Are written communications related to potential or actual COIs and COCs (e.g., email messages, memoranda, and written management plans) subject to release through FOIA?
FOIA permits persons to make requests to review or receive copies of University documents. While there are various exemptions to FOIA’s disclosure requirements, the courts have interpreted the exemptions narrowly. When no exemption applies, the University must provide the requested documents. Because of its commitment to employee privacy, the University considers every reasonably applicable exemption to maintain confidentiality. This practice would, of course, apply to information generated by the implementation of COI/COC policies and procedures. The University would, for example, invoke an exemption for documents that contain private information that is personal in nature, as well as for communications within the University that discuss the proper approach for managing the conflict under consideration. Because the courts have interpreted FOIA exemptions narrowly, however, it is unlikely that the University will be permitted to protect all information pertaining to potential COIs and
Related Questions
- When people forward messages from the exchange server, the actual Internet email addresses do not appear next to the names listed on the original message. What is happening?
- Are written communications related to potential or actual COIs and COCs (e.g., email messages, memoranda, and written management plans) subject to release through FOIA?
- Are email messages considered public records?
