Adapting WDTK for New Zealand

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It has been suggested that UK Freedom of Information website could be changed to apply to New Zealand's Access to Official Information legislation. The following outlines the differences/similarities in NZ legislation to the UK's FOI laws, and then details the required changes to the site to accommodate the NZ legislation by means of a gap analysis of current functionality versus requirements.

  • Official Information Act 1982 (OIA) - applies to NZ central government departments.
  • Local Government Official Information and Meetings Act 1987 (LGOIMA) - applies to local government.
  • Statistics
  • 897 OIA + 204 LGOIMA = 1101 (July 07 - June 08) appealed to Ombudsman (no internal review in NZ)
  • no information found on total number of OIA/LGOIMA requests.
  • could assume total requests based on xx% leading to appeals @ Ombudsman:
  • 5% - 22,000 requests in total
  • 10% - 11,000 requests in total
  • 20% - 5,500 requests in total
  • for comparison, around 10% of UK FOI requests go to internal review.
  • UK FOI - FOI, EIR, FOI(S)A & EIR(S) are compared to the NZ legislation below.
  • It may be worth getting in touch with the following sites to discuss their experiences:

Form of requests

  • OIA
  • Contact the Minister, department, organisation or local authority (Mayor, councillor or council staff ) concerned and ask for the information;
  • Be as specific as you can in identifying what information you are looking for;
  • Requests are best made in writing, but you can ask for the information in person or by telephone too; and
  • Keep a note of when, how and who you made your request to (and keep a copy of any requests made in writing).
  • LGOIMA - as per OIA
  • Example from Aukland City Council: "We have to provide reasonable assistance to anyone who wishes to make a request. Please make sure that your request has the following:
  • your name
  • postal address or e-mail address
  • what information you are requesting (clearly specify).
  • This process is very similar to UK FOI.
  • WDTK follows this process.


  • Both - Agencies are required to give you reasonable help to make an official information request.
  • This process is the same as UK FOI.

Identity of requestor

  • OIA - Anyone who is in New Zealand can request official information. New Zealand citizens overseas, and corporate bodies with a place of business in New Zealand can also apply.

"Under the OIA, anyone who is in New Zealand can request official information from government Ministers or government departments or organisations. New Zealand citizens and residents who are living overseas can also request official information. Companies that are either incorporated in New Zealand, or have a place of business in New Zealand, can also request official information."

  • LGOIMA - "Under LGOIMA, “any person” can request official information from a local government organisation. “Any person” includes corporations and groups of people."
  • Compared to UK FOI:
  • We'd need to ask users whether they are NZ or not for OIA requests.
  • We could ask a sympathetic organisation in NZ to act as a local proxy for OIA requests (to meet the "corporate bodies" clause)
  • No NZ guidance on how to treat pseudononymous or anonymous requests. This is a problem with WDTK, so we'd need to make further enquiries.
  • No official guidance on whether email is acceptable (some individual NZ public authorities says this is OK)


  • OIA
  • There may be a charge, but it must be a reasonable one.
  • You should be told of the charge, or given an estimate, before the information is provided;
  • Any charge will be related to the cost of the labour and materials involved in making the information available; and
  • If you think the charge is unfair you can complain to the Ombudsman (see below).
  • OIA Charging guidelines:
  • LGOIMA - same. See Auckland LGOIMA page for their charging policy.
  • No official statistics found on proporting of OIA/LGOIMA requests were charged for.
  • WDTK would need to handle fees workflow off-line. Current statuses would still apply - "withdrawn", "handled by post", "waiting for info" if paid via postal cheque.

Time for compliance

  • Both OIA & LGOIMA - Your request must be answered within 20 working days. The time limit for answering requests can be extended in some cases but if this happens you must be told of the extension and the reasons for it. No limit on time extensions. An agency can only extend the time limit once.
  • Both OIA & LGOIMA - If you need the information urgently you can ask for the request to be treated as urgent but you must explain why. Additional fee may be required.
  • This is virtually the same as UK FOI. Different sets of public holidays would need to apply.

public body scope

  • The government agencies that you can request information from are listed in the First Schedule to the Ombudsmen Act, the First Schedule to the OIA and the First Schedule to LGOIMA. Each of these Schedules can be viewed at the following website:

  • A list of the agencies that you can request information from can also be found in the Directory of Official Information, which is published by the Ministry of Justice every two years. The directory is available in public libraries or can be viewed at the following website:

1st stage complaints process

  • Both OIA & LGOIMA - complain directly to the Ombudsman, no internal review stage.
  • If not upheld, then can take to High Court
  • The UK FOI concept of Internal Review does not apply in NZ. WDTK would need to remove references & code that support Internal Reviews.

2nd/3rd stage complaints - ombudsman / tribunal / courts

  • If Ombudsman complaint upheld, but then refused by Public Authority, can take complaint to High Court, then Court of Appeal.
  • WDTK doesn't support the equivalent Info Tribunal / Court of Session process, so only on-screen textual advice changes required.

Points for consideration

  • OIA Section 23 – Reasons for Decisions. Under section 23 of the OIA, you are entitled, as a right, to ask an organisation to provide you with a written statement which explains the reasons for any decision or recommendation made by the organisation that affects you personally.
  • Recommend that these are not put through a public website such as WDTK - they are equivalent in the UK to a DPA request.

More info / links

Original legislation

WDTK changes required

  • General presentation - Differentiation required for country + legislation:
  • warning that only NZ nationals can apply for info under OIA
  • may have separate admin volunteers in NZ, different team@ contact email perhaps
  • "freedom of information" may not be a well known term in NZ
  • branding - eg or - image/colour changes?

Public site

  • Header
  • branding - eg or - image changes
  • help text for end-users about process needs to be separated from UK FOI
  • add flag icons or links to allow switch to UK version / site - here or in footer?
  • Search to only search NZ requests
  • Footer
  • different contact WDTK link?
  • different help/about link
  • add flag icons or links to allow switch to UK version / site - here or in footer?
  • Homepage
  • change "UK public authority"
  • amend Example searches
  • only show NZ authorities in example list
  • only show NZ requests in example list
  • Search to only search NZ requests
  • By law, they have to respond (why?) - different "why" link
  • single Public Authority page
  • change "in the UK" to NZ
  • reduced set of fields - no publication scheme, no charity reg no
  • change reference to "FOI" to OIA or LGOIMA as appropriate
  • "Only requests made using are shown" - change branding as required
  • /view_email needs to amend references to "FOI" as required
  • /view_email "please _contact us_" - link to change as required
  • /feed - needs to amend references to "FOI" as required
  • only NZ authorities should be shown
  • List of Public Authorities
  • Only NZ list types should be shown
  • only NZ authorities should be shown
  • "Are we missing a public authority?" needs to link to appropriate contact page
  • "(can't find the one you want?)" needs to link to appropriate contact page
  • List of Requests
  • Only NZ requests should be shown on both Successful & Recent lists of requests.
  • My Requests
  • only my NZ request should be shown
  • "Joined WhatDoTheyKnow in" - replace with site name as required
  • change reference to "Freedom of Information" as required
  • Individual requests
  • "Are you the owner of any commercial copyright on this page?" needs to link to the appropriate place
  • "More similar requests" link needs to search only NZ requests
  • "Similar requests" needs to display only NZ requests
  • Act on what you've learnt - remove/replace: Write to your politician / Petition the PM
  • Pledge with others & Start your own blog are OK to keep - global sites
  • change reference to "Freedom of Information request" as appropriate
  • send followup/reply - remove "I am requesting an internal review (what's that?)" option. Might be better to have "Reply to main OIA address" + "reply to this person" instead.
  • take out link to "Request an internal review"
  • Annotations
  • "read our moderation policy" - change link if required.
  • Add further requirements due to local legislation if required
  • User Management
  • warning on registration that only NZ nationals can apply for info under OIA
  • Help/about
  • needs re-wording appropriately.
  • check for local legislation re personal information takedown publication - may need a stricter policy.
  • Help/unhappy
  • change wording appropriately.
  • no internal review
  • complaints process to Ombudsman is similar to ICO.
  • Search page
  • change reference to "Freedom of Information" as appropriate
  • amend search tips to NZ things
  • remove "internal review" status
  • change reference to "WhatDoTheyKnow" as appropriate
  • Categorise/play
  • no changes required for NZ.

Admin site / workflow

  • General
  • Separate admin site for NZ to allow for separate set of volunteers
  • all admin pages should only display NZ info: requests, users, annotations, authorities, tracks
  • stats page - NZ info only
  • search indexer - to run against NZ info only
  • either different admin URLs or require way of switching between NZ/UK
  • Authorities admin
  • reduced set of fields - no publication scheme, no charity reg no
  • indicate whether public authority is OIA or LGOIMA
  • Request workflow / status
  • Remove concept of internal request.
  • Other statuses are OK
  • NZ set of public holidays required in date calculations.

Solution options & recommendations

  • Option 1: Fork code and amend. New database/website.
  • Option 2: Amend code to accommodate both websites. Same DB
  • Estimates are in man-days (7hrs/md), and are fairly conservative.

Option 1

  • Option 1 is to take a copy of the current codebase and database structure as a starting point, and make required changes for it to accommodate the NZ OIA legislation/workflow. This approach is sometimes known as "lift & shift".
  • It would require its own separate database, website, URL, contact email addresses
  • There would be no link between the UK & the NZ websites. Any admins who were involved in both sites would need separate logins.
  • Any enhancements, bug fixes or changes that affected both sites would need to be developed in one site, and code merged to other site.
  • Developers / IT Support - could be carried out by separate team of NZ-based developers & infrastructure support on their own hardware if not kept in-house.
  • Development estimates: 3-5md infra setup, 10-15md development, 5md testing = TOTAL 18-25md

Option 2

  • Option 2 extends the current codebase & database to accommodate the NZ OIA legislation/workflow.
  • Each page/function needs to ensure the appropriate data is being searched for, displayed & saved correctly.
  • Bug-fixes would be applied on one site, less total support overhead
  • This option does make the current codebase more complex. Additional testing effort would be needed when making change to ensure no breaking fixes.
  • Developers & admins would have access to all data & code, unless requirement exists to segregate access rights, in which case further analysis required.
  • Significant regression testing required to ensure UK functionality still works correctly
  • Performance testing would be required to ensure page response times acceptable with additional traffic/bandwidth
  • Development & testing - could be carried out completely in the UK by existing developers, or outsourced to volunteer developers elsewhere.
  • new development/testing environments may be needed to work on the code if >1 developer is working simultaneously
  • EITHER: Change to source code management methodology to branch/tag/trunk/merge model to support production bugfixes during development phase
  • OR: "change freeze" to production environment during development phase.
  • IT Support - would need overnight resolution from NZ point of view if dependent on UK developers & infrastructure support, eg if site hardware goes down.
  • Development estimates: 0-3md infra setup (if test env'ts required), 20-25md development, 7-10md testing = TOTAL 27-38md

Estimates common to both options

  • 2-3md re-write of help text.
  • 5md collection of public authority data
  • 5md launch - press releases, blog writing, SEO
  • Potential new functionality:
  • method for carrying out Complaints stage with Ombudsman. This may require temporary transfer of the request's public authority to Ombudsman, or amended workflow. Assumes that Ombudsman is happy for complaints process to be public. Impacts on existing Follow-up & Reply functionality, Workflow, Xapian index updating, etc. Could also be fudged by looking at domain email addresses of incoming requests & end-user/admin classification of requests. Estimate: 4-5md incl testing.


  • Both options need to take into consideration end-user support - moderators would need some knowledge of NZ legislation.
  • Recommend recruitment of NZ-based volunteers in order to provide site moderation during NZ daytime timezone.
  • NZ legal advice may be required to assist with any legal disputes over the site, eg data protection, libel, unauthorised disclosures. cf [1] for the latter.
  • If WDTK-NZ is being kept in-house by mysociety, then recommend Option 2, otherwise Option 1.