FREEDOM OF INFORMATION
COMMISSION
OF THE STATE OF CONNECTICUT
In the Matter of a Complaint
by FINAL DECISION
Stephen R. Corbeil
Complainant
against Docket
#FIC 94-115
Certification Unit, State of
Connecticut, Department of
Administrative Services,
Bureau of Personnel and Labor Relations
Respondent April 5, 1995
The above-captioned matter was heard as a contested
case on November 3, 1994, 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 letter
of complaint dated April 8, 1994 and filed with the Commission on April 11,
1994, the complainant appealed to the Commission alleging that the respondent
violated the Freedom of Information ("FOI") Act by denying him access
to records containing certain personal information regarding the job applicants
who sat for the Librarian I Examination No. 9310670, (hereinafter "the
examination").
3. It is
found that the complainant by letter dated March 23, 1994 requested from the
respondent access to records of the gender, age, marital status, physical
handicap, mental handicap, veteran preference, race and corresponding test
score for each applicant who sat for the examination, (hereinafter
"requested records").
4. It is
found that the respondent denied the complainant's request by letter dated
April 15, 1994 claiming that "there is no public document listing all of
the information that you request" but offered to be of further assistance
to the complainant if needed.
5. It is
found that following the April 15 denial a series of communications ensued
between the complainant and the
Docket #FIC 94-115 Page
2
respondent, following which
the respondent provided the complainant with access to a redacted copy of each
job applicant's data sheet, with their social security number and handicapped
status deleted. The respondent also
provided the complainant with a copy of the examination list containing the
names, addresses, test scores and internal ranking of each job applicant.
6. It is
found that as of the date of the hearing in this matter the only information at
issue and which the respondent has not provided to the complainant is each job
applicant's social security number and handicapped status recorded on the
applicant data sheet.
7. It is
concluded that the applicant data sheet is a public record within the meaning
of 1-18a(d) and 1-19(a), G.S.
8. The
Commission takes administrative notice of its decision in Docket #FIC 89-76,
Eric Garrison v. Supervisor, Unclaimed Property Division, State of Connecticut,
Office of the Treasurer.
9. In FIC
89-76, the Commission found that:
...social security numbers are used
by both the public and private sector for a wide range of personal
identification purposes including but not limited to use of this number for
state and federal taxpayer identification.
It is found that disclosure of social
security numbers would allow persons with knowledge of such numbers to access a
wealth of data, including personal, financial, and tax data concerning the
individual assigned that number.
The Commission notes that in the past
it has consistently declined to order disclosure of social security numbers
contained in personnel, medical or similiar files pursuant to 1-19(b)(2),
G.S, ... as such disclosure would constitute an invasion of personal privacy.
10. Similarly
here, as in FIC 89-76, it is found that the social security numbers and
handicapped status requested although not contained in the personnel, medical
or similar files of an employee as anticipated by 1-19(b)(2), G.S.,
Docket #FIC 94-115 Page 3
nonetheless, are precisely
the types of information ordinarily recorded on records contained in an
employee's personnel file.
11. It is
found that the job applicants whose social security numbers and handicapped
status are at issue are not public employees but are applicants for public
employment.
12. Under the
circumstances of this case, and in light of finding 8 and 9, above, the
Commission in its discretion declines to order the disclosure of the social security
numbers of job applicants because it would lead to an invasion of the privacy
of those persons who lack the ability to object to disclosure in this case.
13. However,
with respect to the handicapped status indicated on the applicant data sheet,
it is found that the respondent failed to prove that disclosure of the
handicapped status as indicated on the applicant data sheet is prohibited
pursuant to 42 U.S.C. 12112(c), 12112(d) and 12201(c), and
1-19(b)(12), G.S.
14. The
respondent also failed to prove that disclosure of the handicapped status as
indicated on the applicant data sheet would constitute an invasion of privacy.
15. It is
therefore concluded that the respondent did not violate the complainant's
rights when it failed to disclose the requested social security number. However, the respondent violated the
complainant's right by denying him access to the requested handicapped status
contained on the applicant data sheet.
The following order of the Commission is hereby
recommended on the basis of the record concerning the above-captioned
complaint:
1. The
complaint is dismissed with respect to the request for disclosure of the social
security numbers.
2. Forthwith,
the respondent shall provide the complainant with access to the requested
handicapped status contained on the applicant data sheet.
Approved by Order of the
Freedom of Information Commission at its special meeting of April 5, 1995.
Debra L. Rembowski
Clerk of the
Commission
Docket #FIC 94-115 Page 4
PURSUANT TO SECTION 4-180(c),
G.S. THE FOLLOWING ARE THE NAMES OF EACH PARTY AND THE MOST RECENT MAILING
ADDRESS, PROVIDED TO THE FREEDOM OF INFORMATION COMMISSION, OF THE PARTIES OR
THEIR AUTHORIZED REPRESENTATIVE.
THE PARTIES TO THIS CONTESTED
CASE ARE:
STEPHEN R. CORBEIL
356 Oak Street
East Hartford, CT 06108
CERTIFICATION UNIT, STATE OF
CONNECTICUT, DEPARTMENT OF ADMINISTRATIVE SERVICES, BUREAU OF PERSONNEL AND
LABOR RELATIONS
c/o Thomas P. Clifford III,
Esq., Assistant Attorney General,
55 Elm Street, Hartford, CT
06106-1774
Debra L. Rembowski
Clerk of the Commission