I guess what I was trying to drive at was if we remove proposed paragraph 6.1(1)(a), the department can refuse if (a), (b), and (c) are not provided. You're saying they won't, but under the legislation they appear to be able to. But if we were to keep proposed paragraph 6.1(1)(a) and add that the Information Commissioner had the discretion to grant the ability to refuse, that would seem to be more protection.
Again, though, maybe I'm wrong.