7(1)(o)

FOIA

Data-processing/IT security information

Read the full statute text on /statutes →

Jump to the 4 issues decided under this provision, with a drafting brief ↓

2 upheld (no violation found) · 0 rejected (violation found) · 2 partial violation · 1 closed / insufficient info / other, out of 5 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)(o)

Section 7(1)(o) covers administrative and technical information associated with automated data processing operations. In these decisions, it was invoked for system user guides and manuals, such as an ALPR system user guide and an internal software manual, and for data embedded in proprietary assessment software. The PAC has described this material as per se exempt from disclosure when it falls within the exemption.

The PAC has generally sustained withholding where the record was shown to be that type of technical or software-embedded information. At the same time, it has treated related issues separately, including whether case reports were properly provided, whether other exemptions supported redactions to correspondence, and whether a request would require creating new records or answering questions rather than producing existing records.

At a glance: 5 documents from 2025(0 binding opinions, 5 determination letters). Most often cited alongside: 7(1)(b) (Private information) (2); 7(1)(a) (Confidential under other federal or State law) (1); 7(1)(c) (Personal privacy) (1); 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (1).

Recurring issues

Whether law enforcement system user guides and internal software manuals are exempt as administrative and technical information associated with automated data processing. (ALPR system user guide for in-car use, Police case reports and an internal software manual)
Whether a public body must produce a cost table or other data embedded in proprietary software used for assessments. (A proprietary cost table in assessment software)
Whether redactions to correspondence properly relied on section 7(1)(o) alongside other exemptions for private information and privacy. (Athletic department correspondence with an NIL group)
Whether a request for specific digital data requires a public body to create new records or answer questions. (Native digital files from Snap, Inc)

Practical points

A public body relying on section 7(1)(o) should identify the record as administrative and technical information associated with automated data processing operations.
A request for information embedded in exempt proprietary software may be found unfounded where the embedded material falls under sections 7(1)(o) and 7(1)(a).
A public body is not required to create new records or answer questions in response to a request for specific digital data.

Summary drafted from the linked decisions and checked against them; read the decisions themselves before relying on it. Not legal advice.

All 5 documents citing 7(1)(o)

Issues decided under 7(1)(o)

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.

4 issues across 4 determination letters:1 violation found · 3 no violation.

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

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-o.json.

TOPIC: 5 ILCS 140/7(1)(o) - Data-processing/IT security information
SOURCE: Illinois Attorney General Public Access Bureau decisions compiled at https://illinoisfoia.org/exemptions/7-1-o/
NOTE: Determination letters are not binding precedent; they show how the Bureau applies the law. Verify every decision against the source PDF before citing it.

VIOLATION FOUND (1):
- Redaction of internal meeting hyperlinks
  Rule: A public body must show more than a possibility of a security threat; conclusory assertions that meeting links could enable hacking are insufficient.
  Decision: Athletic department correspondence with an NIL group (non-binding determination letter, November 22, 2024) https://illinoisfoia.org/opinions/letter-80318/

NO VIOLATION (3):
- Denial of ALPR user guide under section 7(1)(o)
  Rule: User guides are per se exempt under section 7(1)(o) as administrative or technical information associated with automated data processing operations, so no security showing is required.
  Decision: ALPR system user guide for in-car use (non-binding determination letter, March 25, 2025) https://illinoisfoia.org/opinions/letter-82383/
- Embedded cost table exempt as software under section 7(1)(o)
  Rule: Information embedded in software is part of the software and is exempt from disclosure under section 7(1)(o) of FOIA.
  Decision: A proprietary cost table in assessment software (non-binding determination letter, March 3, 2025) https://illinoisfoia.org/opinions/letter-84329/
- Section 7(1)(o) exemption for AIRA manual
  Rule: AIRA manual contains technical and administrative automated data processing information whose disclosure would jeopardize system security.
  Decision: Police case reports and an internal software manual (non-binding determination letter, May 7, 2018) https://illinoisfoia.org/opinions/letter-51718/

MOST-CITED AUTHORITIES: Chapman v. Chicago Department of Finance, 2022 IL App (1st) 200547, ¶ 36; Southern Illinoisan v. Illinois Department of Public Health, 218 Ill. 2d 390, 844 N.E.2d 1 (2006); Lieber v. Board of Trustees of Southern Illinois University, 176 Ill. 2d 401, 407 (1997)

TASK FOR THE ASSISTANT: Using only the decisions above, help draft a letter. Argue from the rule and cite the decision by name and date. Do not invent decisions.

Violation found (1)

Redaction of internal meeting hyperlinks
Rule: A public body must show more than a possibility of a security threat; conclusory assertions that meeting links could enable hacking are insufficient.
Violation found Athletic department correspondence with an NIL group · November 22, 2024

No violation (3)

Denial of ALPR user guide under section 7(1)(o)
Rule: User guides are per se exempt under section 7(1)(o) as administrative or technical information associated with automated data processing operations, so no security showing is required.
No violation ALPR system user guide for in-car use · March 25, 2025
Embedded cost table exempt as software under section 7(1)(o)
Rule: Information embedded in software is part of the software and is exempt from disclosure under section 7(1)(o) of FOIA.
No violation A proprietary cost table in assessment software · March 3, 2025
Section 7(1)(o) exemption for AIRA manual
Rule: AIRA manual contains technical and administrative automated data processing information whose disclosure would jeopardize system security.
No violation Police case reports and an internal software manual · May 7, 2018