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Public Access Opinion 16-012

Compensation disclosure

Administrator Contracts
Case: Public Access Opinion 16-012
Date: Wednesday, December 21, 2016

For the second time two calendar years, the PAC has told public bodies that the amount of compensation paid by the public body is subject to disclosure unless it is otherwise exempted.

An individual submitted a FOIA request to the Housing Authority of the City of Freeport for the names and titles of staff members receiving bonuses, as well as the amount of the bonuses. The Authority denied the request in its entirety, asserting that the requested records were exempted under: FOIA Section 7(1)(b) as a “unique identifier” that could be considered personal financial information; FOIA Section 7(1)(c) as personal information that could constitute an “unwarranted invasion of personal privacy”; and the Personnel Record Review Act (820 ILCS 40/). Unpersuaded by these attempts at claiming exemptions, the PAC held that the requested records were subject to disclosure under FOIA Section 2.5 because employee compensation relates to the use of public funds. The PAC ordered the Authority to immediately provide the FOIA requester with records sufficient to show the bonuses paid.

This opinion is binding only to the parties involved and may be appealed pursuant to State law.