Targeted Compliance Failures: 2024 APM Demerit Reversals and Grounds for CDDA Compensation.
Two Demerits Removed, But What Happened to the Records?
APM confirmed two historical compliance events and their subsequent removal. The next question is what happened to the decisions, case notes and audit trails behind them.
DEWR complaint CAS-2634696-N6Q0V3
The correction that raises another question
On 22 October 2026, APM Employment Services confirmed two events in my historical job-search compliance record: one dated 15 September 2023 and another dated 15 January 2024.
APM stated that both demerits had subsequently been removed.
That confirmation matters. A changed compliance outcome is not necessarily the end of the record. The original decisions, reasons for removal, related case notes and any information passed to government systems are separate matters that can be examined.
APM indicated that its complaint process was finalised. I am now seeking the underlying records rather than another generic assurance that the matter has been answered.
What APM actually said
In its 22 October 2026 response, APM's Compliments and Complaints team confirmed the two event dates and that both demerits had been removed.
Its central statement was:
"Both demerits were subsequently removed."
APM described the events as relating to job-search requirements and stated that it had no further information to provide on the matters.
It also treated its complaint handling as finalised.
The response did not supply the original evidence for either event, the date or reasons for each removal, or a record of whether associated information was corrected elsewhere.
Those are the questions at the centre of this investigation.
APM also stated that Job Capacity Assessments were conducted by Centrelink rather than APM.
In relation to a separate dispute concerning The Loft Café, APM said its records did not indicate communication with the café about the end of my employment.
These are APM's positions, recorded here so the relevant record holders can be identified and asked to respond.
The chronology
| Date | Recorded event |
|---|---|
| 15 September 2023 | First job-search compliance event, subsequently removed according to APM. |
| 15 January 2024 | Second job-search compliance event, subsequently removed according to APM. |
| 22 October 2026 | APM confirms both events and their removal. |
| 24 October 2026, 5:36 am AEDT | Personal-information access request sent to APM Privacy. |
| 24 October 2026, 10:26 am AEDT | Formal follow-up to DEWR and APM under complaint reference CAS-2634696-N6Q0V3. |
| 27 October 2026 | DEWR responds, records the feedback and requests proof of identity and consent for complaint referral and investigation. |
The dates correct an earlier description of "two 2024 demerits". The events occurred in two different years.
The January 2024 access request
APM also addressed an earlier request for personal information.
According to its account, it provided instructions on 2 February 2024 for an access form, but did not receive the completed form and therefore did not release records through that process.
That is the provider's explanation. The relevant questions are whether the original request and instructions can be produced, which records remain held, and how access can now be completed.
What I requested from APM on 24 October
At 5:36 am AEDT on 24 October 2026, I sent a renewed personal-information access request to APM Privacy.
The requested material included:
- Original compliance event records, reasons and associated job-search requirements.
- Staff or system identifiers associated with the entries.
- The decisions, dates and reasons for removing both demerits.
- Audit histories and changes to case notes or compliance flags.
- Relevant communications with government agencies and any payment or compliance consequences.
- Record-retention information and the identity of the responsible custodian if records are no longer held by APM.
Removing an entry from a visible compliance tally and correcting every associated record are not necessarily the same operation.
The documents will establish what occurred here.
What DEWR said on 27 October
On 27 October 2026, Graeme, a Feedback and Complaints Officer in the Department of Employment and Workplace Relations' National Customer Service Line, responded to my correspondence.
The department confirmed that my feedback had been recorded under CAS-2634696-N6Q0V3.
"Your feedback has been recorded in our feedback system with reference number CAS-2634696-N6Q0V3."
DEWR explained that a person seeking records held by their employment-services provider should first approach the provider under the Privacy Act 1988, and said the provider was required to respond within 30 days.
It also identified the department's Freedom of Information process as an avenue for obtaining relevant departmental records.
For the complaint itself, DEWR described a referral process under which the provider reviews the matter and reports its actions to the department.
DEWR requested proof of identity and consent before proceeding with complaint registration and investigation through that process.
In my 24 October follow-up, I also requested the underlying records of disputed assessment coding, clarification of which agency owns Job Capacity Assessment information, preservation of records concerning The Loft Café, and an explanation of how complaint closure differs from substantive examination of contested records.
Automation: a question for the audit trail
Digital employment-services systems record requirements, compliance events and corrections.
But the fact that a demerit was entered and later removed does not establish whether either decision was made automatically or by a human officer.
That is precisely why I have requested the audit history: which person or system entered each event, what information was considered, who authorised its removal and whether the correction propagated to other records.
The records, rather than speculation about an algorithm, should answer those questions.
Could compensation be relevant?
The Commonwealth's Scheme for Compensation for Detriment caused by Defective Administration (CDDA) may be relevant where defective Commonwealth administration has caused identifiable detriment.
Its application to the actions of a contracted provider and the facts of this case would need to be assessed.
Three matters require evidence:
- Who was responsible for the relevant action.
- What administrative defect, if any, occurred.
- What loss or other compensable detriment was caused by that defect.
The removal of the demerits alone does not establish a compensation entitlement.
The original decisions, their correction history and any payment-impact records are the logical next exhibits.
The unanswered questions
- What evidence and requirements were relied on for each compliance event?
- Who or what entered each event, and who reviewed it?
- When and why was each demerit removed?
- Were related case notes, flags and downstream records corrected?
- Did either event affect income-support payments or later decisions?
- What records will APM and DEWR release, and what substantive response will follow?
Removing a demerit changes the visible outcome. The outstanding question is whether the record behind that outcome was examined and corrected too.
Source correspondence
APM, 22 October 2026: Written response confirming the two compliance events and their subsequent removal.
APM Privacy request, 24 October 2026: Request for original records, removal decisions, audit histories and related consequences.
DEWR follow-up, 24 October 2026: Written request for examination of original records, assessment coding and agency responsibility.
DEWR, 27 October 2026: National Customer Service Line response under CAS-2634696-N6Q0V3, explaining access and complaint-referral procedures and requesting identity verification and consent.
APM response [TS-PRIV-001] · Privacy request [TS-PRIV-002] · DEWR response and embedded 24 October follow-up [TS-PRIV-003]
