New Jersey
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New Jersey passed
a comprehensive new open records and meetings law on Jan. 8, 2002, which took
effect on July 1, 2002.
Published analyses
characterized New Jerseys previous 38-year-old public-records law as among
the weakest in the nation. Significantly, the law allowed public access only
to those documents an agency was required to maintain and imposed no time limit
on when an agency was required to respond to a request for documents. The new
law assumes that records are open, unless covered by an exemption. The new law
specifically addresses computerized records, but it also contains strong language
in regards to protecting individual privacy.
The New Jersey
Press Association withdrew its support from the bill in the final hour, however,
after legislators added a provision exempting their own correspondence from
disclosure.
The law. Open
Public Records Act declares records to be public unless they fall within certain
exceptions. (PL 2001, c. 404) In enacting the new law, the legislature concluded
as a matter of public policy that "government records shall be readily
accessible for inspection, copying or examination by citizens of this state,
with certain exceptions, for the protection of the public interest." Mirroring
the open-records laws in most other jurisdictions, the legislature mandated
that "all records shall be subject to public access" unless specifically
exempted.
"Government
record" or "record" means any paper, written or printed book,
document, drawing, map, plan, photograph, microfilm, data processed or image
processed document, information stored or maintained electronically or by sound-recording
or in a similar device, or any copy thereof, that has been made, maintained
or kept on file in the course of his or its official business by any officer,
commission, agency or authority of the State or of any political subdivision
thereof, including subordinate boards thereof, or that has been received in
the course of his or its official business by any such officer, commission,
agency, or authority of the State or of any political subdivision thereof, including
subordinate boards thereof. The terms shall not include interagency or intra-agency
advisory, consultative, or deliberative material.
A custodian shall
permit access to a government record and provide a copy thereof in the medium
requested if the public agency maintains the record in that medium. If the public
agency does not maintain the record in the medium requested, the custodian shall
either convert the record to the medium requested or provide a copy in some
other meaningful medium. If a request is for a record: (1) in a medium not routinely
used by the agency; (2) not routinely developed or maintained by an agency;
or (3) requiring a substantial amount of manipulation or programming of information
technology, the agency may charge, in addition to the actual cost of duplication,
a special charge that shall be reasonable and shall be based on the cost for
any extensive use of information technology or for the labor cost of personnel
providing the service.
The revised law
imposes on public agencies "an obligation to safeguard from public access
a citizens personal information with which it had been entrusted when
disclosure thereof would violate the citizens reasonable expectation of
privacy." N.J. Stat. Ann. § 47:1A-1 Thus, it exempts from disclosure
certain documents relating to crime victims, sexual-harassment complaints filed
against public employers, and "that portion of any document which discloses
the Social Security number, credit-card number, unlisted telephone number or
driver-license number of any person." The law also establishes a 13-member
Privacy Study Commission that will study the laws impact on privacy issues.
N.J. Stat. Ann. § 47:1A-11 (a)
Cases & opinions. The new public records law created the Government Records Council to respond to questions regarding the law. The GRC had issued only a handful of opinions by March 2003, two of which addressed electronic records.
In response to
a request for police blotter data to which a city charged a requester $150 for
processing, the GRC concluded that a city did not present the council with any
evidence that the one hour of labor and computer time to produce a copy of the
police blotter or log for July 2, 2002 represents "a substantial amount
of manipulation or programming of information technology" or the "extensive
use of information technology
" pursuant to N.J. Stat. Ann. §
47:1A-5c, notwithstanding the age of the Citys computer system. The council
ordered that custodian "shall charge the requester only the per-page copy
rates in N.J. Stat. Ann. § 47:1A-5b for the record in question. The custodian
shall refund to the requester any sum paid that exceeds the per-page copy cost
for the record in question." GRC Complaint 2002-46 (Aug. 26, 2002)
In regards to a
requester who sought e-mails sent or received by city officials, the custodian
denied the request on the basis that the e-mails were "intra-agency advisory,
consultative or deliberative materials" (ACD) and, thus, not "government
records" accessible under OPRA. N.J.S.A. 47:1A-1.1. The custodian offered
no evidence describing the general content of any e-mail for the council to
assess the validity of the claim as to any particular e-mail communication.
The township attorney advised the council that he would review the e-mail personally
and provide the council with additional evidence in support of any ACD claim
being made for each item. No further decision had been made on this issue. GRC
Complaint 2002-58 (Jan.17, 2003).
Most other cases
and opinions in New Jersey apply the previous statute or common law.
Where a commercial
requester sought access to daily computer printouts, the law required a public
utility to provide time for inspecting the printouts. If a computer record qualifies
as a public record under the Right to Know Law, access may not be denied to
any requester. Even when a computer printout does not qualify as a public record
under the law, a requester may have a common law right of access if the interests
in disclosure outweigh the need for confidentiality of the records. Techniscan
v. Passaic Valley Water Common, 549 A.2d 1249 (N.J. 1988).
A newspaper had
no right of access to a computer spreadsheet prepared for a government body
because the law did not require the agency to make or keep the printout, a private
consultant prepared it, and the reporter could reconstruct the analysis from
public documents. Asbury Park Press v. State Dept. of Health, 558 A.2d
1363 (N.J. Super. Ct. App. Div. 1989), cert. denied, 569 A.2d 1344 (N.J.)
A private company
that provides access to real estate tax assessment records is entitled to a
computer tape of the assessments of each municipality under common law. Higg-A-Rella,
Inc. v. County of Essex, No. A4830-92T3 (N.J. Super Ct. App. Div. Sept.
26, 1994). The court said that under the common law right of access to government
documents, a requester could selectively copy files from a computer database
where such copying had been done for others and where the requester was willing
to pay the cost of creating and running necessary computer search programs.
Board of Educ. Of Newark v. New Jersey Dept. of Treasury, A-67-95, 678
A.2d 660 (N.J. 1996).
Software.
Two exemptions to the new law may impact reporters access to software
or to documentation. "Administrative or technical information regarding
computer hardware, software and networks which, if disclosed, would jeopardize
computer security" and trade secrets and proprietary commercial or financial
information obtained from any source. For the purposes of this paragraph, trade
secrets shall include data processing software obtained by a public body under
a licensing agreement that prohibits its disclosure, "as well as proprietary
information as to computers."
Fees.
With regard to the costs which may be charged for the copies, the statute sets
the following maximum charges:
"A copy or copies of a government record may be purchased by any person
upon payment of the fee prescribed by law or regulation, or if a fee is not
prescribed by law or regulation, upon payment of the actual cost of duplicating
the record. Except as otherwise provided by law or regulation, the fee assessed
for the duplication of a government record embodied in the form of printed matter
shall not exceed the following: first page to tenth page, $0.75 per page; eleventh
page to twentieth page, $0.50 per page; all pages over twenty, $0.25 per page.
The actual cost of duplicating the record shall be the cost of materials and
supplies used to make a copy of the record, but shall not include the cost of
labor or other overhead expenses associated with making the copy except as provided
for in subsection c. of this section. If a public agency can demonstrate that
its actual costs for duplication of a government record exceed the foregoing
rates, the public agency shall be permitted to charge the actual cost of duplicating
the record. C.47:1A-5 (b)
For computer records
"the agency may charge, in addition to the actual cost of duplication,
a special charge that shall be reasonable and shall be based on the cost for
any extensive use of information technology, or for the labor cost of personnel
providing the service, that is actually incurred by the agency or attributable
to the agency for the programming, clerical, and supervisory assistance required,
or both."
Resources. Government Records Council