Corruption and Integrity Update May 2025

In this edition of the Queensland Corruption and Integrity Update we consider various updates related to the CCC, including matters before the Parliamentary Crime and Corruption Committee. We also consider updates from the Office of the Information Commissioner (OIC) and Queensland Ombudsman.

Parliamentary Crime and Corruption Committee Public Meetings

On 13 May 2025, the Parliamentary Crime and Corruption Committee (PCCC) held a public meeting with both the Parliamentary Crime and Corruption Commissioner and the CCC. The Gadens Corruption and Integrity February 2025 Update covered the last public meeting in February 2025.

Parliamentary Crime and Corruption Commissioner

Mr Mitchell Kunde, the Acting Parliamentary Crime and Corruption Commissioner appeared before the PCCC. Mr Kunde presented the Parliamentary Crime and Corruption Commissioner’s public report and provided an update of the work of the PCCC for the period 22 January 2025 to 22 April 2025, noting that key activities of the period include:

• an inspection of the CCC’s telecommunications interception warrants records;
• an inspection of the CCC’s surveillance device warrants records;
• an audit of the CCC’s authorities for the use of assumed identities and a report to the CCC Chair;
• reviewing information and advise whether CCC acted appropriately; and
• assess notifications received from CCC of suspected improper conduct of Commission officers.

One matter of note raised by Mr Kunde related to proposed amendments to the Telecommunication (Interception and Access) Act 1979 (Cth) (TIA Act). Mr Kunde noted that the TIA Act needs to be amended in two ways. Firstly, the PCCC needs to be named as an entity to whom the CCC Chair can communicate information. Secondly, the Act needs to define the permitted purposes for the Parliamentary Commissioner to use that information. The PCCC is working with the CCC and the committee on finalising a settled version to present to the Commonwealth.

CCC

The CCC presented the PCCC with the CCC’s report of activities from 1 January to 31 March 2025, focusing on key activities that were undertaken:

• the finalisation of 10 corruption investigations, which included a brief of evidence relating to fraud being referred to the Office of the Director of Public Prosecutions (DPP) for advice as to the suitability of a criminal prosecution;
• the finalisation of two major crime investigations which covered the production and trafficking of dangerous drugs, and the supplying of substances to other criminal networks and alleged money laundering involving a professional facilitator and involving the use of beneficial trusts to obscure alleged criminally derived assets;
• the use of hearing powers to assist QPS finalise one investigation into crimes against children and other vulnerable people; and
• the proceeds of crime team obtained restraining orders to the value of over $5.248 million, and a total of $6.28 million was returned to the state as forfeited property.

For the relevant period, 1,197 complaints and notifications of corruption were received, with 1,436 being assessed. The CCC received a 28 per cent increase of complaints in the 2024-2025 financial year, with a further 10 per cent increase in the 2024-2025 financial year. The CCC is currently progressing 33 investigations and has been able to reduce the number of matters under active assessment from 499 to 255, which represents a 49 per cent decrease.

On 28 March 2025, the CCC launched their corruption perceptions survey. The survey aimed at understanding the views on corruption risks, attitudes towards reporting corruption and integrity. On 9 May 2025, the survey closed with the CCC receiving 10,059 completed surveys. The breakdown of which agencies responded to the survey are as follows:

• 116 from the Queensland Police Service;
• 973 from local government;
• 5,957 from the public sector; and
• 3,013 from the community.

The CCC is aiming to analyse all the data from this survey within the next month to two months.

Justice, Integrity and Community Safety Committee

On 21 May 2025, the Office of the Queensland Integrity Commissioner (OQIC) appeared before the Justice, Integrity and Community Safety Committee. During the public hearing, Linda Waugh, the Integrity Commissioner, provided an overview of the OQIC’s 2023-2024 annual report, its functions and performance. Key highlights of the hearing include:

• the OQIC is undertaking a review of the Queensland Registered Lobbyists Code of Conduct (Code) and other lobbying matters, and have published a consultation paper setting out the key issues and questions under consideration. Ms Waugh raised that the Code has not been substantively changed since 2013, and she considers that the Code contains prescriptive requirements that would be better placed as directives, in order to keep the Code as a set of value-based standards. Submissions in response to the consultation paper are due by 5pm on 6 June 2025; and
• 66 instances of alleged non-compliance by registered lobbyists were reported to the OQIC during the reporting period. Ms Waugh gave the example of a registered lobbyist failing to enter their lobbying activities into the public register as the type of reported non-compliance referred to the OQIC. Ms Waugh highlighted that the OQIC’s approach so far had been to educate rather than taking formal action (e.g., imposing sanctions) against registered lobbyists due to the lack of formalised training registered lobbyists’ receive on obligations. Following changes to the Integrity Act 2009 (Qld), OQIC is holding its inaugural mandatory training sessions for lobbyists. Ms Waugh highlighted that following the mandatory training sessions, the OQIC will consider taking more formal action against registered lobbyists for non-compliance.

Office of the Information Commissioner Queensland

Information Privacy and Other Legislation Amendment Act 2023 (IPOLA Act) implementation update

In a recent media release, the OIC embraced news that the IPOLA Act amendments will start from 1 July 2025, except for the MNDB in local government, which will follow in 2026.

The IPOLA reforms aim to improve transparency and accountability of Queensland public sector agencies and strengthen privacy protections (covered in our April update). Information Commissioner, Joanne Kummrow, has expressed that these reforms are a positive step forward for Queensland and would ensure greater consistency with the Commonwealth Privacy Act.

In preparation for implementation, the OIC encourages agencies to do the following:

• use the ‘prepare for IPOLA’ workbook;
• refer to the draft privacy policy when agencies update their privacy policy; and
• attend upcoming training that will help agencies draft documents that support compliance with the MNBD scheme.

For more information on the roll out of the MNDB scheme, and when training will commence, please visit IPOLA training –  MNDB scheme.

Queensland Ombudsman releases Casebook on improving decision-making

In late April 2025, the Queensland Ombudsman released a casebook on Helping agencies to improve decision-making (the Casebook). The Casebook contains a sample of the outcomes the Queensland Ombudsman has achieved for Queenslanders through their investigations.

In seeking to help agencies improve their decision-making, the Casebook does the following:

• investigate administrative actions of agencies to identify at which stage/s of the decision-making process problems occurred;
• make recommendations to agencies, generally or in particular cases; and
• provide advice, training, information or other help to agencies.

The Casebook made several recommendations to improve the decision-making process of agencies, including but not limited to:

• ensuring the law needs to be applied to the facts as they stand at the time;
• ensuring a level of transparency for all processes;
• ensuring reasons for decisions are meaningful and accurate;
• ensuring investigations and recordkeeping are adequate to avoid further review;
• ensuring a decision is not made considering irrelevant information;
• ensuring all available information that can impact decision-making is considered;
• ensuring agencies correct inconsistent documents; and
• ensuring dates on correspondence relating to decisions help to clarify the decision-making path.

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Authored by: 
Daniel Maroske, Partner
Anna Fanelli, Senior Associate
Caitlin Holmes, Lawyer
Jacinta Beecher, Lawyer
Jonathan Kumar, Legal Assistant