An Individual’s Name Is Not Exempt from Disclosure as “Private Information” under Section 7(1)(b) of FOIA
The PAC found that the City of Joliet (“City”) violated FOIA when it improperly redacted a water customer’s bill in response to a FOIA request dated October 17, 2017. The FOIA requester, Troy Community Consolidated School District #30C, submitted a FOIA request for a copy of a water bill associated with a particular address. (The District was seeking the information to help it discern who was living at an in-district address). The City provided the water bill with certain redactions. It argued that the water customer’s name was exempt from disclosure under Section 7(1)(b) because the name constituted “private information” Section 7(1)(b). Section 2(c-5) of FOIA, in relevant part, defines “private information” as “unique identifiers, including a person's social security number, driver's license number, employee identification number, biometric identifiers, personal financial information, passwords or other access codes, medical records, home or personal telephone numbers, and personal email addresses….home address and personal license plates…” The City specifically claimed that in the context of the water bill, the customer name constituted personal financial information and should be exempt.
The PAC found that the City could not properly assert the private information exemption because an individual’s name is not a unique identifier under Section 2(c-5). The PAC explained that a name is “basic information” and many people can have the same name; it is therefore not “unique.” Additionally, the PAC noted that even if the customer name did constitute personal financial information, bills for water services are public records subject to inspection because they are “records relating to the obligation, receipt, and use of public funds” under Section 2.5 of FOIA, and that section requires disclosure. The PAC ordered the Village to provide a copy of the water bill with the customer’s name unredacted to the FOIA requester.
This opinion is binding only to the parties involved and may be appealed pursuant to State law.