FOIA section 7(1)(c)

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

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

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

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