Dear Office of The Ombudsman,

I would like to appeal the accessinfo request I made to the AFCD regarding providing a list of all the licensed ivory dealers in Hong Kong, alongside details on how much ivory each of these licensees is licensed to possess (FOI #61, made on the 29th April). This was turned down, and you can see the history here:

https://accessinfo.hk/en/request/ivory_l...

This was turned down involved because the AFCD said this would divulge personal third party information. I did not ask for personal names, just business names, so I would argue this argument is not valid. In my application for the data the AFCD also claim the data was collected for applying for a license, but that's not why they have the data, which is being held and used for administering the licensing scheme. Asking for government administrative data has to be a legitimate excuse for the code on access to information. Every other list of licenses in Hong Kong is public. For example looking in data.gov.hk, pesticide licensing gives the business and district, and restaurant licenses provide addresses of all the restaurants that have licenses. I am just requesting what is available for every other business in Hong Kong, and there is no reason an exception should be made for ivory dealers. These licenses are also required to be displayed in a conspicuous location in the shops, so its not like this is confidential. This information could easily be crowdsourced, so I just want it in a digital format.

I hope you can assist with this appeal, but please let me know if you need additional details.

Yours faithfully,

Scott Edmunds