Dear Statistics New Zealand,

Recently your organisation submitted to the Law Commission's review of the Official Information Act. I would like to request the following information under the OIA:

* a copy of your submission
* all drafts, advice, and internal communications (including emails) relating to that submission

I would prefer to receive an electronic response. Queries about this request will be automatically forwarded to me by the fyi.org.nz website.

With regards to s12 of the OIA, I am an NZ citizen and in NZ.

Yours faithfully,

Alex Harris

Dear Statistics New Zealand,

Thankyou for your response. While the decision to withhold the submisison itself under s18(d) can be justified (though at the same time, seems pointless; whats the cost to you of simply releasing it?), I regard the decision to withhold drafts, advice and communications about it as potentially dubious. I would therefore like to exercise my right under s19(a)(ii) to request the reasons for the decision. I am also concerned that you have not properly considered the public interest in release. The OIA is a fundamental accountability mechanism for government, and therefore there is an extremely high public interest in seeing what public servants _really_ think about it.

Finally, even if those reasons stack up, and the actual advice and communications can be withheld, you should still release a summary of the process used in gathering that advice (formal, or an email round the office?), and of the quantity and type of advice (a formal paper, or a collection of individual emails, and if so, the number of participants in the conversation). Such information does not pose any threat to the ability of public servants to express free and frank opinions, while being far more illuminating than a blanket denial.

Yours faithfully,

Alex Harris