Right to Information Guide for Myanmar iv. privacy and other legitimate private interests; v. commercial and other economic interests, be they private or public; vi. the equality of parties concerning court proceedings; vii. nature; viii. inspection, control and supervision by public authorities; ix. the economic, monetary and exchange rate policies of the state; x. the confidentiality of deliberations within or between public authorities during the internal preparation of a matter.8 The law should include a severability clause so that where only part of a document is confidential, that part should be removed and the rest of the document disclosed. There should also be presumptive overall time limits on confidentiality, for example of 20 or 30 years, after which documents become public absent a special and overriding need for continued secrecy (which should be decided through a special procedure). Finally, right to information laws should provide for consultation with third parties where information is requested which was provided by them. In this case, they may either consent to the disclosure of the information or put forward reasons why it should not be disclosed, which should be taken into account by the information officer. 4. Appeals It is clear under international law that one must have access to a decision-maker outside of the public authority when access to information is refused or other breaches of the law may have occurred. Better practice is to provide for three levels of appeal: internally, to an independent administrative body empowered with adequate powers to investigate and issue binding orders, and to the courts. The law should provide for broad grounds for appeals, basically for any violation of the rules in the law relating to the processing of requests. This should clearly include refusals or failures to provide information but also the provision of wrong or incomplete information and procedural breaches, such as a failure to respond to a request within the established time limits. In many countries, the law provides for an internal appeal to the same public authority which originally refused the request. This can be useful in terms of helping public authorities to resolve matters internally and quickly. It can also be useful because more junior officials are often nervous to disclose information, whereas senior officers are sometimes less so. In most countries, one can ultimately appeal to the courts. This is an important level of appeal because, in the end, one does need the courts to decide on more complicated and difficult questions of law, especially relating to exceptions. The more involved and probing 8 Recommendation Rec (2002)2 of the Committee of Ministers to the Member States on Access to Official Documents, para. IV, https://rm.coe.int/16804c6fcc. The Centre for Law and Democracy is a non-profit human rights organisation working internationally to provide legal expertise on foundational rights for democracy. 8