i. Privacy Interest

Under 7(C), “[t]he preliminary question is whether” an individual’s interest in nondisclosure of the records is a “personal privacy” interest protected by the exemption.⁷² For purposes of this exemption — like Exemption 6 — the third party must have “more than a de minimis privacy interest” that would be compromised by the release of the requested material.⁷³ Therefore, in appealing a denial under this exemption, you should strongly argue that there is little or no privacy interest in the records at issue.