The Department of the Premier and Cabinet (DPC) Circular 35 – Proactive Disclosure of Regularly Requestion Information (PC035) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) specifies the information required to be proactively disclosed to the public through online publication.

The existence of PC035 does not limit an agency’s ability to proactively disclose other information at the discretion of the agency Chief Executive.

This webpage assists agencies interpret and implement PC035 consistently and considers:

Agency staff responsible for publishing information under PC035 should consider the provisions of the Freedom of Information Act 1991 (FOI Act). If the information they are considering is likely to be exempt from disclosure under the FOI Act then the agency may wish to redact the exempt information or delay disclosure until such time as the reason for exemption ceases to be of relevance.

Reporting elements of PC035

This section provides additional context to section 5 of PC035, the type of staff it applies to and which agencies must report them.

This table indicates which state government agencies are responsible for reporting the different types of information listed under section 5 of PC035.

Disclosed information

Agencies required to report

Overseas travel
(section 4.2)

All public sector agencies as per definition of the Public Sector Act 2009.

All other information listed in Section 5 of PC035
(section 4.1)

All Ministers offices, the Leader of the Opposition and the agencies (or substitutes of those agencies) listed below:

  • Attorney-General’s Department
  • Department for Child Protection
  • Department for Correctional Services
  • Department for Education
  • Department for Energy and Mining
  • Department for Environment and Water
  • Department for Health and Wellbeing
  • Department for Housing and Urban Development
  • Department for Infrastructure and Transport
  • Department of Human Services
  • Department of the Premier and Cabinet
  • Department of Primary Industries and Regions
  • Department of State Development
  • Department of Treasury and Finance
  • South Australia Police

All public sector agencies as defined in the PS Act are required to comply with the overseas travel disclosure requirements of PC035.

However, if the following staff types are traveling overseas with a Minister, their travel will need to be reported as per Part 3A of the PS Act (more information below).

Staff type

Reporting details required under PC035;

Chief Executive

  • the number of travellers
  • the destination
  • the reason for travel
  • the outcome of travel and
  • the cost (excluding salary) of travel paid for out of the budgets of Ministers and/or agencies.

Public Sector Employees (not including CEs)

  • the number of travellers
  • the destination
  • the reason for travel and
  • the total cost (excluding salary) of travel paid for out of agency budgets.

Key overseas travel details:

The use of the word ‘including’
The policy refers to ‘Details of …. overseas travel arrangements including cost of travel…’.  This suggests disclosure is not limited to cost; all travel arrangements should be published even if the costs are nil meaning all non-financial columns of the template can still be completed. Agencies may explain in the template why the costs are nil (for example, they were paid for out of a parliamentary allowance or by a conference organiser).

The outcome of travel (CEs)
The outcome of travel is only required to be published for Chief Executive’s travel arrangements.

It is suggested that agencies attach, or include separate hyperlinks to, consolidated scanned documents containing the information for ‘reasons for travel and outcomes of travel’ in the relevant columns within the template, where required.

Agencies will need to determine the level of detail they include in the ‘travel outcomes’ and ‘reasons for travel’ documentation. Chief Executives are required to prepare a report for their agency in line with the requirements of Commissioner’s Determination 3.2.  It may be efficient to use these documents as the basis for disclosure where appropriate.

The outcome of travel (public sector employees excluding CEs)
Summarised travel information only needs to be published for public sector employees’ (excluding Chief Executives’) overseas travel arrangements. The outcome of travel is not required.

Following publication of summarised public sector employee travel information, if a member of the public seeks to access travel outcomes it is recommended, where possible, this documentation be released outside of the FOI process and at no cost to the requestor. This recommendation is in line with section 3(3) of the FOI Act which provides that nothing in the FOI Act is intended to prevent or discourage the publication of information, or the giving of access to documents, in ways other than under this Act if it is proper and reasonable to do so.

Templates
Chief Executive overseas travel information should be recorded using the ‘Chief Executive’ template.

Public sector employee (excluding Chief Executives) overseas travel information should be recorded using the ‘public sector employees’ template.

Consultants
If consultants are travelling with the Chief Executive, and their travel was organised by an agency, they should be included in the ‘Chief Executives’ template. The number of consultants should be included in the ‘No. of travellers’ column and if the consultant’s travel is paid for out of the budget of an agency then the consultant’s costs should be included in line with the relevant template.  If their travel costs were paid for in some other way, do not include the costs.

Total cost of travel
The total of the actual expense incurred by the agency (in Australian dollars) should be included in the ‘total cost of travel’ column.

Chief Executive/public sector employee salary costs are not required to be included.

Public sector agencies identified in section 4.1 are only required to comply with the interstate travel disclosure requirements of PC035. However, if public sector employees (including Chief Executives) are traveling interstate with a Minister, their travel will need to be reported as per Part 3A of the PS Act, not PC035.

If not traveling with a Minister, Chief Executives are only required to report interstate travel under PC035. All other public sector employees are not required to report interstate travel.

Travel type

Minister

Chief Executive

Public Sector Employee

w/ Minister

w/o Minister

w/ Minister

w/o Minister

Interstate

PS Act

PS Act

PC035

PS Act

n/a

The reporting details required for interstate travel under PC035 include:

  • number of travellers
  • the destination
  • the reason for travel and
  • the total cost (excluding salary) of travel paid for out of agency budgets.

Key interstate travel details:

  • Any travel outside of South Australia by a Chief Executive, where a cost is incurred and paid for out of an agency budget, needs to be disclosed.
  • ‘The outcome of travel’ is not required to be reported under PC035 for interstate travel. However, it is recommended requests for access to interstate travel outcomes are processed outside of the FOI Act.
  • Relevant costs may include costs associated with flights, train tickets, vehicle hire, ferry passage, accommodation, meals.
  • Where staff are travelling with the Chief Executive and the dominant reason for their travel is to support or assist them, then their travel details should be included. If staff would have been attending the function or event in their own job capacity as part of their own job role they do not need to be included.

Public sector agencies identified in section 4.1 are only required to comply with the intrastate travel disclosure requirements of PC035. Details of intrastate travel arrangements of Ministers and Chief Executives, where costs are incurred, are required to be reported. All other public sector employees are not required to report intrastate travel.

Travel type

Minister

Chief Executive

Public Sector Employee

w/ Minister

w/o Minister

w/ Minister

w/o Minister

Intrastate

PC035

PC035

PC035

n/a

n/a

Publication of intrastate travel should include:

  • the number of travellers
  • the destination
  • the reason for travel and
  • the total cost (excluding salaries and vehicles included within employment package arrangements) paid for out of the budgets of Ministers and/or agencies.

Key intrastate travel details:

  • Any travel outside of metropolitan Adelaide by a Minister/Chief Executive, where a cost is incurred and paid for out of a ministerial or agency budget, needs to be disclosed.
  • Relevant costs may include costs associated with flights, train tickets, vehicle hire, ferry passage, accommodation, meals.
  • Where staff are travelling with the Minister/Chief Executive and the dominant reason for their travel is to support or assist them, then their travel details should be included. If staff would have been attending the function or event in their own job capacity as part of their own job role they do not need to be included.

Expenditure relating to the mobile phone usage is required to be reported by Ministers, ministerial staff and the Chief Executives of agencies listed in section 4.1. However, agencies are exempt from reporting this information if the release of this information would breach contractual obligations.

  • The policy refers to ‘government expenditure relating to the mobile phone usage…’ Purchasing handsets is not considered a cost of usage, but rather a set-up cost. The cost of the handset should therefore not be included in the disclosure. However data costs should be disclosed.

Expenditure on functions or events hosted or attended by Ministers, ministerial staff and Chief Executives of agencies listed in section 4.1 is required to be reported.

Publication must include:

  • description of the event
  • the location
  • accommodation expenses and
  • refreshments provided in or out of meetings with external visitors.

Key ancillary expense details:

  • Any expenses incurred by a department related to hosting or attending functions or events that are not part of ordinary office expenditure constitute ‘ancillary expenses’ and should be included. Travel and accommodation to attend such events would be included if it is not included under the domestic/regional or overseas travel disclosure. Hosting visitors (individuals external to the agency) where morning tea or lunch / refreshments are provided should be included.
  • Functions and events like internal office meetings, training and staff meetings do not need to be included.

Credit card and/or purchase card expenses paid for out of agency or ministerial budgets must be reported under PC035. This applies to Ministers, ministerial staff and Chief Executives of agencies listed in section 4.1.

This can be achieved by publishing a card statement report that identifies the:

  • card provider
  • date range
  • employee name and
  • lists the date, merchant, transaction description and expense amount.

Travel reporting under Part 3A of the Public Sector Act 2009

In 2024, the PS Act was amended to introduce a requirement for certain travel reporting to be tabled in Parliament as per Part 3A of this Act.

This requirement ensures Ministerial travel details are reported to Parliament within 45 days. This applies to Ministers and the Leader and Deputy Leader of the Opposition in the House of Assembly and Legislative Council who undertake official travel outside South Australia. Part 3A also extends to details of any ministerial staff member or public sector employee (including Chief Executives) who accompany the Minister.

Information now required to be reported under the PS Act, previously reported under PC035, have been removed from PC035. This is to avoid confusion and ensure there is no duplicated reporting.

See the Travel Reporting Matrix below for an overview of reporting requirements depending on who is travelling and where.

Refer to the Travel reporting webpage (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) (external site) for more information and templates in relation to reporting under the PS Act.

State Records recommends agencies provide a link to reports tabled under the PS Act on their websites to alleviate potential enquiries and FOI requests.

Travel reporting matrix

This matrix identifies the mechanism for reporting required for each travel type and the staff travelling.

Travel type

Minister1

Chief Executive

Public Sector Employee

w/ Minister

w/o Minister

w/ Minister

w/o Minister

Overseas

PS Act

PS Act

PC035

PS Act

PC035

Interstate

PS Act

PS Act

PC035

PS Act

n/a

Intrastate

PC035

PC035

PC035

n/a

n/a

1The term Minister includes the Leader of the Opposition as per PC035 and includes both the Leader and Deputy Leader of the Opposition as per Part 3A of the PS Act.

Page last updated: 30 January 2025