Email redirection and communication plans
Joe made this Official Information request to Department of Internal Affairs
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From: Joe
Dear Department of Internal Affairs,
I am seeking clarification regarding the position of the Department of Internal Affairs and their advice to NZ government agencies, regarding "communication plans" which include "email redirection".
In ACC's response GOV-005668 (04/08/2020), Sasha Wood, Manager Official Information Act Services, stated:
"Redirection of emails, outside of a communication plan, may occur..."
In ACC's response GOV-026875 (11/08/2023), Sara Freitag, Acting Manager Official Information Act Services, wrote:
"ACC’s Communication Plan Policy was approved in December 2022. This policy is a formal document outlining the process undertaken if client’s behaviour or communication is unreasonable; this process includes email redirection."
ACC's Communication Plan Policy v2.0 states:
"The restrictions that can be placed on a client are the same as those outlined by the Ombudsman in Managing unreasonable complainant conduct practice manual."
In ACC's response GOV-029414 (15/12/2023), Sara Freitag, Manager Official Information Act Services, wrote:
"We currently have a total of 71 mail flow rules for email redirection purposes."
In ACC's response GOV-029712 (29/01/2024) Jason Hope, Acting Manager Official Information Act Service, wrote:
"ACC has 75 client email addresses subject to email redirection. These email addresses are either linked to at least one client in EOS or are not linked to a client in EOS but we have otherwise determined are emails used by clients. Some of these may also be linked to non-client records. We have identified a further nine email addresses subject to email redirection, which were previously linked to a client in EOS."
I can find no mention of "email redirection" in the Ombudsman's manual, only references to email blocking or forwarding (both legitimate and lawful). The comment on p 100 could be loosely interpreted as "email forwarding", but then Chapter 20 starts with "What if access cannot be restricted or we have contributed to the problem?"
I request documents, reports, advice, or any other information, that describe the Department of Internal Affairs': understanding of:
(a) the meaning of "email redirection",
(b) when "email redirection" is to be implemented as part of a communication plan,
(c) how "email redirection" is to be implemented,
Please specify whether the "email redirection" should:
(a) occur during transit, that is the email is redirected to an unintended person at an email server and before reaching the intended recipient, or
(b) occur after the intended recipient received the email, which requires either the intended recipient to open and forward the email manually, or the intended recipient sets up a rule so that the email is forwarded to a person that they designated.
To clarify, in scenario (a) all of the sender's emails are redirected to an unintended recipient, including all emails sent to the general complaint team inbox. That is, not one communication is ever received by the intended recipient. However, in scenario (b), the intended recipient receives the communication, but then the intended recipient chooses whom to forward the message to (like their manager).
I request the list of documents which informed the Department of Internal Affairs' advice and the discussion papers as to how restriction of complainants' communications is consistent with obligations imposed under the OIA, Privacy Act, NZBoRA, and any other legislation that confers rights of freedom of expression (seeking, obtaining, and disseminating information)
Please specify whether the extreme steps of restricting communications is applicable when the complainant has legitimate complaints, which are not being addressed in accordance with the law, and when the complainant has not been violent or abusive, but has only been persistent expressed frustration or has been simply annoying.
Thanks
Joe
From: OIA
Department of Internal Affairs
Good morning Joe,
I have confirmed with ACC that they did not receive any advice from the Department of Internal Affairs regarding email redirection in communications plans (or anything similar to this). Across the Department, we are also not aware of having provided any advice to ACC in relation to communications plans, email redirection, or engagement with the public.
I understand that ACC is already responding to you on the same matter.
Can you advise whether you still require any information from the Department of Internal Affairs?
Thanks,
Michelle Reed (she/her)
Lead Advisor Official Correspondence | Information Management and Privacy
He Ringa Manaaki | Workplace Services Group
He Pou Aronui | Organisational Capability and Services
Te Tari Taiwhenua | Department of Internal Affairs
Level 3, 45 Pipitea St | PO Box 805, Wellington 6140, New Zealand | http://www.dia.govt.nz/
-----Original Message-----
From: Joe <[FOI #27127 email]>
Sent: Tuesday, June 4, 2024 12:51 PM
To: OIA <[DIA request email]>
Subject: Official Information request - Email redirection and communication plans
[You don't often get email from [FOI #27127 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]
Dear Department of Internal Affairs,
I am seeking clarification regarding the position of the Department of Internal Affairs and their advice to NZ government agencies, regarding "communication plans" which include "email redirection".
In ACC's response GOV-005668 (04/08/2020), Sasha Wood, Manager Official Information Act Services, stated:
"Redirection of emails, outside of a communication plan, may occur..."
In ACC's response GOV-026875 (11/08/2023), Sara Freitag, Acting Manager Official Information Act Services, wrote:
"ACC's Communication Plan Policy was approved in December 2022. This policy is a formal document outlining the process undertaken if client's behaviour or communication is unreasonable; this process includes email redirection."
ACC's Communication Plan Policy v2.0 states:
"The restrictions that can be placed on a client are the same as those outlined by the Ombudsman in Managing unreasonable complainant conduct practice manual."
In ACC's response GOV-029414 (15/12/2023), Sara Freitag, Manager Official Information Act Services, wrote:
"We currently have a total of 71 mail flow rules for email redirection purposes."
In ACC's response GOV-029712 (29/01/2024) Jason Hope, Acting Manager Official Information Act Service, wrote:
"ACC has 75 client email addresses subject to email redirection. These email addresses are either linked to at least one client in EOS or are not linked to a client in EOS but we have otherwise determined are emails used by clients. Some of these may also be linked to non-client records. We have identified a further nine email addresses subject to email redirection, which were previously linked to a client in EOS."
I can find no mention of "email redirection" in the Ombudsman's manual, only references to email blocking or forwarding (both legitimate and lawful). The comment on p 100 could be loosely interpreted as "email forwarding", but then Chapter 20 starts with "What if access cannot be restricted or we have contributed to the problem?"
I request documents, reports, advice, or any other information, that describe the Department of Internal Affairs': understanding of:
(a) the meaning of "email redirection",
(b) when "email redirection" is to be implemented as part of a communication plan,
(c) how "email redirection" is to be implemented,
Please specify whether the "email redirection" should:
(a) occur during transit, that is the email is redirected to an unintended person at an email server and before reaching the intended recipient, or
(b) occur after the intended recipient received the email, which requires either the intended recipient to open and forward the email manually, or the intended recipient sets up a rule so that the email is forwarded to a person that they designated.
To clarify, in scenario (a) all of the sender's emails are redirected to an unintended recipient, including all emails sent to the general complaint team inbox. That is, not one communication is ever received by the intended recipient. However, in scenario (b), the intended recipient receives the communication, but then the intended recipient chooses whom to forward the message to (like their manager).
I request the list of documents which informed the Department of Internal Affairs' advice and the discussion papers as to how restriction of complainants' communications is consistent with obligations imposed under the OIA, Privacy Act, NZBoRA, and any other legislation that confers rights of freedom of expression (seeking, obtaining, and disseminating information)
Please specify whether the extreme steps of restricting communications is applicable when the complainant has legitimate complaints, which are not being addressed in accordance with the law, and when the complainant has not been violent or abusive, but has only been persistent expressed frustration or has been simply annoying.
Thanks
Joe
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[FOI #27127 email]
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From: Joe
Dear Ms Reed,
This is a follow up request for the documents which informed your statement "I understand that ACC is already responding to you on the same matter." ACC has not responded to my request.
Yours sincerely,
Joe
From: Joe
Dear Ms Reed,
Thank you for your email; however you have not responded to my request. I used ACC as an example, but my request was not restricted to ACC.
The DOIA has the
- Government Chief Data Officer
- Government Chief Privacy Officer
- Government Chief Information Officer.
These officers are all responsible for providing guidance, standards, interpretation, etc., for the ethical and legal methods for obtaining, seeking, disclosing, using, and/or storing personal information, and hence should all have a position regarding "communication plans" and "email redirection". The DOIA is also one of the agencies who has persons who may intercept personal communications, after having obtained a lawful warrant, under the Search and Surveillance Act. Thus, there must be clear statements about the legality of "email redirection".
Yours sincerely,
Joe
From: minadviceteam
Department of Internal Affairs
Good morning Joe,
Please find attached the Department's response to your request.
Kind regards,
Olivia
Olivia Ryan (she / her) | Senior Advisor Ministerial and Official Correspondence
Ministerial, Monitoring, and Capability Group
Toi Hiranga | Regulation and Policy
Department of Internal Affairs | Te Tari Taiwhenua
45 Pipitea Street | PO Box 6011, Wellington 6140 | http://www.dia.govt.nz/
-----Original Message-----
From: Joe <[FOI #27127 email]>
Sent: Monday, June 17, 2024 7:03 AM
To: OIA <[DIA request email]>
Subject: RE: Official Information request - Email redirection and communication plans
[You don't often get email from [FOI #27127 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]
Dear Ms Reed,
Thank you for your email; however you have not responded to my request. I used ACC as an example, but my request was not restricted to ACC.
The DOIA has the
- Government Chief Data Officer
- Government Chief Privacy Officer
- Government Chief Information Officer.
These officers are all responsible for providing guidance, standards, interpretation, etc., for the ethical and legal methods for obtaining, seeking, disclosing, using, and/or storing personal information, and hence should all have a position regarding "communication plans" and "email redirection". The DIA is also one of the agencies who has persons who may intercept personal communications, after having obtained a lawful warrant, under the Search and Surveillance Act. Thus, there must be clear statements about the legality of "email redirection".
Yours sincerely,
Joe
-----Original Message-----
Good morning Joe,
I have confirmed with ACC that they did not receive any advice from the Department of Internal Affairs regarding email redirection in communications plans (or anything similar to this). Across the Department, we are also not aware of having provided any advice to ACC in relation to communications plans, email redirection, or engagement with the public.
I understand that ACC is already responding to you on the same matter.
Can you advise whether you still require any information from the Department of Internal Affairs?
Thanks,
Michelle Reed (she/her)
Lead Advisor Official Correspondence | Information Management and Privacy He Ringa Manaaki | Workplace Services Group He Pou Aronui | Organisational Capability and Services Te Tari Taiwhenua | Department of Internal Affairs Level 3, 45 Pipitea St | PO Box 805, Wellington 6140, New Zealand | http://www.dia.govt.nz/
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #27127 email]
Disclaimer: This message and any reply that you make will be published on the internet. Our privacy and copyright policies:
https://fyi.org.nz/help/officers
If you find this service useful as an Official Information officer, please ask your web manager to link to us from your organisation's OIA or LGOIMA page.
-------------------------------------------------------------------
hide quoted sections
From: Joe
Dear Department of Internal Affairs,
Thank you for your response, however, it was incomplete.
I request documents, reports, advice, or any other information, that describe the Department of Internal Affairs': understanding of:
(a) the meaning of "email redirection",
(b) when "email redirection" is to be implemented as part of a communication plan,
(c) how "email redirection" is to be implemented,
Please specify whether the "email redirection" should:
(a) occur during transit, that is the email is redirected to an unintended person at an email server and before reaching the intended recipient, or
(b) occur after the intended recipient received the email, which requires either the intended recipient to open and forward the email manually, or the intended recipient sets up a rule so that the email is forwarded to a person that they designated.
Yours faithfully,
Joe
From: OIA
Department of Internal Affairs
Tēnā koe Joe
Thank you for your Official Information Act request to the Department of Internal Affairs (included with this email).
Please find attached an email train between the Department and ACC. The email that was sent by Paulina Buchta on 06 June 2023 at 12.43 GMT is the document that informed my statement "I understand that ACC is already responding to you on the same matter.".
Similar phrasing is often exchanged between agencies during transfer consultation, when they are confirming to one another that transfer is unnecessary as they are also responding to the same request. Due to my role handling most of the Department's transfers, it appears I misunderstood the meaning of Paulina's comment. I note that I am not aware of the details/timing of any requests you may have made to ACC. I apologise for any confusion that my statement may have caused.
You have the right to seek an investigation and review by the Ombudsman of this decision. Information about how to make a complaint is available at www.ombudsman.parliament.nz or Freephone 0800 802 602.
Nāku, nā
Michelle Reed (she/her)
Lead Advisor Official Correspondence | Information Management and Privacy
He Ringa Manaaki | Workplace Services Group
He Pou Aronui | Organisational Capability and Services
Te Tari Taiwhenua | Department of Internal Affairs
Level 3, 45 Pipitea St | PO Box 805, Wellington 6140, New Zealand | www.dia.govt.nz
-----Original Message-----
From: Joe <[FOI #27127 email]>
Sent: Monday, June 17, 2024 6:58 AM
To: OIA <[DIA request email]>
Subject: RE: Official Information request - Email redirection and communication plans
[You don't often get email from [FOI #27127 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]
Dear Ms Reed,
This is a follow up request for the documents which informed your statement "I understand that ACC is already responding to you on the same matter." ACC has not responded to my request.
Yours sincerely,
Joe
hide quoted sections
From: Melanie Carpinter
Department of Internal Affairs
Kia ora Joe,
Please find attached a response to your Official Information Act request
dated 1 July 2024.
Ngâ mihi,
Mel
Mel Carpinter
General Manager – Communications
Te Tari Taiwhenua | Department of Internal Affairs
[1]www.dia.govt.nz | [2]Facebook | [3]LinkedIn
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