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  <title>Illinois FOIA &amp; OMA Reference: 7(1)(g)</title>
  <link href="https://illinoisfoia.org/exemptions/7-1-g/feed.xml" rel="self"/>
  <link href="https://illinoisfoia.org/exemptions/7-1-g/"/>
  <id>https://illinoisfoia.org/exemptions/7-1-g/</id>
  <updated>2026-06-09T00:00:00Z</updated>
  <entry>
    <title>Master index of all PAC FOIA opinions issued since 2010</title>
    <link href="https://illinoisfoia.org/opinions/10-001-2/"/>
    <id>https://illinoisfoia.org/opinions/10-001-2/</id>
    <updated>2026-06-09T00:00:00Z</updated>
    <summary>This document is not a legal decision, but rather a master list or index of all binding opinions issued by the Illinois Attorney General's Public Access Counselor since 2010. It is intended to help the public and legal professionals find specific past rulings on Freedom of Information Act (FOIA) issues.</summary>
  </entry>
  <entry>
    <title>University of Illinois properly withheld police training curriculum as educational records under 7(1)(j)(iv)</title>
    <link href="https://illinoisfoia.org/opinions/letter-88300/"/>
    <id>https://illinoisfoia.org/opinions/letter-88300/</id>
    <updated>2025-10-07T00:00:00Z</updated>
    <summary>A requester asked the University of Illinois for police training curriculum and lesson plans. The University refused to release them, claiming they were protected educational records. The Attorney General's office agreed with the University, concluding that the records are exempt from disclosure because they are used by faculty for educational purposes.</summary>
  </entry>
  <entry>
    <title>Village of Hanover Park improperly withheld business lease agreements under 7(1)(g)</title>
    <link href="https://illinoisfoia.org/opinions/letter-77566/"/>
    <id>https://illinoisfoia.org/opinions/letter-77566/</id>
    <updated>2024-04-10T00:00:00Z</updated>
    <summary>A resident requested copies of business leases submitted to the Village of Hanover Park, but the Village refused to provide them, claiming they were exempt from disclosure. The Attorney General's office reviewed the documents and found that the Village's denial was incorrect. The Village must now release the leases to the requester, though they are allowed to black out personal signatures.</summary>
  </entry>
  <entry>
    <title>Non-disclosure Agreement Concerning Planned Commercial Development Project That Has Been Publicly Announced is Not Exempt Under Section 7(1)(g) of FOIA</title>
    <link href="https://illinoisfoia.org/opinions/2023-pac-77982/"/>
    <id>https://illinoisfoia.org/opinions/2023-pac-77982/</id>
    <updated>2023-12-12T00:00:00Z</updated>
    <summary>The requester, a newspaper reporter, sought a non-disclosure agreement between a city and a company concerning a development project, which the city withheld as confidential commercial information. The Public Access Counselor held that although the agreement was commercial and treated as confidential, neither the city nor the company demonstrated that disclosure would cause competitive harm as the exemption requires, particularly given that the project's existence had already been publicly annou</summary>
  </entry>
  <entry>
    <title>Community High School District No. 99 Lawfully Withheld Sexual Harassment Training Under 7(1)(g)</title>
    <link href="https://illinoisfoia.org/opinions/letter-56208/"/>
    <id>https://illinoisfoia.org/opinions/letter-56208/</id>
    <updated>2022-12-09T00:00:00Z</updated>
    <summary>A requester asked for a school district's sexual harassment training presentation, but the district refused to release it, arguing it contained confidential trade secrets. The Attorney General's office reviewed the document and agreed that the district was legally allowed to keep the information private. As a result, the case is closed and the records will not be released.</summary>
  </entry>
  <entry>
    <title>Records Directly Related to Providing Medical Care to Inmates in Possession of Third Party Contracted to Provide Medical Care to Inmates are Public Records of Illinois Department of Corrections</title>
    <link href="https://illinoisfoia.org/opinions/2020-pac-62579/"/>
    <id>https://illinoisfoia.org/opinions/2020-pac-62579/</id>
    <updated>2020-07-27T00:00:00Z</updated>
    <summary>The requester sought aggregate data on inmate head injuries and related medical-evaluation policies from a state prison agency, which said it did not possess the records and that its outside healthcare contractor had refused to provide its policies, claiming they were confidential trade secrets. The Public Access Counselor held that records held by a contractor performing a governmental function on the agency's behalf are public records of the agency, and that the agency failed to prove the cont</summary>
  </entry>
  <entry>
    <title>City of Chicago Mayor's Office properly withheld investment bank pitchbooks under 7(1)(g)</title>
    <link href="https://illinoisfoia.org/opinions/letter-56600/"/>
    <id>https://illinoisfoia.org/opinions/letter-56600/</id>
    <updated>2020-06-30T00:00:00Z</updated>
    <summary>The requester sought investment-bank marketing materials (pitchbooks) submitted to the mayor's office about potential municipal bond sales, which the office withheld as confidential commercial information. The PAC determined that the pitchbooks contained commercial information furnished under a claim of confidentiality and that disclosure would cause competitive harm to the firms that submitted them by revealing their unique marketing approaches and methods. The office's withholding did not viol</summary>
  </entry>
  <entry>
    <title>Illinois Department of Healthcare and Family Services improperly withheld MCO cost reports under 7(1)(g)</title>
    <link href="https://illinoisfoia.org/opinions/letter-56759/"/>
    <id>https://illinoisfoia.org/opinions/letter-56759/</id>
    <updated>2019-12-19T00:00:00Z</updated>
    <summary>A consultant requested financial cost reports from the state's Medicaid managed care organizations, but the Department of Healthcare and Family Services refused to release them, claiming they were trade secrets. The Attorney General's Public Access Counselor reviewed the request and found that the Department did not provide a valid legal reason to keep the documents secret. Consequently, the Department was asked to release the records to the requester.</summary>
  </entry>
  <entry>
    <title>Reports of Manganese Throughputs Submitted to a City Public Health Department Are Not Exempt From Disclosure under Section 7(1)(g) of FOIA</title>
    <link href="https://illinoisfoia.org/opinions/2019-pac-58468/"/>
    <id>https://illinoisfoia.org/opinions/2019-pac-58468/</id>
    <updated>2019-09-23T00:00:00Z</updated>
    <summary>The requester, an environmental law clinic, sought a company's manganese throughput reports filed with a city health department, which the department withheld as confidential commercial information that could cause the company competitive harm. The Public Access Counselor held that although the reports were commercial information submitted under a claim of confidentiality, the department failed to prove by clear and convincing evidence that disclosure would actually cause competitive harm, since</summary>
  </entry>
  <entry>
    <title>Improper Denial of a Request for Records as an Unduly Burdensome Repeated Request; Financial Terms Related to a Public Body's Use of Public Funds Are Not Exempt under Section 7(1)(g) of FOIA</title>
    <link href="https://illinoisfoia.org/opinions/2018-pac-52443/"/>
    <id>https://illinoisfoia.org/opinions/2018-pac-52443/</id>
    <updated>2018-07-11T00:00:00Z</updated>
    <summary>The requester, a physician, sought a contract amendment showing the fixed monthly rate a county health system paid a mental health provider per enrollee, records she had previously been given in redacted form; the county system denied her renewed request as an unduly burdensome repeated request. The Public Access Counselor held that a repeated-request denial requires the agency to have already properly provided or denied the same records, which the county system had not done, and separately held</summary>
  </entry>
  <entry>
    <title>Third Party Cost Records Submitted to a City Related to a City-Funded Redevelopment Project Are Not Exempt - From Disclosure under Section 7(1)(g) of FOIA</title>
    <link href="https://illinoisfoia.org/opinions/2017-pac-50559/"/>
    <id>https://illinoisfoia.org/opinions/2017-pac-50559/</id>
    <updated>2018-03-06T00:00:00Z</updated>
    <summary>The requester, a newspaper reporter, sought a private developer's project budget that the developer had submitted to the city to justify a public redevelopment-assistance payment, and the city withheld the budget in full as commercial and financial information furnished in confidence. The Public Access Counselor held that the developer had not shown it submitted the budget under an express claim of confidentiality at the time it was furnished -- a letter asserting confidentiality only after the </summary>
  </entry>
  <entry>
    <title>Financial Terms of Contracts, Billing Invoices, and Budget Documents Related to a Public Body's Use of Public Funds Are Not Exempt under Section 7(1)(g) of FOIA</title>
    <link href="https://illinoisfoia.org/opinions/2017-pac-46400/"/>
    <id>https://illinoisfoia.org/opinions/2017-pac-46400/</id>
    <updated>2017-05-26T00:00:00Z</updated>
    <summary>The requester, a city clerk, sought contracts, invoices, and annual budgets involving the sanitary district's private wastewater-management contractor, and the district redacted substantial financial terms, invoice amounts, and budget figures, citing a confidentiality clause in its contract and the commercial-information exemption. The Public Access Counselor held that the confidentiality clause did not apply because none of the information had been marked confidential as the clause required and</summary>
  </entry>
  <entry>
    <title>University of Illinois properly withheld animal medical records but improperly redacted protocol names</title>
    <link href="https://illinoisfoia.org/opinions/letter-35091/"/>
    <id>https://illinoisfoia.org/opinions/letter-35091/</id>
    <updated>2015-07-14T00:00:00Z</updated>
    <summary>The requester sought an animal's medical and research records from a public university, which withheld the animal's medical records entirely and redacted portions of the related research protocol. The PAC determined the medical records were properly exempt as research materials, but that the university had not shown that the names of individuals, departments, companies, and buildings in the protocol, or the sponsor's identity and the drug or device name, met any claimed exemption, and that only </summary>
  </entry>
  <entry>
    <title>Home Rule Ordinance Does Not Supersede FOIA; Negotiated Terms of Contracts with Public Bodies Do Not Constitute Trade Secrets; Correspondence With Third Parties Is Not Part of A Public Body's Deliberative Process</title>
    <link href="https://illinoisfoia.org/opinions/2014-pac-31746/"/>
    <id>https://illinoisfoia.org/opinions/2014-pac-31746/</id>
    <updated>2015-01-23T00:00:00Z</updated>
    <summary>The requester, a journalist, sought records related to a touring musician's concerts at a village-owned entertainment venue, including contracts, correspondence, and financial terms with the concert promoter, and the village government withheld ticket-pricing emails and rental/revenue figures, citing the deliberative-process and trade-secret exemptions and, later, a home-rule ordinance it passed after the request was denied. The Public Access Counselor held that the village's ordinance could not</summary>
  </entry>
  <entry>
    <title>Records Documenting Public Funds Paid to Entities Pursuant to Contracts For Performance of A Governmental Function Are Subject to Disclosure</title>
    <link href="https://illinoisfoia.org/opinions/2014-pac-28485/"/>
    <id>https://illinoisfoia.org/opinions/2014-pac-28485/</id>
    <updated>2014-06-30T00:00:00Z</updated>
    <summary>The requester sought copies of the state lottery agency's marketing and advertising contracts, specifically the pricing structure and hourly rates, but the agency's private lottery manager redacted the financial terms, citing exemptions for information barred by other state law and for confidential commercial/financial information that could cause competitive harm. The PAC held that neither exemption applied: the financial terms did not qualify as &quot;confidential data&quot; under the Lottery Law's narr</summary>
  </entry>
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