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PREPARING FOR IMPLEMENTATION

Appointing Officers to RTI Positions: Assistant Public Information Officers

Section 5(2) of the Central Act requires the appointment of Assistant Public Information Officers (APIOs) "at each sub-divisional level or other sub-district level" at the Centre and in all States.

These APIOs are given the responsibility of receiving applications and forwarding them on to the relevant Public Information Officer.

APIOs are not responsible under the law for actually processing an application - although, of course, if they hold the information and can easily supply it to the requester the should. Under the Central Act though, they are simply required to act like mailboxes - they receive applications and appeals and then distribute them to the relevant PIO. This means that APIOs do not need to be senior officers with authority to make decisions. They simply need to be well organised and trustworthy, so that they can discharge their duties under the Central Act in a timely, efficient manner.

Notably, there has been some confusion as to whether the Central Act requires the appointment of APIOs by every public authority or if one APIO can be appointed in each district who will be responsible for forwarding application to any and all public authorities. Ideally, the nodal agency responsible for implementation at the Centre and in the States should issue guidelines clarifying what is required. If the nodal agency has not issued guidelines you should consider contacting them for guidance.

If your organisation only has a small staff and is not represented at the sub-divisional or sub-district level, you may also want to consider negotiating with another body covered by the Central Act to use their APIO to collect and forward applications and appeals for your organisation. This will serve the additional purpose of reducing bureaucratic red tape and training requirements for APIOs.