Anne says that she took into account s18B of the Act, but did not consider taking the step in 18B would allow the request to be answered. That step was to "consider whether consulting with the person who made the request would assist that person to make the request in a form that would remove the reason for the refusal".

It is difficult for me to say conclusively that Anne should have made contact with you to discuss possible alternatives, but I am left wondering if that was a possiblity that was not taken by her. She does not say whether the register records the date of reciept of request and the date of completion. However if the register does, then it may be that she could simply provide you an Excel spreadsheet of requests for the time period covered that lists the date the request was received, the date it was completed, and the subject. You may then be able to use a formula to determine how many requests were completed within or outside of the 20 working day limit. One would think that the DPMC (which is one of the central agencies) would be diligent about recording the date the request was received and the date it was completed. But because Anne didn't go into detail as to what metadata is captured by DPMC then I (and maybe others reading the request) are left wondering.

In my view:
1. the DPMC should be capturing detailed metadata about OIA requests they are receiving for internal management purposes, and for being accountable if a request such as yours arises, and
2. could have perhaps taken a more proactive attitude or at least outline what metadata is and is not captured so you can make an informed decision as to an alternative request for what information you can obtain.

Furthermore, here is an example of the what Office of the Prime Minister provided to another requester, which exemplifies what I was outlining:

https://fyi.org.nz/request/1982/response...

I fully agree with Luke above. I would be complaining to the Ombudsman about this response on the same reasoning outlined by Luke.

So, how do I go about taking the action described above? Is there an easy way to raise this with the Ombudsman - e.g. would a link to this discussion suffice? Or do I need to collate the the response, and the discussion for their benefit?