California
Fees
Online
Software
Special
cases
Resources
For years, reporters
seeking databases in California have run into problems with agencies providing
computer printouts over electronic data. In 2001, the law was altered to require
agencies to make electronic information available to requesters. Other barriers
to accessing databases in California have been and continue to be high costs
for acquiring data and the states strict privacy laws that make getting
information on individuals difficult.
The law. The
California Public Records Act applies to any "writing containing information
relating to the conduct of the publics business . . . regardless of physical
form or characteristics." It defines writing to include "magnetic
or paper tapes, . . . magnetic or punched cards, discs, drums and other documents."
Cal. Govt Code § 6252. The fact that public records may be stored
in a computer does not effect their status as public records. Cal. Govt
Code § 6254.9(d). Section 6253.9, which became effective Jan. 1, 2001,
requires public agencies that have information which constitutes an identifiable
public record from disclosure that is in an electronic format to make that information
available in an electronic format when requested unless it is otherwise exempt
from disclosure. This statute supersedes portions of an earlier statute (Section
6253(b)) that allowed public agencies to determine the form in which computer
data would be made available.
The requester can
choose the format if it is one that has been used by the agency to create copies
for its own use or for provision to other agencies. Cal. Govt Code §
6253.9(a)(2). Otherwise, the agency shall make the information available in
any electronic format in which it holds the information. Cal. Govt Code
§ 6253.9(a)(1). However, § 6253.9 does not require release of records
in electronic format where "release would jeopardize or compromise the
security of integrity of the original record or any proprietary software in
which it is maintained." Cal. Govt Code § 6253.9(f).
While the requester
can try to persuade the public agency to do a customized search, there is no
provision requiring the agency to provide electronic information other than
in a format in which it normally keeps the information or in a format that has
been used by the agency to create copies for its own use or for use by other
agencies. Cal. Govt Code § 6253.9(a). Moreover, an agency is not
required to reconstruct a record in an electronic format if the agency no longer
has the record available in an electronic format. Cal. Govt Code §
6253.9(c). However, an agency arguably cannot deny access to public information
because the request would require it to "compile data, write programming
language or a computer program, or to construct a computer report to extract
data." These are legitimate reasons for allowing the agency to extend the
time necessary to comply with a Public Records Act request, but not for denying
access altogether. See Cal. Govt Code § 6253(c)(4).
Cases &
opinions. Judicial records are not subject to the Public Records Act, but
a computerized list of prospective jurors and their addresses is public. However,
confidential questionnaires completed by prospective jurors and used by the
court to compile a master list are not public for privacy reasons. "Confidential"
information, such as occupation, former felonies and former jury service, had
to be deleted before providing the data in printed form or on computer tape.
Pantos v. San Francisco, 198 Cal. Rptr. 489 (Cal. Ct. App. 1984).
The "Gang
Reporting, Evaluation and Tracking" (GREAT) system contains intelligence
information and security procedures incorporated into the gang reporting, evaluation,
and tracking system by law enforcement agencies. The records are not subject
to public disclosure under the Public Records Act. (Atty Gen. Op. No.
95-607, Sept. 13, 1996)
Fees.
The act allows fees only for "direct costs" of copying a record
unless another statute specifically allows search fees or higher copying fees.
Cal. Govt Code § 6257. No fee or other charge may be imposed as a
condition of accessing information available by way of the computer network
over the Internet. Cal. Govt Code § 10248. In a case involving a
commercial requester, a statutory fee was upheld as reasonable even though the
agency made a profit from copying computer tapes. Shippen v. Dept. of Motor
Vehicles, 208 Cal. Rptr. 13 (Ct. App. 1984).
A public agency may charge a fee for a copy of a public record in an amount
that is either (1) based upon and limited to the "direct costs of duplication"
or (2) authorized and determined under some other statute. North County Parents
Organization v. Department of Education, 23 Cal.App.4th 144, 147-148 (1994).
When the electronic record is in a format that has been used by an agency to create copies for its own use or for provision to other agencies, an agency may charge only the direct cost of duplication, which is the direct cost of producing the record in the electronic format. Cal. Govt Code § 6253.9(a)(2). When, however, the record is one that is produced only at otherwise regularly scheduled intervals or when the request would require data compilation, extraction, or programming, an agency may charge for the cost of producing a copy of the record, including the cost of constructing the record and the cost of programming and computer services necessary to produce a copy of the record. Cal. Govt Code § 6253.9(b).
A county board
of supervisors may charge fees for copying public records in excess of the amount
mandated by the California Public Records Act. An opinion by the states
attorney general contrasts the fee mandate in the CPRA, which allows only for
direct cost of duplication, with a competing government code, § 54985,
which states that a "county board of supervisors shall have the authority
to increase or decrease the fee or charge, that is otherwise authorized to be
levied by another provision of law." The fee must be an amount "reasonably
necessary to recover the costs" of the copy.
"In charging a fee to cover its costs," the opinion said, "a county board of supervisors could conceivably benefit those being charged since an inability to charge fees in a sufficient amount to cover costs would likely produce inadequate staffing." Fees that largely exceed the direct cost of copying are not unusual in California, said Tom Newton of the California Newspaper Publishers Association, noting that in some areas people are charged as much as $20 for a police report. Calif. Atty. Gen. Op. 01-605, Nov. 1, 2002).
Software.
A statute exempts from disclosure computer software developed by a state or
local agency. Software includes "computer mapping systems, computer programs,
and computer graphics systems." The statute says information is not software
merely because it is stored in a computer. State agencies may sell, lease, or
license the software for commercial or noncommercial uses. Computer software,
defined as "computer mapping systems, computer programs and computer graphics
systems," developed by a state or local agency is not itself a public record
under the CPRA. Cal. Govt Code § 6254.9.
Online.
All state statutes, the constitution and current legislative information are
available in electronic form through the Internet. Cal. Govt Code §
10248.
The department
of real estate is required to disclose information on its licensees, including
real estate brokers, on the Internet. Cal. Govt Code § 11018.5. Lobbying
and political contribution reports required by the Political Reform Act of 1974
may now be filed electronically. Cal. Govt Code §84602.
Additionally, the
Legislative Counsel is required to make available via the Internet its calendar,
hearing schedules, a list of matters pending on the floor of both houses, a
list of legislative committees and their members, as well as all bill information
for the current legislative session, including the text of all versions of any
bill, the bills history and status, analysis of legislative committees,
all vote information, and any veto message. Cal. Govt Code § 10248.
No state or local agency shall post the home address or telephone number of
any elected or appointed official on the Internet without first obtaining the
written permission of that individual. Cal. Govt Code § 6254.21.
Special
cases. Voter records media exemption under the election code,
section 2194. Voter registration card information: "Shall be confidential
and shall not appear on any computer terminal, list, affidavit, duplicate affidavit,
or other medium routinely available to the public at the county elections officials
office. (2) Shall be provided with respect to any voter, subject to the provisions
of Section 2188, to any candidate for federal, state, or local office, to any
committee for or against any initiative or referendum measure for which legal
publication is made, and to any person for election, scholarly, journalistic,
or political purposes, or for governmental purposes, as determined by the Secretary
of State."
Vital Records.
On Sept. 25, 2002, Gov. Gray Davis signed a bill limiting access to indices
of vital records such as births, deaths and marriages. He said the move will
protect the public from "identity theft," but an open-records advocate
calls the measure "a terrible precedent." As a result, the state limited
access to vital records data such as births, deaths and marriages and created
a tiered system for who can access which level of detail. The indices are exempt
from disclosure under the CPRA. Under the new law, members of the public and
media may "view" an edited version of the records, but only after
certifying under penalty of perjury that they will not to use the information
viewed to commit a crime. Vital records would still be available to government
and law enforcement agencies, but these agencies would be prohibited from selling
or releasing these indices, except as authorized by law. Cal. Health and Safety
Code § 102230-102232.
Home Addresses
in DMV, voter registration, gun license, public housing, local agency utility
and public employee records are exempt, as are addresses of certain crime victims.
(§§ 6254(f),(u), 6254.1, 6254.3, 6254.4, 6254.16, 6254.21)
Police Incident
Reports, Rap Sheets and Arrest Records are exempt (Penal Code §§
11075, 11105, 11105.1), but information in the "police blotter" (time
and circumstances of calls to police; name and details of arrests, warrants,
charges, hearing dates; etc.) must be disclosed unless disclosure would endanger
an investigation or the life of an investigator.
Resources. California First Amendment Coalition; California Newspaper Publishers Association