7(1)(c)
FOIAPersonal privacy
Personal privacy (records whose release would be a clearly unwarranted invasion of personal privacy)
Read the full statute text on /statutes →
Jump to the 59 issues decided under this provision, with a drafting brief ↓
19 upheld (no violation found) · 72 rejected (violation found) · 17 partial violation · 8 closed / insufficient info / other, out of 116 documents.
Not legal advice, and not a per-exemption ruling — this reflects each document's overall disposition. See the FAQ disclaimer.
How the Public Access Counselor has treated 7(1)(c)
Section 7(1)(c) exempts personal information whose disclosure would be a clearly unwarranted invasion of personal privacy. The decisions treat it as a narrow exemption that requires balancing the individual's privacy interest against the public interest in disclosure, with the public body bearing the burden to justify withholding.
In these decisions the Public Access Counselor generally rejected broad privacy claims and found violations. Termination and separation letters, disciplinary and misconduct records, officer names, candidate applications, and police and jail incident reports were ordered disclosed where the public interest outweighed privacy. Redactions were allowed only for highly sensitive details. Denial was upheld only where records concerned an alleged sexual offense against a minor.
At a glance: 116 documents from 2012 to 2026(42 binding opinions, 74 determination letters). Most often cited alongside: 7(1)(b) (Private information) (61); 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (20); 7(1)(a) (Confidential under other federal or State law) (19); 7(1)(d)(iv) (Would disclose a confidential source or informant) (11); 7(1)(d) (Law-enforcement/administrative-proceeding records) (9).
Recurring issues
- Public bodies withheld termination or separation letters of public employees as a privacy invasion. (A termination letter for a public employee, A police officer's separation records, A mayor's termination letter to a village clerk)
- Police and jail incident reports were withheld in full to protect victim or detainee privacy. (Incident reports on restraint chair use at a county jail, Police reports on a missing person's death, Police reports of a teacher's arrest for crimes against a student)
- Names and identifying details were redacted from employee misconduct, disciplinary, and attendance records. (Disciplinary records of a city employee, Names of employees in misconduct allegations, Police employee attendance records)
- Applications, emails, and internal letters related to public employment or public business were claimed to be personal or private. (An outgoing police chief's email to staff on policies, Applications for a village board vacancy, A letter requesting a vote of no confidence)
Practical points
- A public body should not withhold an entire termination letter, disciplinary file, or incident report on privacy grounds without showing disclosure would be clearly unwarranted.
- A requester seeking records about public employees or police conduct can point to the public interest in oversight as weighing against privacy withholding.
- A public body considering redactions should limit them to highly sensitive personal details rather than names, employment actions, or addresses tied to public duties.
Summary drafted from the linked decisions and checked against them; read the decisions themselves before relying on it. Not legal advice.
All 116 documents citing 7(1)(c)
- A termination letter for a public employeeBinding opinion · Violation found
Improperly withheld records
- A former official's correspondence with a contractor forwarded to an attorneyBinding opinion · Violation found
Improperly withheld records
- Incident reports on restraint chair use at a county jailBinding opinion · Violation found
Improperly withheld records
- A police officer's separation recordsBinding opinion · Violation found
Violation found
- A mayor's termination letter to a village clerkBinding opinion · Violation found
Improperly withheld records
- Records identifying officers flagged under Brady/Giglio protocolsBinding opinion · Violation found
Improperly withheld records
- Settlement agreements for legal counsel paymentsBinding opinion · Violation found
Improperly withheld records
- Police reports on a missing person's deathBinding opinion · Violation found
Improperly withheld records
- Excel file of scattered-site unit addresses and occupancy statusBinding opinion · Violation found
Improperly withheld records
- A police department's case/incident report and related recordsBinding opinion · Violation found
Improperly withheld records
- A letter requesting a vote of no confidenceBinding opinion · Violation found
Improperly withheld records
- A police report of a DUI arrest and vehicle impoundmentDetermination letter · Partial violation
Partial violation – improper redactions of driver statements and officer conduct; proper redactions of unique identifiers, dates of birth, height, and weight.
- Police reports of a teacher's arrest for crimes against a studentBinding opinion · Violation found
Improperly withheld records
- An outgoing police chief's email to staff on policiesBinding opinion · Violation found
Improperly withheld records
- Disciplinary records of a city employeeBinding opinion · Violation found
Improperly withheld records
- Applications for a village board vacancyBinding opinion · Violation found
Improperly withheld records
- Police records of uncharged sexual offense allegations against minorsBinding opinion · No violation
No violation found
- Police employee attendance recordsBinding opinion · Violation found
Violation found
- Residential parking exception letters with namesBinding opinion · Violation found
Improperly withheld records
- Names of employees in misconduct allegationsBinding opinion · Violation found
Violation found
- Applications for cannabis cultivation center licensesBinding opinion · Violation found
Improperly withheld records
- Police arrest reportsBinding opinion · Violation found
Improperly withheld records
- Redacted narrative sections of police arrest reportsBinding opinion · Violation found
Improperly withheld records
- A school district's customer account information for water utilityBinding opinion · Violation found
Violation found
- Employee salary and wage records for 2016-2017Binding opinion · Violation found
Violation found
- Settlement agreement claims with a former principalBinding opinion · Violation found
Violation found
- Misconduct complaints against a former district police officerBinding opinion · Violation found
Violation found
- A state police field report referenced in a crash reportBinding opinion · Violation found
Improperly withheld records
- Credit card and cell phone statements for elected officialsBinding opinion · Violation found
Violation found
- Contractor employee names in certified payroll recordsBinding opinion · Violation found
Violation found
- Crime scene and autopsy photographs of a death investigationBinding opinion · Violation found
Improperly withheld records
- Police officers' personal emails about a caseBinding opinion · Violation found
Violation found
- Staff bonus amounts after a fund re-allocationBinding opinion · Violation found
Violation found
- Information in a criminal complaint filed by a public figureBinding opinion · Violation found
Improperly withheld records
- A settlement agreement in a federal lawsuitBinding opinion · Violation found
Improperly withheld records
- Physician employment contracts with compensation detailsBinding opinion · Violation found
Improperly withheld records
- Surveillance video of a fatal rest-area accidentBinding opinion · Violation found
Improperly withheld records
- Settlement agreements under the personal privacy exemptionBinding opinion · Violation found
Improperly withheld records
- A public employee's résumé and job applicationBinding opinion · Violation found
Improperly withheld records
- An investigative file on a real estate agentBinding opinion · Violation found
Violation found
- Index of PAC binding opinions on FOIA since 2010Binding opinion · Other
Administrative index document
- Autopsy reports for high-profile suicide deathsBinding opinion · Violation found
Improperly withheld records
- Names of first-time freshmen and graduation statusesBinding opinion · Violation found
Improperly withheld records
- In-car traffic stop video footage on DVDDetermination letter · Violation found
Improperly assessed fees
- Audit data on railcar component originsDetermination letter · Partial violation
Partial violation found
- Prescription drug order records held by a contractorDetermination letter · Violation found
Improperly withheld records
- Correspondence between a governor's office and a former agency directorDetermination letter · Violation found
Improperly withheld records
- Correspondence about state hiring sent to a revenue departmentDetermination letter · Violation found
Improperly withheld records
- A settlement agreement and remedial warning for a tenured teacherDetermination letter · Violation found
Improperly withheld records
- University records claimed exempt under personal privacyDetermination letter · No violation
Improperly withheld records
- A school official's emails about morning announcementsDetermination letter · Violation found
Improperly withheld records
- Disciplinary records and citizen complaints for three police officersDetermination letter · Violation found
Improperly withheld records
- Attorneys' emails with factual updates to clientsDetermination letter · Violation found
Improperly withheld records
- A transit district's bus driver personnel fileDetermination letter · Partial violation
Improperly withheld records
- An exhibit to a teacher's notice to remedy resolutionDetermination letter · Violation found
Improperly withheld records
- Student enrollment counts by feeder grammar schoolDetermination letter · Violation found
Improperly withheld records
- Police reports and 9-1-1 recordings in a retail theft and homicide caseDetermination letter · Violation found
Improperly withheld records
- Records on gating Griffith Cave and Natural Heritage Database accessDetermination letter · Violation found
Improperly withheld records
- Police records of a past burglary investigationDetermination letter · Partial violation
Improperly redacted records
- An investigation of police officersDetermination letter · Violation found
Violation found
- An internal investigation into a professor's research and IRB processDetermination letter · Partial violation
Improperly withheld records
- Surveillance video of minors in a school gymnasiumDetermination letter · No violation
No violation found
- Police use-of-force reports for 2017Determination letter · Violation found
Improperly withheld records
- Campus safety incident reports and crime logsDetermination letter · Partial violation
Partial violation found
- Police reports naming the requesterDetermination letter · Violation found
Improperly withheld records
- Death investigation records and police-federal communicationsDetermination letter · Violation found
Improperly withheld records
- Records on environmental and zoning violations at a freight siteDetermination letter · Partial violation
Partial violation found
- A school district's settlement agreement with a student's familyDetermination letter · Partial violation
Partial violation found; records ordered disclosed
- Police reports on a fatal motor vehicle accidentDetermination letter · Partial violation
Closed, no further action
- Police reports and complaints about an individualDetermination letter · Partial violation
Partial violation found; records ordered released
- Communications about scheduling make-up school daysDetermination letter · Violation found
Violation found
- Police incident report for case 2019-48357Determination letter · Violation found
Improperly withheld records
- Misconduct complaint records involving two city employeesDetermination letter · Partial violation
Improperly withheld records
- Investigative records and photos of a 1992 murder caseDetermination letter · Partial violation
Partial violation found
- Audio and video recordings of a police photo arrayDetermination letter · Violation found
Improperly withheld records
- Personnel records of police, fire, and water department employeesDetermination letter · Closed no further action
Closed, no further action
- Security camera footage from a school eventDetermination letter · Partial violation
Improperly withheld records
- Invoices and purchase orders for legal servicesDetermination letter · Violation found
Improperly withheld records
- Police reports redacted for attorney-client privilegeDetermination letter · Violation found
Improperly withheld records
- Disciplinary reports from a community collegeDetermination letter · Partial violation
Partial violation found
- Complaints and investigatory findings about a public employeeDetermination letter · Violation found
Improperly withheld records
- A mayor's text messages with city officialsDetermination letter · Partial violation
Partial violation found
- Emails between four individuals over three monthsDetermination letter · Violation found
Improperly withheld records
- Parking ticket data fields from 2015 to 2022Determination letter · Violation found
Improperly withheld records
- Employee information covered by a collective bargaining agreementDetermination letter · No violation
No violation found
- Police call records for a residenceDetermination letter · No violation
No violation found
- Emails from non-city accounts used by the mayorDetermination letter · Violation found
Violation found
- A mayor's text messages with public officialsDetermination letter · No violation
No violation found
- Personnel files of three housing authority employeesDetermination letter · Violation found
Improperly withheld records
- A drainage district's maintenance assessment rolls and collector's booksDetermination letter · Violation found
Improperly withheld records
- Body-camera footage and 911 recordings of a YMCA incidentDetermination letter · No violation
No violation found
- Redacted witness information in a police crash reportDetermination letter · Closed no further action
Closed, no further action
- Police body-camera footage of a public encounterDetermination letter · Violation found
Improperly withheld records
- A summary of responses to an Invitation for ProposalsDetermination letter · Violation found
Improperly withheld records
- Application materials for a police chief finalistDetermination letter · Partial violation
Improperly withheld records
- Police dashcam and body-camera footage of a traffic stopDetermination letter · Partial violation
Partial violation found
- A city's email correspondence with union addressesDetermination letter · No violation
No violation found
- A police report withheld by a villageDetermination letter · Violation found
Improperly withheld records
- Internal communications on a property development projectDetermination letter · No violation
No violation found
- I-Pass transponder and license plate data for an individualDetermination letter · Violation found
Improperly withheld records
- A private citizen's contact details in a dog bite incident reportDetermination letter · Closed no further action
No violation found
- Police reports on named private individualsDetermination letter · No violation
No violation found
- Police body-camera footage of a private-residence incidentDetermination letter · No violation
No violation found
- Police incident report of criminal damage to a vehicleDetermination letter · No violation
No violation found
- Police records on Automated License Plate Reader data and investigationsDetermination letter · No violation
No violation found
- Witness statements in a police reportDetermination letter · Closed no further action
Closed, no further action
- Police reports and body camera footage of an incident involving a minorDetermination letter · No violation
No violation found
- Police reports on child custody incidentsDetermination letter · Closed no further action
No violation found
- Crash report with driver's personal identifiersDetermination letter · Closed no further action
Closed, no further action
- Interview questions for teacher candidatesDetermination letter · No violation
No violation found
- A police incident report involving a public official and her spouseDetermination letter · No violation
No violation found
- Unredacted police report of a medical assist incidentDetermination letter · No violation
No violation found
- Job applications and résumés of unsuccessful applicantsDetermination letter · No violation
No violation found
- Native digital files from Snap, IncDetermination letter · Closed no further action
Closed, no further action
- Investigative materials and hearing transcripts from a 2013 disciplinary orderDetermination letter · No violation
No violation found
- 911 audio recordings of a suicidal person report and crashDetermination letter · Violation found
Improperly withheld records
Issues decided under 7(1)(c)
Individual questions the Public Access Bureau decided under this provision, with the rule it applied, grouped by outcome. Extracted automatically from the letters; check each source letter.
59 issues across 39 determination letters:33 violation found · 23 no violation · 1 no determination / resolved · 2 other.
Counts are per issue, not per letter, and come from automated extraction checked against sampled letters. Determination letters are not binding precedent.
Authorities the Bureau cites most on this issue
- Chicago Journeymen Plumbers' Local Union 130 v. Department of Public Health, 327 Ill. App. 3d 192 (1st Dist. 2001) cited 10 times
- Information in a criminal complaint filed by a public figure (Pub. Acc. Op. No. 16-009) cited 7 times
- Schessler v. Department of Conservation, 256 Ill. App. 3d 198 (4th Dist. 1994) cited 7 times
- Police incident reports and 911 call records of an arrest (Pub. Acc. Op. No. 12-006) cited 5 times
- A public employee's résumé and job application (Pub. Acc. Op. No. 14-015) cited 4 times
- Lieber v. Board of Trustees of Southern Illinois University, 176 Ill. 2d 401, 407 (1997) cited 4 times
- Ill. Att'y Gen. PAC Req. Rev. Ltr. 26904 cited 3 times
- Ill. Att'y Gen. PAC Req. Rev. Ltr. 52303 cited 3 times
How to challenge a denial on this issue
AI-generated summary of the decisions listed on this page, with each point linked to the letters it comes from. Determination letters are not binding precedent and this is not legal advice. Open the letter and check the PDF before relying on any point.
When a challenge is strong
- The record concerns a public employee's job duties, qualifications, attendance, or compensation. Information bearing on public duties is not an unwarranted invasion of personal privacy under section 7(1)(c).Based on: A transit district's bus driver personnel file · Emails between four individuals over three mont… · Personnel files of three housing authority empl…
- The public body withheld an entire record instead of redacting exempt portions. The body must disclose non-exempt content after redacting private details; withholding the whole record violates FOIA.Based on: A police report withheld by a village · Disciplinary reports from a community college · A school official's emails about morning announ…
- The requested information is not highly personal (e.g., ages, business names, middle initials, license plate numbers, ticket location, hospital name). Such information does not invade personal privacy and is not exempt.Based on: Police records of a past burglary investigation · Personnel files of three housing authority empl… · Parking ticket data fields from 2015 to 2022
- The person whose information is at issue is an arrestee (not a victim, witness, or uncharged suspect). Arrestees' identities are generally not exempt under section 7(1)(c).Based on: Investigative records and photos of a 1992 murd… · 2024 · A police report of a DUI arrest and vehicle imp…
- The record involves police conduct, use of force, or an interaction on a public street. The public interest in monitoring police actions outweighs individual privacy interests.Based on: Police use-of-force reports for 2017 · Police body-camera footage of a public encounter · Security camera footage from a school event
When the public body usually wins
- The record contains dates of birth. Dates of birth are highly personal and their disclosure would be a clearly unwarranted invasion of personal privacy.Based on: Police incident reports, CAD notes, 911 audio, … · Crash report with driver's personal identifiers · Redacted witness information in a police crash …
- The record identifies crime victims, witnesses, or complainants. Disclosure of such identifying information is an unwarranted invasion of personal privacy.Based on: Police incident report of criminal damage to a … · Police reports on child custody incidents · Witness statements in a police report
- The record contains personal health information, Social Security numbers, driver's licenses, or highly personal private details. These are exempt because the privacy interest outweighs any public interest.Based on: Police reports and complaints about an individu… · Personnel files of three housing authority empl… · Athletic department correspondence with an NIL …
- The record is a police report of a private domestic incident with no arrests. The privacy interests of the individuals involved outweigh the public interest in disclosure.Based on: A police incident report involving a public off… · Police reports on named private individuals
- The record contains information about unsuccessful job applicants (other than finalists for high-level positions). Disclosure would be objectionable to a reasonable person and invade personal privacy.Based on: Job applications and résumés of unsuccessful ap… · Application materials for a police chief finali…
Points to put in your letter
- If the record relates to a public employee's job duties, state that information bearing on public duties is not exempt under 7(1)(c) and the public interest in disclosure outweighs any privacy claim.Based on: A transit district's bus driver personnel file · Emails between four individuals over three mont…
- If the body withheld entire records, argue that FOIA requires redaction of only exempt information and disclosure of the rest.Based on: A police report withheld by a village · Disciplinary reports from a community college
- If the information is not highly personal (e.g., ages, business names, middle initials), point out that such details do not constitute a clearly unwarranted invasion of personal privacy.Based on: Police records of a past burglary investigation · Personnel files of three housing authority empl…
- If you are seeking arrestee identities, note that arrestees' names are generally not exempt under the personal privacy exemption.Based on: Investigative records and photos of a 1992 murd…
- If the record involves police use of force or public interactions, emphasize the strong public interest in oversight of law enforcement.Based on: Police use-of-force reports for 2017 · Police body-camera footage of a public encounter
Common mistakes
- Assuming that all personnel records are exempt from disclosure.Based on: A transit district's bus driver personnel file
- Believing that dates of birth are not private and must be disclosed.Based on: Police incident reports, CAD notes, 911 audio, … · Crash report with driver's personal identifiers
- Thinking that victim or witness identities must be disclosed because they appear in police reports.Based on: Police incident report of criminal damage to a … · Witness statements in a police report
- Failing to request that the body redact exempt portions instead of withholding the entire record.Based on: A police report withheld by a village · Disciplinary reports from a community college
- Assuming that because records were used in court, the privacy exemption is lost.Based on: Investigative records and photos of a 1992 murd…
Facts to gather first
- Whether the person is a public employee and the record relates to their public duties.
- Whether the record contains dates of birth, health information, or victim/witness identities.
- Whether the incident resulted in an arrest.
- Whether the public body withheld entire records or only redacted portions.
- Whether the information is already public or was used in court (though court use does not waive the exemption).
These determination letters are non-binding, and outcomes depend on specific facts. Always verify the current version of the PDF decisions for full context.
Drafting brief for an AI assistant
Copy this into your assistant to help draft a request, appeal, or challenge to a denial that turns on this issue. It carries the rules and decisions, not your facts: add those yourself. Machine-readable version: foia-7-1-c.json.
Violation found (33)
Redaction of decedent's 911 call statements
Rule: The Sheriff's Office failed to prove by clear and convincing evidence that the decedent's statements in the 911 recording are exempt under section 7(1)(c), because the public interest in disclosure outweighs the asserted privacy interests.
Violation found 911 audio recordings of a suicidal person report and crash · January 13, 2026
Section 7(1)(c) personal privacy exemption for toll records
Rule: Toll records of a public employee's publicly funded commuting bear on public duties and are not a clearly unwarranted invasion of personal privacy.
Violation found I-Pass transponder and license plate data for an individual · December 31, 2024
Improper withholding of entire police report under FOIA section 7(1)(c)
Rule: A public body may not withhold an entire police report when non-exempt portions describing officers' activities can be disclosed after redacting identifying information and highly personal details.
Violation found A police report withheld by a village · December 30, 2024
Withholding police chief finalist's application materials under 7(1)(c)
Rule: Publicly identified finalist for police chief is not a mere pending applicant; public interest in his qualifications outweighs privacy, so exemption does not apply.
Violation found Application materials for a police chief finalist · November 21, 2023
Withholding transitory emails with general status updates under 7(1)(c)
Rule: General status updates about selection process are not highly personal and their disclosure would not constitute a clearly unwarranted invasion of personal privacy.
Violation found Application materials for a police chief finalist · November 21, 2023
Redaction under section 7(1)(c) for personal privacy
Rule: Section 7(1)(c) does not permit blurring the identity of an individual who interacted with officers on a public street.
Violation found Police body-camera footage of a public encounter · October 4, 2023
Employment applications, resumes, and references
Rule: Employment and educational histories, references, and application materials bear on public employees' qualifications and are not exempt under section 7(1)(c).
Violation found Personnel files of three housing authority employees · June 23, 2023
Academic transcripts and course records
Rule: Academic transcripts and course records paid for by a public body relate to public duties and are not exempt under section 7(1)(c).
Violation found Personnel files of three housing authority employees · June 23, 2023
Employee retirement investment elections
Rule: The Housing Authority did not demonstrate that redactions in the Checklist for Retirement Program Enrollment are highly personal and exempt under section 7(1)(c).
Violation found Personnel files of three housing authority employees · June 23, 2023
Middle initials of employee names
Rule: Middle initials are not highly personal information, and the public interest in full names of public employees outweighs privacy, so they are not exempt under section 7(1)(c).
Violation found Personnel files of three housing authority employees · June 23, 2023
Redaction of e-mail under section 7(1)(c)
Rule: The public body must disclose portions of the e-mail where the public interest outweighs the minor privacy invasion, redacting only highly personal details.
Violation found Emails from non-city accounts used by the mayor · March 17, 2023
Withholding ticket location and license plate numbers under section 7(1)(c)
Rule: The Department did not establish that disclosure would be highly personal or objectionable, so the privacy exemption does not apply.
Violation found Parking ticket data fields from 2015 to 2022 · March 2, 2023
Redaction of employee name under 7(1)(c)
Rule: Information bearing on public employees' public duties is not an unwarranted invasion of personal privacy and cannot be withheld under 7(1)(c).
Violation found Emails between four individuals over three months · July 18, 2023
Whether redactions under section 7(1)(c) were proper
Rule: Personal information is exempt only if disclosure would be a clearly unwarranted invasion of privacy, but information bearing on public duties is not exempt.
Violation found A mayor's text messages with city officials · March 23, 2022
Withholding complaint records under section 7(1)(c)
Rule: Complaints about public employees' job-related misconduct are not wholly exempt under 7(1)(c), but complainant-identifying information may be redacted.
Violation found Complaints and investigatory findings about a public employee · June 8, 2022
Withholding entire RADAR and police reports under 7(1)(c) and 7(1)(d)(iv)
Rule: A public body must redact exempt information and disclose the remaining non-exempt content; it cannot withhold records in their entirety when they contain non-exempt information.
Violation found Disciplinary reports from a community college · December 2, 2021
Section 7(1)(c) personal privacy exemption
Rule: The video bears on a public employee's duties, so it is not exempt in its entirety, though student images may be redacted.
Violation found Security camera footage from a school event · April 19, 2022
Redaction of arrestee names from witness statements
Rule: Arrestees' identities are generally not exempt under section 7(1)(c), and the Department did not show that disclosing them would unavoidably identify witnesses.
Violation found Investigative records and photos of a 1992 murder case · November 21, 2024
Section 7(1)(c) redactions in Elias email
Rule: Information bearing on public duties is not exempt under 7(1)(c), so the City improperly redacted portions of the Elias email.
Violation found Misconduct complaint records involving two city employees · August 31, 2020
Section 7(1)(c) redactions in Fuller letter
Rule: Information bearing on public duties is not exempt under 7(1)(c), so the City improperly redacted portions of the Fuller letter.
Violation found Misconduct complaint records involving two city employees · August 31, 2020
Redaction of treating hospital name
Rule: The name of a treating hospital or medical facility is standard nondescript information that does not constitute personal information and its disclosure would not cause an unwarranted invasion of personal privacy.
Violation found Police reports and complaints about an individual · May 25, 2023
Redactions under personal privacy exemption
Rule: The District failed to prove that certain redacted information was exempt under section 7(1)(c) because it was not highly personal or attributable to a particular student.
Violation found A school district's settlement agreement with a student's family · December 15, 2023
Section 7(1)(c) personal privacy redaction
Rule: Public interest in police use of force outweighs privacy, but names of non-arrested subjects and identifying details may be redacted.
Violation found Police use-of-force reports for 2017 · September 13, 2018
Redaction of ages and business names under 7(1)(c)
Rule: Ages and names of businesses are not exempt under section 7(1)(c) because they do not invade personal privacy.
Violation found Police records of a past burglary investigation · April 17, 2018
Notice to remedy not exempt as personal information under FOIA 7(1)(c)
Rule: Information bearing on public duties of public employees is not an unwarranted invasion of personal privacy, so the notice to remedy must be disclosed.
Violation found An exhibit to a teacher's notice to remedy resolution · September 13, 2017
Personnel file withheld in entirety under section 7(1)(c)
Rule: The current personal privacy exemption uses a balancing test, not a per se personnel file exemption, so records bearing on public duties must be disclosed.
Violation found A transit district's bus driver personnel file · April 13, 2018
Job application, resume, and employment history
Rule: Records bearing on a public employee's qualifications for employment are not exempt under section 7(1)(c).
Violation found A transit district's bus driver personnel file · April 13, 2018
Driver's license status and class
Rule: Information about whether a bus operator possessed a non-expired driver's license and the class of license bears on public duties and is not exempt.
Violation found A transit district's bus driver personnel file · April 13, 2018
Attendance and absence records
Rule: Records detailing a public employee's attendance or absences relate to public duties and are not exempt under section 7(1)(c).
Violation found A transit district's bus driver personnel file · April 13, 2018
Accrued time off
Rule: Accrued time off is part of a public employee's compensation and relates to the use of public funds, so it is not exempt.
Violation found A transit district's bus driver personnel file · April 13, 2018
Payroll and wage information
Rule: Payroll and wage information relates to the use of public funds and is not exempt under section 7(1)(c).
Violation found A transit district's bus driver personnel file · April 13, 2018
Employee's place of birth
Rule: The District did not sustain its burden to show the employee's place of birth is exempt under section 7(1)(c).
Violation found A transit district's bus driver personnel file · April 13, 2018
Withholding parent emails under section 7(1)(c)
Rule: Records containing highly personal information must be redacted to prevent identification; if redaction is possible, the records are not exempt in their entirety.
Violation found A school official's emails about morning announcements · June 30, 2016
No violation (23)
Denial of unsuccessful applicants' applications and résumés under 7(1)(c)
Rule: Records identifying pending or unsuccessful applicants for public employment are exempt under section 7(1)(c) because disclosure would be objectionable to a reasonable person and invade personal privacy.
No violation Job applications and résumés of unsuccessful applicants · September 9, 2025
Redaction of personal information under 7(1)(c)
Rule: Disclosure of highly personal information about an unresponsive person without written consent would cause a clearly unwarranted invasion of personal privacy.
No violation Unredacted police report of a medical assist incident · May 13, 2025
Withholding police report under section 7(1)(c)
Rule: A police report of a domestic incident with no arrests or public-duty connection is exempt under section 7(1)(c) because privacy interests outweigh the public interest.
No violation A police incident report involving a public official and her spouse · April 21, 2025
Withholding driver's date of birth as personal information
Rule: An individual's birth date is highly personal, and the right to privacy outweighs any legitimate public interest in disclosure.
No violation Crash report with driver's personal identifiers · March 27, 2025
Redaction of personal information from police reports
Rule: A public body may redact personal information when disclosure would constitute a clearly unwarranted invasion of personal privacy, including the identity and statements of a police complainant.
No violation Police reports on child custody incidents · March 17, 2025
Redaction of dates of birth from report and CAD notes
Rule: Disclosure of a person's date of birth constitutes a clearly unwarranted invasion of personal privacy under section 7(1)(c).
No violation Police incident reports, CAD notes, 911 audio, and body-camera footage of an arrest · April 10, 2025
Redaction of complainant identity and statements under 7(1)(c)
Rule: Disclosing the identity of a person who complains to police, or the information they provided, is an unwarranted invasion of personal privacy even if the requester alleges false reports.
No violation Witness statements in a police report · February 14, 2025
Denial of victim-identifying records under personal privacy exemption
Rule: Disclosure of information identifying a criminal offense victim is a clearly unwarranted invasion of personal privacy, so the body may deny or redact such records.
No violation Police incident report of criminal damage to a vehicle · June 6, 2025
Withholding police reports under section 7(1)(c)
Rule: Police reports of a private incident with no arrests may be withheld in full under section 7(1)(c) because disclosure would be a clearly unwarranted invasion of personal privacy.
No violation Police reports on named private individuals · October 2, 2024
Redaction of one line of highly personal information
Rule: A record is exempt under section 7(1)(c) if it is highly personal, the subject's privacy outweighs the public interest, and it does not concern public business.
No violation Athletic department correspondence with an NIL group · November 22, 2024
Withholding transitory emails containing other candidates' information under 7(1)(c)
Rule: Disclosure of information identifying unsuccessful applicants would constitute an unwarranted invasion of personal privacy.
No violation Application materials for a police chief finalist · November 21, 2023
Redaction of witness birth dates
Rule: Dates of birth are exempt from disclosure under section 7(1)(c) as personal information whose disclosure would be an unwarranted invasion of personal privacy.
No violation Redacted witness information in a police crash report · February 6, 2023
Salary history information
Rule: Private sector salary history is highly personal and not subject to disclosure, but public sector salary history is subject to disclosure under section 2.5 of FOIA.
No violation Personnel files of three housing authority employees · June 23, 2023
Participant Direction of Investment and benefit elections
Rule: Personal financial decisions and benefit elections, including dependents, are highly personal and exempt under section 7(1)(c).
No violation Personnel files of three housing authority employees · June 23, 2023
Social Security cards and driver's licenses
Rule: Social security cards and driver's licenses are exempt in whole under section 7(1)(c) because disclosure would compromise identity for identity theft.
No violation Personnel files of three housing authority employees · June 23, 2023
Redaction of names and dates of birth under section 7(1)(c)
Rule: Disclosure of names of uncharged suspects, witnesses, and third parties, and dates of birth, would constitute a clearly unwarranted invasion of personal privacy.
No violation Police call records for a residence · October 16, 2022
Redaction of witness and third-party identities under section 7(1)(c)
Rule: Disclosure of identities of third parties incidentally mentioned in police reports constitutes a clearly unwarranted invasion of personal privacy, and the exemption is not lost because records were used in court.
No violation Investigative records and photos of a 1992 murder case · November 21, 2024
Permissible redaction of non-arrestee lineup photos
Rule: The City may redact photos or identifying information of individuals in lineup photos who were not arrested.
No violation Police incident report for case 2019-48357 · March 11, 2020
Redaction of personal health information
Rule: Information identifying an individual as having a physical or mental health issue is highly personal and its disclosure would cause a substantial invasion of personal privacy.
No violation Police reports and complaints about an individual · May 25, 2023
Redaction of victim and third-party identifying information under 7(1)(c)
Rule: Disclosure of victim and third-party identifying information would constitute a clearly unwarranted invasion of personal privacy and is exempt.
No violation Police records of a past burglary investigation · April 17, 2018
Employee's birth date
Rule: An employee's birth date is exempt from disclosure under section 7(1)(c).
No violation A transit district's bus driver personnel file · April 13, 2018
Emergency contact names
Rule: The names of emergency contacts are personal information that may be redacted under section 7(1)(c).
No violation A transit district's bus driver personnel file · April 13, 2018
Withholding personal emails under section 7(1)(c)
Rule: Emails unrelated to public duties that are highly personal are exempt when the individual's privacy right outweighs any public interest in disclosure.
No violation Correspondence between a governor's office and a former agency director · March 31, 2016
No determination / resolved (1)
Permissible redaction of dates of birth
Rule: Dates of birth may be redacted because disclosure would constitute a clearly unwarranted invasion of personal privacy.
No determination / resolved An investigation of police officers · June 27, 2018
Other (2)
Redaction under section 7(1)(c) for personal privacy
Rule: The minor's identifying information, dates of birth, and arrestee's height and weight were properly redacted, but the arrestee's statements and police conduct were not exempt as there is a legitimate public interest in DUI arrests.
Other A police report of a DUI arrest and vehicle impoundment · August 21, 2024
Redaction of inmate-identifying information from responsive records
Rule: Identifying information may be redacted because disclosure would constitute an unwarranted invasion of personal privacy.
Other Prescription drug order records held by a contractor · January 13, 2016