ace individuals, including children, at risk of harm. ISR 17 therefore makes it a criminal offence for an intermediary adoption agency to disclose any information in contravention of ISR 7. See Annex A. Fees: ISR 18 10.88. An intermediary agency has the discretion to charge a reasonable fee to cover any costs incurred in processing an application, including counselling. It may include any costs incurred by the agency in seeking to identify the AAA, and ascertaining the agency’s views under ISR 12, tracing the subject of the application and seeking their consent under ISR 7. The fee may be charged to the applicant or the subject of an application who is considering whether to give their consent to the disclosure of identifying information under ISR 7. 10.89. Where the subject has requested that counselling and support be provided, it is envisaged that any fees associated with providing the counselling would normally 205 be met by the applicant, as it would not be appropriate to charge the subject in connection with a service which they did not initiate. There may be circumstances where the subject would be prepared to meet those costs such as where the applicant was unable to do so themselves. 10.90. The general expectation is that the intermediary agency would normally provide the counselling itself, although it may choose to make an arrangement with any of the bodies listed at ISR 10.4 to provide counselling services on its behalf. Where the intermediary agency secures the provision of counselling by another agency on its behalf, ISR 18.2.a permits it to charge a fee to cover any reasonable costs it incurs in securing that provision. 10.91. Where the intermediary agency secures the provision of overseas counselling for a person, ISR 18.2.b permits it to charge a fee to