Informal Opinion Letter Summary

Memo Decision 09-14

Payroll Records

A member of the public asked whether Waters of Life Charter School (“WOLCS”) properly denied his request for the payroll records of WOLCS from 2003 to the time of his request (the “Payroll Records”).

OIP found that WOLCS had failed to meet its burden to justify nondisclosure of the records. OIP did not have the opportunity to review the records and WOLCS did not provide any information as to what the records contained.

OIP, however, raised certain exceptions sua sponte and found that the Payroll Records must be disclosed, subject to possible redaction of (1) any individuals’ social security numbers, based on the individuals’ privacy interests and because disclosure is prohibited by statute; and (2) any payroll deductions, tax withholding or net pay under the UIPA’s privacy exception, § 92F-13(1). OIP advised that WOLCS should seek guidance from OIP before redacting any other information.

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