FREEDOM OF INFORMATION COMMISSION
OF THE STATE OF CONNECTICUT
In the Matter of a Complaint by FINAL
DECISION
Susan G. Kniep
Complainant
against Docket
#FIC 88-412
Community Development Office of the Town of East Hartford
Respondent February
8, 1989
The above-captioned
matter was heard as a contested case on November 18, 1988, at which time the
complainant and the respondent appeared, stipulated to certain facts and
presented testimony, exhibits and argument on the complaint.
After consideration of
the entire record, the following facts are found and conclusions of law are
reached:
1. The respondent is a public agency within the
meaning of §1-18a(a), G.S.
2. By correspondence dated September 21,
1988, the complainant requested that the respondent's housing rehabilitation
specialist provide her with completed contractor qualification questionnaires
for the period 1986 through 1988.
3. On October 13, 1988, the complainant
received contractor qualification forms submitted with some information thereon
masked.
4. By letter dated October 17, 1988, and
filed with the Commission on October 18, 1988, the complainant alleged that the
respondent denied her access to public records and did not respond to her
request within four business days.
5. The complainant's request was limited
to contractor customer references, supplier references, and subcontractor
references.
6. The respondent claims that the
requested records are exempt from disclosure:
a. under
§1-19(b)(5), G.S., because they are commercial or financial information given
in confidence, not required by statute;
Docket
#FIC 88-412 Page
Two
b. under
§1-19(b)(10), G.S.;
c. under
§1-19(b)(2), G.S.;
d. under
§1-19(b)(8), G.S.;
e. by
virtue of Freedom of Information Commission Advisory Opinions #58 and #52, and
§4-190, G.S.; and
f. because
if the records are not held to be exempt, prospective contractors would be
discouraged from participation in the rehabilitation program.
7. It is found that the respondent took
over 20 days to respond to the complainant's correspondence, well beyond the
four business day limitation set forth in §1-21i(a), G.S.
8. It is concluded, therefore, that the
respondent violated §1-21i(a), G.S. by failing to respond within four business
days to the complainant's request.
9. It is found that the requested records
are required by 42 United States Code §1451(d)(2), which authorizes the federal
Secretary for Housing and Urban Development to establish facilities for the
assembly, analysis and reporting of information pertaining to urban renewal
service programs.
10. It is further found that 24 Code of
Federal Regulations §511.72, promulgated in furtherance of 42 United States
Code §1451(d)(2), provides for the public disclosure of urban renewal service
program records.
11.
It is concluded that the requested records are required by statute and are
therefore not exempt from disclosure pursuant to §1-19(b)(5), G.S.
12. It is found that the requested records do
not constitute records, tax returns, reports and statements exempted by federal
law or state statutes, or commmunications privileged by the attorney-client
relationship.
13. It is concluded that the requested
records are not exempt from disclosure under §1-19(b)(10), G.S.
14. It is found that the records requested
are not personnel or similar files the disclosure of which would constitute an
invasion of personal privacy.
Docket
#FIC 88-412 Page
Three
15. It is concluded that the records are not
exempt under §1-19(b)(2), G.S.
16. The respondent failed to prove that the
records requested comprised statements of personal worth or personal financial
data required by a licensing agency and filed by an applicant with such
licensing agency to establish his personal qualification for the license, certificate or permit applied
for.
17. It is concluded that the records are not
exempt under §1-19(b)(8), G.S.
18. The Commission notes that Advisory
Opinion #58 states that a company's customer or agent lists constitute
commercial information within the meaning of §1-19(b)(5), G.S.
19. The Commission notes that Advisory
Opinion #58 additionally states that the company providing the information must
request confidentiality upon its submission, and the specific information must
not be readily available from other sources.
20. The respondent failed to prove that
during the period covered by the complainant's request, more than one
contractor demanded that its completed questionnaire be made confidential or
received assurances of confidentiality before completing the standard forms.
21. Advisory Opinion #58 also requires a
showing that a record is not required by statute, in order for §1-19(b)(5),
G.S., to apply.
22. It is concluded that even if the
requested records were confidential, this would be immaterial as they are
required by federal statute.
23. The Commission notes that Advisory
Opinion #52 ruled that an agency may release exempt information unless
prohibited by federal or state law.
24. The respondent offered no proof of any
federal or state law that forbids dissemination of the requested records.
25. It is concluded that neither Advisory
Opinion #58 nor #52 applies to exempt the requested records from disclosure.
26. It is found that §§4-190 to 4-197, G.S.,
(the Personal Data Act), do not operate to exempt the requested records from
disclosure under §§1-15 and 1-19(a), G.S.
Docket
#FIC 88-412 Page
Four
27. It is found that even if the respondent
had proved that disclosure of the requested records would discourage
contractors from participating in the program, this would not excuse the
respondent from complying with the Freedom of Information Act, nor create an
exemption thereunder.
The
following order by the Commission is hereby recommended on the basis of the
record concerning the above-captioned complaint:
1. Henceforth, the respondent shall
strictly comply with the time period specified by §1-21i(a), G.S.
2. The respondent forthwith shall provide
the complainant with a copy of each of the completed contractor qualification
questionnaires.
3. In complying with paragraph 2 of the
order, above, the respondent may mask or otherwise conceal information which,
if disclosed, would reveal information other than customer references, supplier
references and subcontractor references.
Approved
by order of the Freedom of Information Commission at its regular meeting of
February 8, 1989.
Karen
J. Haggett
Clerk
of the Commission