATION

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Electoral and Constitutional Team | Policy Group
DDI s9(2)(a)
| Ext s9(2)(a)

Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz | electoralreview.govt.nz

From: Jenny Vickers [DPMC] <[email address]>
Sent: Wednesday, 10 January 2024 9:08 am
To: Moore-Jones Anna <[email address]>
Cc: Connell, Elisha <[email address]>; Diana Hawker [DPMC]
<[email address]>
Subject: RE: Assistance with CabGuide connection - Open Government Partnership NAP4

You don't often get email from [email address]. Learn why this is important
Kia Ora Anna

The CabGuide is a living resource that gets updated as needed, so if you consider that there are
updates that could be made to make it a more useful tool for agencies, then I’m very happy to
chat about them. It is essentially a practical guide to Cabinet processes, which supplements the
Cabinet Manual, circulars, and other such information, and is primarily intended as a ‘how to’
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guide for public servants. We try not to use it as a source of repetition, but as a compliment
and/or signpost for other info out there.

Kind regards
Jenny

ACT 1982
From: Diana Hawker [DPMC] <[email address]>
Sent: Tuesday, 9 January 2024 1:13 pm
To: Moore-Jones, Anna <[email address]>
Cc: Connell, Elisha <[email address]>; Jenny Vickers [DPMC]
<[email address]>
Subject: RE: Assistance with CabGuide connection - Open Government Partnership NAP4

[UNCLASSIFIED]

Hi Anna,

Jenny Vickers is your best contact for the CabGuide – I’ve copied her into this email and she will
be back in the office from tomorrow.

INFORMATION
Regards
Diana

From: Moore-Jones, Anna <[email address]>
Sent: Wednesday, 20 December 2023 11:11 am
To: Diana Hawker [DPMC] <[email address]>
Cc: Connell, Elisha <[email address]>
Subject: Assistance with CabGuide connection - Open Government Partnership NAP4

You don't often get email from [email address]. Learn why this is important
Kia ora Diana,

I am in the Electoral + Constitutional policy team at Justice and am working on the Open
Government Partnership Fourth National Action Plan. The Ministry leads a commitment within
this action plan to improve scrutiny of exemptions to the Official Information Act 1982 (OIA).

I hoped that someone in your team would be able to direct us to an appropriate person
responsible for the CabGuide? We are interested in understanding more about the role of the
CabGuide and how it is maintained and updated.

We have carried out research on several pieces of legislation with exemptions and assessed
current guidelines for policy agencies regarding the OIA. Our research has illustrated that there is
a variance between agencies in the public rationale that is provided for any exemptions, and
there are some potential areas where guidance could be strengthened.

As part of this work, we are also speaking to different agencies about how current guidance
could be improved to assist agencies to give proper consideration to the OIA in new legislation.
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We have spoken with Treasury and the Ombudsman, and would also be interested in speaking
with someone about the CabGuide early in the new year.

We appreciate your assistance and hope that you have a lovely holiday break.

Ngā mihi nui,
Anna
ACT 1982

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Electoral and Constitutional Team | Policy Group
DDI s9(2)(a)
| Ext s9(2)(a)

Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz | electoralreview.govt.nz

INFORMATION
The information contained in this email message is for the attention of the intended recipient only and is not
necessarily the official view or communication of the Department of the Prime Minister and Cabinet. If you are not
the intended recipient you must not disclose, copy or distribute this message or the information in it. If you have
received this message in error, please destroy the email and notify the sender immediately.

The information contained in this email message is for the attention of the intended recipient only and is not
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5
Meeting with Jenny Vickers, DPMC to discuss Cabinet Guide, 17 January 2024
Meeting purpose: To discuss feasibility of updating CabGuide
Attendees: Anna Moore-Jones, Elisha Connel and Jenny Vickers (DPMC)
ACT 1982
CabGuide is aimed at public servants and for people in ministers’ offices.
Can be updated fairly easily.
Jenny recently worked with MoJ to update the guide around human rights.
CabGuide is not a primary resource – practical how to guide, much softer in its language, more
practical than Cab Manual. E.g. human rights info includes a little bit of repetition, but isn’t the
primary source.
Cab paper template can be tricker to make changes. They can make little tweaks, but more
substantive changes require at least PM approval. They try to keep the cab paper template shorter
than 10 pages. If there is something that will come up on a case by case basis it may not be suitable
to include in the template.
Jenny suggested that just doing an update to the guide may be a place to start.
INFORMATION
Jenny suggested pasting the content from the CabGuide into a word doc and playing with wording.
Look at OIA page itself. Under proactive release there is a page with details about OIA. Could also
add a link under the section ‘when you’re writing a paper.’
Next steps:
Review sections Jenny suggested and consider potential updates.
Consider if a link could be added, e g. that links to ombuds guidance or MoJ webpage (noted that
MoJ website didn’t have particularly comprehensive info so an update to this may also be
warranted). A link could also be added to the LDAC supplementary material if this is developed.
There may also be opportunity to discuss ombuds thoughts on guidance – perhaps there are key
points they may recommend adding/adjusting?
Update Sarah Kerkin with details we’ve gained from speaking with Jenny.
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6
Tuesday 30 January 2024 (10.30-11am)
Attendees: Sarah Kerkin, s9(2)(a)
s9(2)(a)
, Elisha Connel , Anna Moore-Jones
ACT 1982
Notes
The Office of the Clerk’s advice to Select Committee is about raising potential issues and questions for
the committee to ask. It is largely based on the LDAC guidelines. It was noted that LDAC guidelines
include little about the OIA and scrutiny of exemptions.
Office of the Clerk agreed that this topic would be a good inclusion to their Legislative Scrutiny work and
that they can take it back to their leadership for discussion. However, there are a lot of resource
pressures on the Office at the moment and the practical side of implementing any change to the
guidance or legislative scrutiny work that they do might not be possible at this time.
A lot of the time the individuals that are carrying out legislative scrutiny within the Office are not legally
trained so need guidance and authority from other sources to assist them to be wel  equipped in
completing the scrutiny and advising the committee. Currently they each complete an 8hr training
through Victoria University.
INFORMATION
Office of the Clerk noted that the best vehicle would be a reference within Disclosure Statements and
RIS as that would also then assist them with their legislative scrutiny. MOJ discussed the slower
timeframe of changing disclosure statements that was indicated in their conversation with TSY.
But discussed that maybe MOJ could do a bit more at RIS stage to flag issues and comment on other
people's Cabinet papers etc so as to set an example for good process on this topic.
Then discussed the role of Cab Guide, Ombudsman, and Parliament within this work.
Also referenced a statutory requirement that was passed some years ago but does not appear to have
been implemented by PCO {unclear what mechanism exactly? Part 4 or 5 PCO guidance on disclosure
statements. . .parliamentary approval of contents by resolution?}.
Office of the Clerk il ustrated that between 2015-2020 any legislative scrutiny they did was ad-hoc and
not done on all pieces of legislation. Their authority to complete legislative scrutiny was given to them in
2020 by the Standing Orders committee.
The Office is carrying out a huge work programme to operationalise the 2023 Review of Standing Orders
which is probably the biggest change to Select Committee since 1985. Therefore, it might not be
possible to also consider and include this issue within a new work programme given current resource
pressures.
However, in future, they can add the issue to the categories to be considered within their Legislative
Scrutiny guidance but would need to do a training session on it and it can be hard to find time in peoples
diaries for such a training.
MOJ outlined timeline and reporting requirements of NAp4 and OGP. Agreed that would show Office of
the Clerk any reporting that referenced them given the importance of maintaining constitutional
independence.
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Any guidance should cover what principles are for the OIA and any exemptions as wel  as what OIA
exemptions might look like (as they are not necessarily obvious).
Next Steps
-  MOJ to talk to LDAC about potential inclusion of issue within guidance
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-  MOJ to keep in touch with the Office of the Clerk and update them on progress
-  Office of the Clerk to take issue to managers to consider updating processes/guidance for
legislative scrutiny

Meeting with s9(2)(a)
and s9(2)(a)
, Office of the Clerk, 30 January 2024
Attendees: s9(2)(a)
(Principal Clerk of Committee), s9(2)(a)
(Principal Clerk (Procedure)),
Sarah Kerkin (Chief Advisor, ODS), Anna Moore-Jones (Advisor, E+C), Elisha Connell (Senior Adviser, E+C)
Purpose - to discuss potential involvement of Office of the Clerk in supporting Commitment 7.
Sarah provided an introduction to Commitment 7. In considering this work, she noted she had
immediately thought of the scrutiny work that the Clerk of the House had started. It struck her that this
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is an area that committees could start to look at.
s9(2)(a) noted that what stood out to him in the research paper was the range of different ways that the
OIA can be affected.
Sarah advised that she would be discussing the paper/issue with LDAC and noted that she felt there was
a gap in the guidelines and that these could be reviewed and supplementary guidance developed.
Sarah noted her support for the ‘disinfectant power of sunlight.’ The Office of the Clerk doesn’t need to
have the answers, but can shine light on the issue and encourage policy makers to consider things
further.
s9(2)(a) thought the issue looks like a good candidate for legislative scrutiny and is happy to take it back to
leadership to propose that it’s included in their programme. However, noted that it may not be suitable
to do so at this time given the following:
•  Resourcing for staff training around this issue/legislative scrutiny
•  Potential reduction to their budget (which could result in the scrutiny initiative being stopped)
•  Significant recent changes to select committees (staff have been very focused on these changes and
unsuitable to bring in further changes at present)
•  A lack of LDAC guidance on this issue (this is needed if training is to be given to staff and for staff to refer
to on an ongoing basis)
It was noted that it can be more challenging for the Office of the Clerk to identify things that aren’t there
as such (ie an exemption).
s9(2)(a)  noted that the disclosure statement would be a good trigger. Also noted the RIS as another place
that the issue could be flagged. s9(2)(a) noted that they do rely on RIS as can’t always be across large bills.
Anna explained advice we had received from Treasury and DPMC around editing templates.
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Sarah noted that the Office of the Clerk is not the ‘final fence at the top of the cliff,’ there are other
safety nets/mechanisms, however essential y each one does not catch everything, e.g. LDAC doesn’t
review every bill. If there is something that the Office of the Clerk could pick up and add to the work that
they’re doing it will help to layer the ‘safety nets.’
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Sarah noted that exemptions can be valid, but need to be done in a careful considered way.
s9(2)(a) noted the Office of the Clerk emphasises their independence, and if work is conducted, or Office
of the Clerk is noted in reporting, they would wish to see this to ensure they’re comfortable with
content.
s9(2)(a) also discussed that there is a parliamentary interest in this issue. There is an open question as to
whether OIA exemptions hinder parliament’s access to this information. He noted that this angle could
support interest in this issue.
Next steps
Sarah summarised the discussion and advised that next steps would be to discuss the issue with LDAC,
but wouldn’t pursue further with Office of the Clerk at this stage, though would report back after
discussion with LDAC. She noted that she could share an update on LDAC’s timeframes in due course.
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s9(2)(a) noted that he would share an update about the meeting with their management/leadership team.
He also requested that we email him so he has written confirmation that we will check wording with
them if Office of the Clerk is noted in our reporting/work (confirmation email sent 30 January 2024).

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8
Legislation Design and Advisory Council (LDAC) meeting notes, 15 February 2024
Background: Anna Moore-Jones, Advisor E&C, and Elisha Connell, Senior Advisor E&C, attended part
of the LDAC meeting held on 15 February 2024 to provide a short presentation on OGP Commitment
7 and recent research completed. LDAC had been sent a paper discussing the research prior to the
meeting. Sarah Kerkin, LDAC Deputy Chair, was unable to join remotely due to an internet outage.
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Opening comments:
Mark Steel, LDAC Chair, expressed that LDAC is interested in the issue of OIA exemptions and sees
this as an important area of concern. LDAC is willing to support efforts to review/strengthen
guidance. Appreciated the paper sent to LDAC prior.
Discussion following the presentation:
Existing guidance:
Is this matter covered in the LDAC guidelines already? There is passing reference to OIA in guidance.
LDAC is aware that they have previously given advice where they’ve advised that an agency hasn’t
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given a rationale for an OIA exemption. s9(2)(g)(i)

Stuart McGilvray, Chief Legal Adviser, Office of the Ombudsman, noted there isn’t a central place
where guidance is given around this issue/OIA. There is an inconsistent approach across the statute
book and OIA exemptions often don’t work (this area is messy). He wondered if guidance could be
developed, either by the Ombudsman or LDAC and queried if it could be an area for supplementary
guidance.
Potential approaches to new guidance:
Perhaps some slightly stronger presumptions could be provided, i.e. you should proceed on the basis
that the OIA and Privacy Act apply Maybe there is some language LDAC can develop around these
areas. LDAC is particularly sensitive to the circumstances that agencies face, but this can drift into a
situation where it is easy to provide justification.
There are three situations where OIA exemptions may be sought:
- Special comme cial grounds s9(2)(g)(i)
- Temporal aspect – temporal aspect of secrecy – probably justifiable
- Agencies try to use the OIA for just when they should proactively release information – this
is borrowing a concept from the OIA.
For the first situation, it’s easy to have a firm view, but for the third situation, there is uncertainty
about how to approach this.
When a similar issue was discussed/addressed by LDAC, there was a temptation to decide when
there were certain instances where things were more justifiable than others. This is problematic as it
provides a ‘train track’ for how people approach it. It would be a case of navigating this and noting
that these are the kinds of things that could be considered.
1
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Anna noted that it may not be so much a case of defining what circumstances, but more about
outlining that this is something agencies should be considering.
Stuart McGilvray noted that it may be more difficult for LDAC to take too strong a position, but that
the Ombudsman could provide a firmer stance. He noted that this may be an opportunity for the
Ombudsman to provide stronger guidance. He suggested that LDAC guidance could perhaps be ACT 1982
jointly produced with the Ombudsman.
It could be difficult to suggest that agencies should have a rationale and seek guidance, as people
will then seek guidance around what kind of rationale to provide.
At MBIE, staff receive training on the OIA, but it’s a one-off session and may not enable staff to have
sufficient knowledge/familiarity to approach this issue.
Two points:
-  If large numbers of OIA exemptions occur this would create a parallel regime.
-  If there is a genuine reason for withholding information this can be done. From an efficiency
perspective this is easy to understand if the information is never going to be released. The
question is whether there is already an ability to withhold the information.
With respect to potential adjustments to current LDAC guidance, an LDAC member queried if the
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OIA should be added to the constitutional issues in Chapter 4.
Consideration of public interest:
Experience from MBIE is that staff may not always have a strong grasp of the OIA, and have
apprehension around the balancing test. Generally, public service skills/knowledge on the OIA needs
to be improved.
More could be done to give effect to public interest.
LDAC further discussed public interest, and  t was noted that sometimes there is a lack of
understanding about what public interest means (sometimes it is misunderstood as something the
public is interested in).
Additional comments:
In the private sector, companies aim is to get around the OIA and to find ways to do that.
An LDAC member was interested in knowing how many of the proposed OIA exceptions in past years
have been reviewed by LDAC. (Seemingly not very many, if any).
With respect to open government, often government agencies might say they would prefer that
information is not provided, rather than provided with the caveat that it needs to be kept
confidential  Addressing this prevents the creation of secret submissions.
Potential ways that LDAC could help:
Mark Steel (LDAC Chair), suggested there may be four ways LDAC could support this issue:
-  LDAC could be more alert during their consideration of bills s9(2)(g)(i)

s9(2)(g)(i)

2
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-  LDAC could highlight the Ombudsman’s role and existing capability (LDAC can do more to
advise/state there is this entity that exists).
-  More specific guidance could be developed i.e. supplementary.
-  LDAC can contribute to efforts to support departmental capability – most likely through the
webinar series (he noted there is lots of room to strengthen departmental capability)   ACT 1982
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3
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While the project may be around policy decisions,  we hoped that taking a “swiss cheese” kind of
approach might be useful – as in, trying multiple different approaches for ensuring that the issue
is raised at multiple levels ahead of enactment. We hoped that this might provide various
opportunities for the rationale for any exemption to be made publicly available.

We are therefore interested in asking you:
Are there any places that could trigger both PCO and agencies to consider why an
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exemption is being included before drafting is complete? For example, in instances where
legislation is largely being copy/pasted, could there be an opportunity for PCO to flag any
OIA exemptions that might be carried across?
What is the training that kaimahi at PCO complete e.g. does it include training around
constitutional pieces of legislation like the OIA? Could any future training reference this
issue as one for consideration during drafting?
What guidance is provided from PCO that might include reference to this consideration
when carrying out drafting instructions and/or drafting itself? Could it be included in, for
example, a future newsletter update?

We hope that this is of assistance. We look forward to discuss ng this where appropriate.

Ngā mihi nui,
INFORMATION
Anna

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Democracy and Open Government Team | Policy Group

Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz  |  electoralreview.govt.nz

From: s9(2)(a)
@pco.govt.nz>
Sent: Monday, 18 March 2024 1:12 pm
To: Moore-Jones, Anna <[email address]>
Cc: s9(2)(a)
@pco.govt.nz>; Connell, Elisha <[email address]>
Subject: RE: Potential for Discussion? - Open Government Partnership - Commitment within the
Fourth National Action Plan

Hi Anna,

Thank you for your email and attached paper.

The attached paper helpfully outlines the project and the work that MoJ has done to date
identifying the number and type of provisions in our legislation overriding the disclosure
requirements in the OIA.
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Īmera: [email address]
Pae tukutuku: justice.govt.nz | electoralreview.govt.nz
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From: s9(2)(a)
@pco.govt.nz>
Sent: Friday, 8 March 2024 11:48 am
To: Moore-Jones, Anna <[email address]>
Cc: Connell, Elisha <[email address]>; s9(2)(a)
@pco.govt.nz>
Subject: RE: Potential for Discussion? - Open Government Partnership - Commitment within the
Fourth National Action Plan

Kia ora Anna,

Thank you for the opportunity to contribute “;-)

Our go-to person on information sharing and privacy matters is s9(2)(a)
.
INFORMATION

s9(2)(a) is out of the frame today but has a flexible schedule next week.
s9(2)(a)contact details are: s9(2)(a) @pco.govt.nz or s9(2)(a)

Before making contact, you may wish to provide Cathy with any relevant material (in addition to
the National Plan provided via the link below).

Ngā mihi,
s9(2)(a)

From: Moore-Jones Anna <[email address]>
Sent: Friday, March 8, 2024 11:02 AM
To: s9(2)(a)
@pco.govt.nz>
Cc: Connell, Elisha <[email address]>
Subject: Potential for Discussion? - Open Government Partnership - Commitment within the
Fourth National Action Plan

CAUTION: This email originated from outside the PCO. Do not click links or open attachments unless you
recognise the sender and know the content is safe.

Kia ora s9(2)(a)

I am in the Democracy and Open Government policy team at Justice and am working on the
Open Government Partnership Fourth National Action Plan. The Ministry leads a commitment
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within this action plan to improve scrutiny of exemptions to the Official Information Act 1982
(OIA).

I hoped that you or someone in your team would be interested in talking with us about any
relevant guidance/work at PCO that could be considered as part of this work?

We have carried out research on several pieces of legislation with exemptions and assessed ACT 1982
current guidelines for policy agencies regarding the OIA. Our research has illustrated that there is
a variance between agencies in the public rationale that is provided for any exemptions, and
there are some potential areas where guidance could be strengthened.

As part of this work, we are also speaking to different agencies about how current guidance
could be improved to assist agencies to give proper consideration to the OIA in new legislation.
We have spoken with Treasury, the Ombudsman, and LDAC, among others, and would also be
interested in speaking with someone at PCO sometime over the next few weeks, where suitable.

We look forward to hearing from you.

Ngā mihi nui,
Anna
INFORMATION

Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Democracy and Open Government Team | Policy Group

Wahi mahi: Justice Centre – Level 6, 19 Aitken St  Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz  |  electoralreview.govt.nz

Parliamentary Counsel Office Te Tari Tohutohu Pāremata
Level 13 Reserve Bank Building 2 The Terrace
PO Box 18 070
Wellington 6160
New Zealand
Phone: +64 4 333 1000
Website: www.pco.govt.nz Free access to NZ legislation: www.legislation.govt.nz
The information in this email (including any attachments) may be confidential and subject
to legal privilege. If the information has been given a security classification, it must be
handled in accordance with that classification.
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10
From:
Gareth Derby
To:
Moore-Jones, Anna
Cc:
Connell, Elisha; Yu-Lina George
Subject:
RE: Update around Commitment 7 of the Open Government Partnership
Date:
Friday, 12 April 2024 10:35:14 am
Attachments:
image001.jpg
image002.jpg
Hi Anna
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The closest we have is the Ombudsman’s Guidance on when to engage the Ombudsman in law reform proposals
which includes the following section:
Ombudsmen Act 1975 jurisdiction
6.
The Ombudsman has a general role under the Ombudsmen Act to investigate complaints about
public bodies and undertake own-motion reviews across the public sector. This jurisdiction is
broad and diverse, allowing the Ombudsman to act as a general watchdog over various public
entities.
7.
According to the LDAC guidelines, where new bodies are being established to exercise public
power the Ombudsman should be included as an oversight body.5 Agencies should consult the
Ombudsman if there is any proposal to deviate from that principle. A new agency has to be
brought within the Ombudsman’s jurisdiction by adding it to Schedule 1 of the Ombudsmen Act.6
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Official Information jurisdictions
8.
The Ombudsman supports the Official Information Act 1982 and the Local Government Official
Information and Meetings Act 1987 by investigating and reviewing complaints and conducting
systemic monitoring of official information practices across agencies.
9.
If changes to the OIA/LGOIMA, exemptions from the OIA/LGOIMA, or the establishment of
alternative official information regimes are under consideration, the Ombudsman should be
consulted. The Ombudsman’s view is that the OIA and LGOIMA should apply as broadly as
possible as a general regime guiding official information practices across the public sector. The
courts have long recognised the OIA as being ‘constitutional’ in nature.7 In addition, the OIA is
one of the vehicles by which New Zealanders may exercise their fundamental freedom to seek
and receive information, as enshrined in section 14 of the New Zealand Bill of Rights Act 1990. It
follows that the application of the OIA, as a constitutional measure which reflects fundamental
freedoms, should only be curtailed where there is clear justification.
10.
The OIA/LGOIMA contain a tried and tested regime which balances the competing interests in
accessing information held by public agencies. Creating alternate regimes is generally
unnecessary or misguided, and will inevitably involve complex and often unintended interactions
with the OIA/LGOIMA.
And the footnotes:
5
At [20.5] and [28.9].
6
This can be done by Order in Council, see s 32 Ombudsmen Act 1975.
7 Commissioner of Police v Ombudsman [1988] 1 NZLR 385
I’ve included the Ombudsmen Act part as inclusion within the schedules of the Ombudsmen Act generally makes
the agency subject to the OIA as well.
Kind regards
Gareth Derby
Principal Advisor Strategic Advice
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clarification on at this stage.

Further to the last meeting, I believe I mentioned the Chief Ombudsman’s:
submission on the Civil Aviation Bill, which is located here: https://www.parliament.nz/resource/en-
NZ/53SCTI_EVI_115765_TI2218/a70ff58e4e179cfd122cee45887470fbcdf1d471
submission on the Public Service Legislation Bill, located here:
https://www.parliament.nz/en/pb/sc/submissions-and-
advice/document/52SCGA_EVI_93134_GA3993/chief-ombudsman (page 4 onwards)
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This reflects a long line of submissions, including:
a 2012 submission on the Mixed Ownership Model proposals:
https://www.ombudsman.parliament.nz/sites/default/files/2022-
02/Submission%20of%20the%20Ombudsmen%20on%20the%20Mixed%20Ownership%20Model%20Bill.pdf
a 2013 submission on partnership schools proposals:
https://www.ombudsman.parliament.nz/sites/default/files/2022-
02/Submission%20of%20the%20Ombudsmen%20on%20the%20Education%20Amendment%20Bill.pdf

There are no doubt others which a deeper trawl might uncover, but I suggest they d simply show the
Ombudsman has consistently suggested the OIA regime should apply to agencies and/or specific information
held by agencies in the absence of a very good reason not to, on the basis that the OIA typically already provides
the ability to protect information where it warrants protection in the public interest. However if you would like
me to find further (public) examples, I’d be happy to do a deeper trawl!

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Kind regards
Gareth Derby
Principal Advisor Strategic Advice
Office of the Ombudsman | Tari o te Kaitiaki Mana Tangata

DDI s9(2)(a)
| Phone s9(2)(a)
| Fax s9(2)(a)
Email [email address] | www.ombudsman.parliament.nz
PO Box 10152, Level 7, SolNet House, 70 The Terrace, Wellington

IMPORTANT: The information contained in this email may be confidential or legally privileged. It is intended
solely for the recipient or recipients named in this message. Please note that if you are not the intended recipient
you are not authorised to use, copy or distribute the email or any information contained in it. If you have
received this email in error, please advise the sender immediately and destroy the original message and any
attachments.

From: Moore-Jones, Anna <[email address]>
Sent: Wednesday, 3 April 2024 3:52 pm
To: Gareth Derby <[email address]>
Cc: Connell, Elisha <[email address]>
Subject: Update around Commitment 7 of the Open Government Partnership

Kia ora Gareth,

I hope that you are well and had a lovely long weekend.

We wanted to give you an update on this commitment under the Open Government Partnership as have
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progressed various tasks since we last spoke. This includes:
-
Completed paper summarising research on OIA exemptions (attached)
-
Meetings with various agencies including a presentation to LDAC in February
o We are waiting to hear confirmation from LDAC on next steps but think there may be opportunity
for supplementary guidance or a webinar, and that this might include work to make better
reference to the Office of the Ombudsman’s role/guidance in this area.
-
Consultation with civil society as part of the partnership
o We provided a paper to civil society organisations outlining options for improving various scrutiny
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mechanisms/guidance for public servants and have received several submissions. We are still
collating feedback but note that a few have commented on the role of the Office of the
Ombudsman in this area but many suggestions are also out of scope of the current
commitment/OGP.
We are happy to meet to discuss anything or to provide further information, such as about the feedback from
consultation, if you would like. We’re also currently working through how we can share the submissions publicly
and can keep you updated on this.
We also always welcome any further details you might have of relevant examples of advice and/or guidance from
the Office of the Ombudsman as discussed at our last meeting.
Ngā mihi nui,
Anna
INFORMATION
Anna Moore-Jones (she/her/ia)
Policy Advisor – Kaitātari Kaupapa
Democracy and Open Government Team | Policy Group
Wahi mahi: Justice Centre – Level 6, 19 Aitken St, Wellington
Īmera: [email address]
Pae tukutuku: justice.govt.nz | electoralreview.govt.nz
IMPORTANT: The information contained in this email may be confidential or legally privileged. It is intended
solely for the recipient or recipients named in this message. Please note that if you are not the intended recipient
you are not authorised to use, copy or distribute the email or any information contained in it. If you have
received this email in error, please advise the sender immediately and destroy the original message and any
attachments.
IMPORTANT: The information contained in this email may be confidential or legally privileged. It is
intended solely for the recipient or recipients named in this message. Please note that if you are not the
intended recipient you are not authorised to use, copy or distribute the email or any information contained
in it. If you have received this email in error, please advise the sender immediately and destroy the
original message and any attachments.
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