26 July 2024
Sue
[email address]
[FYI request #27051 email]
Kia ora
Your Official Information Act request, reference: GOV-032719
Thank you for your requests of 29 May 2024 and 3 June 2024, asking for the following information under
the Official Information Act 1982 (the Act):
1.
I am writing to request the current list of all of ACC policies. I note the last request was in 2020. If a
current list of all of ACC's policies is available on ACC's website (such as a dedicated page) then
please direct me to that web page. Please provide the information in an excel spreadsheet format.
2.
I am writing to request the current list of all of ACC's processes and procedures, which, if I'm not
mistaken, would be the Promapp table of contents.
3.
Please also provide the list of historical ACC's list of ACC's processes and procedures, with
descriptors, for 2021, 2022, and 2023, if they are different from the current processes and
procedures. Please provide the information in an excel spreadsheet format.
4.
I would like to add an additional request. When you provide the list of policies, would you also
provide the directory extension for each document (in Promapp or other repository) and last date of
change.
Our Response I refer to your two emails via fyi.org.nz dated 15 July 2024 declining to provide the further information that
ACC sought to be able to deal with your request.
I note that ACC has received seven other messages in identical terms on 15 July 2025 from someone using
the same name as you in relation to requests that ACC is still considering and one in relation to a request
that ACC has recently declined, however none of those messages acknowledge that they are all sent by the
same person, despite ACC’s request that you should do so if that is the case.
ACC sent a message to you dated 5 July 2024 explaining in detail why ACC needed information about
yourself and the reasons for this official information request.
ACC notes that you do not accept ACC’s explanation justifies it asking for the information it has sought, and
you claim that ACC is treating you inconsistently with the way it treats others.
As ACC has previously explained to you, the Ombudsman accepts that where an agency receives an official
information request like yours, it may need to ask the requestor about themselves and the reasons for their
request.
ACC is treating you no differently than it would anyone else, whom it might reasonably ask if their request
was one of many related requests that could potentially be responded to together or refined in the ways
allowed by the Official Information Act.
GOV-032719 Page 1 of 3
The information sought about who you are and why you were making your request are the minimum
necessary for four reasons:
1. ACC is entitled to ask if your request is one of several related requests made by the same or related
people;
2. ACC has offered you the option to provide any personal information confidentially; and
3. ACC has invited you to suggest other ways to provide information to address ACC’s concerns if you
do not want to provide the information requested or to provide it in the way requested; and
4. You do not have to answer all of ACC's questions about your personal information if you prefer not
to, although how you answer ACC’s questions may be relevant to ACC’s decision whether to
respond to your official information request.
For the reasons that follow, ACC now declines your request.
• Over the past two months ACC has received more than 40 apparently closely related official
information requests that also appear to be made by or on behalf of the same person.
• These include a significant number of requests apparently made by you under the same name,
including the eight other separate requests where ACC received identical messages from the
requestor on 15 July, and other requests that are either anonymous or made under other names.
• All of these 40 or more information requests require considerable expense and effort for ACC to
respond to. ACC estimates that it is currently allocating more than the equivalent on one full time
employee to respond to each of these requests separately, despite the fact that they seem closely
related. It would likely require further effort to produce all of the information sought in each of
these requests.
• In one of the requests apparently made under your name, the requestor has acknowledged having
made more than one request, but neither they nor you have provided any details of any other
requests so to assist ACC to consider them together.
• ACC has decided that you, or people closely related to you, have probably made all of the large
number of recent requests mentioned above whether made under your name or not.
• The way that you, or people acting for you, appear to have asked for a wide range of information in
many separate requests rather than include all questions in one request interferes with ACC’s
ability to determine whether and how it might be able to apply various provisions of the Official
information Act to deal with your request. Those provisions relate to whether the requests taken as
a whole require substantial collation or research so as to:
o allow ACC to decline some or all of the requests under s18(f) of the Act;
o consider combining your request with any other requests made by you under s18A(2) of
the Act;
o fully to consider fixing a charge for providing the documents concerned under s15 and
s18A(1) of the Act.
• ACC considers that your request is frivolous or vexatious in terms of s18(h) of the Act. Your request
appears to be part of a wider course of conduct making numerous official information requests in a
way that prevents ACC from applying the parts of the Official Information Act that protect agencies
from being put to unreasonable effort and expense in responding to official information requests.
You have declined to assist ACC by providing information that might permit ACC to deal with your
request along with many other related requests. ACC has received similar refusals to assist in the
GOV-032719 Page 2 of 3
eight other requests referred to above. Your request and your refusal to answer questions about it
appear to be part of a course of conduct designed to prevent ACC from taking legitimate steps to
minimise the costs and inconvenience of responding to a series of related requests.
If ACC is wrong and your request is not one among many related requests then please let me know
urgently, or if you prefer, take the issue to the Ombudsman in the way set out at the end of this message.
ACC sought the same information from each of the requestors in as many of the related requests as it has
been able to identify and has not received information from any of them to allow it to work out how to
consider and respond to the requests in the way required by the Act.
If you have any questions about this response, please get in touch
You can email me at
[email address]. If you are not happy with this response, you can also
contact the Ombudsman
via [email address] or by phoning 0800 802 602. Information
about how to make a complaint is available at
www.ombudsman.parliament.nz. Ngā mihi
Christopher Johnston
Manager Official Information Act Services
Government Engagement
GOV-032719 Page 3 of 3
Document Outline
