BUSINESS AND OPERATIONS: TEXAS PUBLIC INFORMATION ACT      [LAW]

 

 

1.         Definitions

 

Public information means information that is collected, assembled, or maintained under a law or ordinance or in connection with the transaction of official business by the school, for the school, and to which the school owns or has a right of access. 

 

Tex. Gov’t Code § 552.002(a).

 

2.         Availability

 

Public information is available to the public at a minimum during the school’s normal business hours. 

 

Tex. Gov’t Code § 552.021.

 

3.         Categories of Public Information

 

The following categories of information are public information and not excepted from required disclosure unless they are expressly confidential under other law:

 

A.        A complete report, audit, evaluation, or investigation made of, for, or by the school, except certain law enforcement and prosecutorial information as provided by Tex. Gov’t Code § 552.108;

 

B.         The name, sex, ethnicity, salary, title, and dates of employment of each employee and officer of the school;

 

C.        Information in an account, voucher, or contract relating to the receipt or expenditure of public or other funds;

 

D.        The name of each official and the final record of voting on all proceedings of the school;

 

E.         All working papers, research material, and information used to estimate the need for or expenditure of public funds or taxes by the school, on completion of the estimate;

 

F.         A description of the school’s organization and where, from whom, and how the public may obtain information, submit information or requests, and obtain decisions;

 

G.        A statement of the general course and method by which the school functions are channeled and determined, including the nature and requirements of all formal and informal policies and procedures;

 

H.        A rule of procedure, a description of forms available, or the places at which forms may be obtained, and instructions relating to the scope and content of all papers, reports, or examinations;

 

I.          A substantive rule of general applicability adopted or issued by the school, and a statement of general policy or interpretation of general applicability formulated and adopted by the school;

 

J.          Each amendment, revision, or repeal of information described in subsections (F)-(I) hereof;

 

K.        All final opinions and orders issued in the adjudication of cases;

 

L.         A policy statement or interpretation that has been adopted or issued by the school;

 

M.        Administrative staff manuals and instructions to staff that affect a member of the public;

 

N.        Information regarded as open to the public under the school’s policies;

 

O.        Information that is in a bill for attorney’s fees and that is not privileged under the attorney-client privilege;

 

P.         Information that is also contained in a public court record;

 

Q.        A settlement agreement to which the school is a party.

 

Tex. Gov’t Code § 552.022.

 

4.         Confidentiality of Personal Information

 

A.        Each current or former employee or official of the school shall choose whether to allow public access to the information in the custody of the school that relates to the person’s address, telephone number, or Social Security number, or that reveals whether the person has family members.

 

B.         Each current and former employee and official shall state that person’s choice as to disclosure to the main personnel officer of the school in a signed writing not later than the 14th day after the date on which:

 

(1)        The employee begins employment with the school;

 

(2)        The official is elected or appointed; or

 

(3)               The former employee or official ends service with the school.

 

C.                 If a current or former employee or official fails to specify his/her choice, the information is subject to public access.  However, the employee or official may open or close public access to the information at any time by making a written request to the main personnel officer.

 

D.        Personal information of peace officers, county jailers, employees of the Texas Department of Criminal Justice, and commissioned peace officers is confidential and may not be disclosed if the person so chooses and informs the school.  An election as to confidentiality remains valid until rescinded.

 

Tex. Gov’t Code §§ 552.024, 552.1175.

 

5.         Education Records

 

Educational records may only be released in conformity with the Family Educational Rights and Privacy Act. 

 

Tex. Gov’t Code § 552.026.

 

6.         Information Excepted from Required Disclosure

 

A.        The school, or its officer for public information, may voluntarily make part or all of its records available to the public, unless the disclosure is expressly prohibited by law or the records are confidential.

 

Tex. Gov’t Code § 552.007(a).

 

B.         The following categories of information are excepted from disclosure to the public:

 

(1)        Information considered confidential by other law, either constitutional, statutory, or by judicial decision;

 

(2)        Information in a personnel file, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy, including transcripts from an institution of higher education.  This exception does not cover the degree obtained or the curriculum on a transcript in the personnel file;

 

(3)        Information relating to litigation of a civil or criminal nature to which the school is or may be a party, or to which an officer or employee of the school, as a consequence of the person’s office or employment, is or may be a party, but only if the litigation is pending or reasonably anticipated at the time the school’s public information officer receives the request;

 

(4)        Information that, if released, would give advantage to a competitor or bidder.  Information of this type is excepted from disclosure notwithstanding that it falls into a category of public information described above;

 

(5)        Information relating to the location of real or personal property for a public purpose prior to public announcement of the project; or appraisals or purchase price of real or personal property for a public purpose prior to the formal award of contracts for the property;

 

(6)        A draft or working paper involved in the preparation of proposed policies;

 

(7)        Information that the school’s attorney is prohibited from disclosing because of a duty to the school under the Texas Rules of Civil Evidence, the Texas Rules of Criminal Evidence, or the Texas Disciplinary Rules of Professional Conduct, or information prohibited from public disclosure by a court order;

 

(8)        Under certain circumstances, information held by a law enforcement agency or prosecutor that deals with:

 

(a)        The detection, investigation, or prosecution of crime; and

 

(b)        An internal record or notation of a law enforcement agency or prosecutor maintained for internal use in matters relating to law enforcement or prosecution.

 

            Basic information about an arrested person, an arrest, or crime is not protected by this exception;

 

(9)        Private correspondence or communications of an elected office holder relating to matters the disclosure of which would constitute an invasion of privacy;

 

(10)      A trade secret obtained from a person and privileged or confidential by statute or judicial decision;

 

(11)      Commercial or financial information for which it is demonstrated, based on specific factual evidence, that disclosure would cause substantial competitive harm to the person from whom the information was obtained;

 

(12)      A memorandum or letter that would not be available by law to a party in litigation with the school;

 

(13)      Information in a student record unless requested by:

 

(a)        Educational institution personnel;

 

(b)        The student involved or the student’s parent, legal guardian, or spouse; or

 

(c)        A person conducting a child abuse investigation pursuant to the Family Code provisions;

 

(14)      Test items developed by a state-funded educational institution, a licensing agency, or governmental body;

 

(15)      A record of the school library that identifies or serves to identify a person who requested, obtained, or used a library material or service unless the record is disclosed because:

 

(a)        The library system determines that disclosure is reasonably necessary for the operation of the library and the record is not otherwise confidential; or

 

(b)        Other law requires disclosure of the information;

 

(16)      The name of an applicant for the position of School Director is excepted from disclosure except that the board must give public notice of the name or names of the finalists being considered for the position at least 21 days before the date of the meeting at which a final action or vote is to be taken;

 

(17)      A driver’s license record or other personal identification document issued by an agency of the state may only be released pursuant to disclosure provisions of the Transportation Code;

 

(18)      An informer’s name or information that would substantially reveal the identity of an informer, unless:

 

(a)        The informer is a student or former student and the student or former student, or legal guardian, or spouse of the student or former student consents to disclosure; or

 

(b)        The informer is an employee or former employee who consents; or

 

(c)        The informer planned, initiated, or participated in the possible violation.

 

An “informer” is a person who has furnished a report of another person’s possible violation of criminal, civil, or regulatory law to the school or the proper regulatory enforcement authority;

 

(19)      A credit card, debit card, charge card, or access device number that is collected, assembled, or maintained by or for the school is confidential;

 

(20)      An electronic mail address of a member of the public that is provided for the purpose of communicating electronically with the school is confidential and not subject to disclosure unless the member of the public affirmatively consents to its release;

 

(21)      Information that relates to computer network security or to the design, operation, or defense of a computer network, including vulnerability reports;

 

(22)      Information in a commercial book or publication purchased or acquired by the school for research purposes, if the book or publication is commercially available to the public.  The school is not required to make copies of commercially available information, but the school shall allow the inspection of information in a book or publication that is made part of, incorporated into, or referred to in a rule or policy of the school.

 

Tex. Gov’t Code §§ 552.027, 552.101-137.

 

7.         Officer for Public Information

 

            The School Director is designated as the officer for public information.  Each officer of public information shall:

 

A.        Make public information available for public inspection and copying;

 

B.         Carefully protect public information from deterioration, alteration, mutilation, loss, or unlawful removal;

 

C.        Repair, renovate, or rebind public information as necessary to maintain it properly;

 

D.        Prominently display a sign prescribed by the General Services Commission (GSC) containing:

 

(1)        Basic information about the rights of the requestor;

 

(2)        The responsibilities of the school; and

 

(3)        The procedures for inspecting or obtaining a copy of public information;

 

E.         Place the informational sign where it is plainly visible to:

 

(1)        Members of the public who request public information in person; and

 

(2)        Employees of the school whose duties include receiving or responding to requests for public information.

 

Tex. Gov’t Code §§ 552.201, 552.203, 552.205.

 

8.         Procedures Related to Access

 

A.        The school may promulgate reasonable rules of procedure under which public information may be inspected and copied efficiently, safely, and without delay.

 

Tex. Gov’t Code § 552.230.

 

B.         The officer for public information shall promptly produce public information for inspection, duplication, (or both) on application by any person to the officer.  Compliance with this policy may be by providing the public information for inspection or duplication in the offices of the school or by mailing them to the requestor, subject to any applicable charges.

 

Tex. Gov’t Code § 552.221(a), (b).

 

C.        If the requested information is unavailable at the time of the request because it is in active use or in storage, the officer for public information shall inform the requestor in writing and set a date and hour within a reasonable time when the information will be available for inspection or duplication.  If the officer cannot produce the requested information within 10 business days after the date of the request, the officer shall so inform the requestor in writing and schedule a date and hour, within a reasonable time, when the information will be made available for inspection or duplication.

 

Tex. Gov’t Code § 552.221(c)-(d).

 

D.        The officer of public information or designee shall not make any inquiry of a requestor except:

 

(1)        To establish proper identification;

 

(2)        To clarify the request;

 

(3)        To discuss how large requests might be narrowed; or

 

(4)        To establish that the requestor is eligible to receive the information if the request relates to motor vehicle records.

 

The school may not inquire into the purpose for which information will be used.

 

Tex. Gov’t Code § 552.222.

 

E.         The officer for public information or the officer’s agent shall treat all requests for information uniformly without regard to the position or occupation of the requestor, the person on whose behalf the request is made, or the status of the individual as a member of the media.  Furthermore, the school shall give to a requestor all reasonable comfort and facility for the full exercise of the right outlined in this policy.

 

Tex. Gov’t Code § 552.223-.224.

 

F.         If the requested information exists in an electronic or magnetic medium, the requestor may request a copy either on paper or in an electronic medium, such as on diskette or on magnetic tape.  The school shall provide a copy in the requested medium if:

 

(1)        The school has the technological ability to produce a copy in the requested medium;

 

(2)        The school is not required to purchase any software or hardware to accommodate the request; and

 

(3)        Provision of a copy of the information in the requested medium will not violate the terms of any copyright agreement between the school and a third party.

 

If the school is unable to comply with a request to produce a copy of information in a requested medium for any of the reasons described in this policy, the school shall provide a paper copy or a copy in another medium that is acceptable to the requestor.  The school is not required to copy information onto a diskette provided by the requestor but may use its own supplies.

 

Tex. Gov’t Code § 552.228(c).

 

G.        Consent for the release of information excepted from disclosure but available to a specific person because of a special right of access, must be in writing and signed by the specific person or the person’s authorized representative.  If the school determines that information subject to a special right of access is exempt from disclosure under an exception, then the school shall submit a written request for a decision to the attorney general within 10 days of refusing the request and before disclosing the information.

 

An individual under 18 years of age may consent to the release of information under special right of access only with the additional written authorization of the individual’s parent or guardian.  Furthermore, a person adjudicated incompetent to manage his/her own affairs, or for whom an attorney ad litem has been appointed, may consent to the release of special right of access information only by written authorization of the designated legal guardian or attorney ad litem.

 

Tex. Gov’t Code §§ 552.229(a), (c), 552.307.

 

H.        If responding to a request will require programming or manipulation of data, and compliance is not feasible, or the information can only be made available at a cost, the officer shall provide a written statement to the requestor within 20 days of the request with the following information:

 

(1)        A statement that the information is not available in the requested form;

 

(2)        A description of the form in which the information is available;

 

(3)        A description of any contract or services that would be required to provide the information in the requested form;

 

(4)        A statement of the estimated cost of providing the information in the requested form, as determined in accordance with the rules established by the GSC; and

 

(5)        A statement of the anticipated time required to provide the information in the requested form.

 

The school may have an additional 10 days to provide the statement if it provides written notice to the requestor within the initial 20 days that more time is needed.  The school shall establish policies that assure the expeditious and accurate processing of requests for information that require programming or manipulation of data.  The policies shall provide for the maintenance of a file containing all written statements issued under this policy in a readily accessible form.

 

Tex. Gov’t Code § 552.231.

 

9.         Repetitious/Redundant Requests

 

The school is not required to respond to repetitious or redundant requests by providing access to the information.  If the school determines the requestor has already been given access to or provided a copy of requested information on a previous occasion, the school may elect to certify to the requestor that copies of all or part of the requested information were previously furnished or made available to the requestor.  The certification must be made free of charge and include:

 

A.        A description of the information for which copies have been previously furnished or made available to the requestor;

 

B.         The date that the school received the requestor’s original request for that information;

 

C.        The date that the school previously furnished copies of or made available copies of the information to the requestor;

 

D.        A certification that no subsequent additions, deletions, or corrections have been made to that information; and

 

E.         The name, title, and signature of the officer for public information or the his/her agent making the certification.

 

Tex. Gov’t Code § 552.232.

 

10.       Charges for Providing Copies of Public Information

 

A.        General Rule

 

The charge for providing a copy of public information shall be an amount that reasonably includes all costs related to reproducing the public information, including costs of materials, labor, and overhead.  If a request is for 50 or fewer pages, the charge for providing the copy of the information may not include costs of materials, labor, or overhead, but shall be limited to photocopying costs, unless the pages are located in two (2) or more separate buildings or in a remote storage facility.  If the charge for providing a copy of public information includes costs of labor, the requestor may require the school to provide the requestor with a written statement as to the amount of time that was required to produce and provide the copy.  The statement must be signed by the officer for public information or the officer’s agent, and the signor’s name must be typed below the signature.  A charge may not be imposed for providing the written statement.

 

Tex. Gov’t Code § 552.261(a)-(b).

 

B.         Required Itemized Estimates of Charges

 

If the charge is to exceed $40, the school must provide the requestor with a written itemized statement that details all estimated charges that will be imposed, including any allowable charge for labor or personnel costs.  If an alternative less costly method of viewing the records is available, the statement must include a notice that the requestor may contact the school regarding such alternative method.  The school must inform the requestor of the duties imposed on the requestor by this policy and give the requestor the information needed to respond including:

 

(1)        That the requestor must provide the school with a mailing, facsimile, or electronic mail address to receive the itemized statement and indicate the requestor’s choice of which type of address to provide;

 

(2)        That the request is considered automatically withdrawn if the requestor does not respond within 10 days in writing to the itemized statement and any updated itemized statement in the time and manner required;

 

(3)        That the requestor may respond to the statement by delivering the written response to the school by mail, in person, by facsimile if the school is capable of receiving documents in that manner, or by electronic mail if the school has an electronic mail address.

 

If the school later determines that the estimated charges will exceed the charges detailed in the written itemized statement by 20% or more, the school shall send to the requestor a written updated itemized statement that details all estimated charges that will be imposed, including any allowable charges for labor or personnel costs.  If the requestor does not respond in writing to the updated estimate in the time and manner described above, the request is considered to have been withdrawn by the requestor.

 

Tex. Gov’t Code § 552.2615.

 

            C.        Required Bonds

 

(1)        The officer for public information may require a deposit or bond for payment of anticipated costs for the preparation of a copy of public information if the officer has provided the requestor with the required written itemized statement detailing the estimated charge and if the estimated charge exceeds:

 

(a)        $100 if the school has more than 15 full-time employees; or

 

(b)        $50 if the school has fewer than 16 full-time employees.

 

Tex. Gov’t Code §552.263(a).

 

(2)        A bond may not be required for copies of public information that the requestor may make in the future, but a bond may be required for unpaid amounts in relation to previous requests for public information if the amount exceeds $100.  The officer for public information or his/her agent may not seek requests for payment of those unpaid amounts through any other means.

 

Tex. Gov’t Code § 552.263 (b)-(c).

 

(3)        A request for a copy of public information is considered to have been received by the school on the date the school receives the deposit or bond for payment of anticipated costs or unpaid amounts if the officer for public information requires a deposit or bond as outlined in this policy.

 

Tex. Gov’t Code § 552.263(d).

 

D.        Cost Guidelines

 

The school shall use the Texas Building and Procurement Commission (TBPC) rules to determine the charges for providing copies of public information and to determine the charge, deposit, or bond required for making public information that exists in a paper record available for inspection, except to the extent that other law provides for charges for specific kinds of public information.  The charges for providing copies of public information may not be excessive, and may not exceed the actual cost of producing the information or form making public information that exists in a paper record available.  The school may determine its own charges for producing public information, but may not charge an amount that is greater than 25% more than the amount established by the TBPC, unless it requests an exemption.

 

Tex. Gov’t Code § 552.262; 1 Tex. Admin. Code § 111.61(b).

 

            E.         Requests for old Information and Large Requests

 

(1)        If the school has 16 or more full-time employees, the school may require a deposit or bond for the payment of anticipated personnel costs only if:

 

(a)        The information requested is older than five (5) years or fills six (6) or more archival boxes; and

 

(b)        The officer for public information estimates that more than five (5) hours will be required to make the information available for inspection.

 

Tex. Gov’t Code § 552.271(c).

 

(2)        If the school has fewer than 16 full-time employees, the deposit, or the bond authorized above may be required only if:

 

(a)        The public information is older than three (3) years or fills three (3) or more archival boxes; and

 

(b)        The officer for public information estimates that more than two (2) hours will be required to make the information available for inspection.

 

Tex. Gov’t Code § 552.271(d).

 

F.         Waiver/Reduction of Charge

 

The school shall provide a copy of public information without charge or at a reduced charge if the school determines that waiver or reduction of the charge is in the public interest because providing the copy of the information primarily benefits the general public.

 

Tex. Gov’t Code § 552.267.

 

G.        Overcharges

 

A person who overpays for a copy of public information because the school refuses or fails to follow the rules for charges adopted by the GSC is entitled to recover three (3) times the amount of the overcharge if the school did not act in good faith in computing the costs.

 

Tex. Gov’t Code § 552.269(b).

 

H.        When Inspection Only is Requested

 

A charge may not be imposed for making available for inspection any public information that exists in a paper record unless the requested page contains confidential information that must be edited from the record before the information can be made available for inspection.

 

Tex. Gov’t Code § 552.271(a)-(b).

 

11.       Withholding Information

 

A.        Request for Attorney General Decisions

 

(1)        If the school wishes to withhold from public disclosure information it considers to be within one of the exceptions, it must ask for a decision from the attorney general concerning whether the information is within that exception.  The school must ask for the decision and state the exceptions that apply not later than 10th business day after the request is received by mail, facsimile, or electronic mail.  If the school requests a decision, it must provide to the requestor, not later than the 10th business day after the request is received, a written statement that the school wishes to withhold the information and has requested a decision from the attorney general.  The school must also provide to the requestor a copy of the school’s written communication to the attorney general with any of the requested information redacted.

 

Tex. Gov’t Code § 552.301(a)-(d).

           

(2)        If the school requests an attorney general decision, it must, within 10 days after receiving the request, submit the following to the attorney general:

 

(a)        Written comments stating the reasons why the stated exceptions apply that would allow the information to be withheld;

 

(b)        A copy of the written request for information;

 

(c)        A signed statement as to the date on which the written request for information was received by the school or evidence sufficient to establish the date; and

 

(d)        A copy of the specific information requested, or submit representative samples of the information if a voluminous amount of information was requested.

 

Tex. Gov’t Code §552.301(e)(1).

 

(3)        The school must release the requested information and is prohibited from asking for a decision from the attorney general if:

 

(a)        The school has previously requested and received a determination from the attorney general concerning the precise information at issue in a pending request; and

 

(b)        The attorney general or a court determined that the information is public information to which no exception applies.

 

Tex. Gov’t Code § 552.301(f).

 

            B.         Presumption That Requested Information is Public

 

(1)        Unless the information is confidential by law, the public information officer may disclose the requested information to the public or the requestor before a final determination has been made by the attorney general or a court with jurisdiction.

 

Tex. Gov’t Code § 552.303(a).

 

(2)        If the school does not request an attorney general decision as provided under this policy, and provide the requestor with the information requested, as outlined in subparagraph (11)(A)(2) above, the information requested in writing is presumed to be subject to required public disclosure and must be released unless there is a compelling reason to withhold the information.

 

Tex. Gov’t Code § 552.302.

 

C.        Issuance of Attorney General Decisions

 

The attorney general shall render the decision not later than the 45th working day after the date the attorney general received the request.  The attorney general may extend the period for response by an additional 10 working days by informing the school and the requestor, during the original 45-day period, of the reason for the delay.

 

Tex. Gov’t Code § 552.306.

 

12.       Criminal Violations

 

A.        Destruction, Removal, or Alteration of Public Information

 

A person commits an offense if the person willfully destroys, mutilates, removes without permission, or alters public information.  An offense hereunder is a misdemeanor punishable by:

 

(1)        A fine of not less than $25 or more than $4,000;

 

(2)        Confinement in the county jail for not less than three (3) days or more than three (3) months; or

 

(3)        Both the fine and confinement.

 

Tex. Gov’t Code §552.351.

 

B.         Distribution of Confidential Information

 

A person commits an offense if the person distributes information considered confidential under the terms of this policy.  An offense hereunder is a misdemeanor constituting official misconduct punishable by:

 

(1)        A fine of not more than $1,000;

 

(2)        Confinement in the county jail for not more than six (6) months; or

 

(3)        Both the fine and confinement.

 

Tex. Gov’t Code §552.352.

 

C.        Failure or Refusal to Provide Access to or Copying of Public Information

 

(1)        The officer for public information or his/her designee commits an offense if s/he fails or refuses to give access to, or to permit or provide copying of, public information to a requestor as provided by this policy.  An offense hereunder is a misdemeanor constituting official misconduct punishable by:

 

(a)        A fine of not more than $1,000;

 

(b)        Confinement in the county jail for not more than six (6) months; or

 

(c)        Both the fine and confinement.

 

Tex. Gov’t Code § 552.353(e)-(f).

 

(2)        It is an affirmative defense to prosecution for failing to provide proper access that the officer for public information reasonably believed that public access to the requested information was not required, and that the officer:

 

(a)        Acted in reasonable reliance on a court order or a written interpretation of Tex. Gov’t Code, Chapter 552 contained in an opinion of either a court of record, or of the attorney general issued in response to an opinion request.

 

(b)        Requested a decision from the attorney general and the decision is pending; or

 

(c)        Not later than the 10th calendar day after the date of receipt of a decision by the attorney general that the information is public, and filed a proper legal action against the attorney general seeking relief from compliance with the attorney general’s decision, and such petition is pending.

 

Tex. Gov’t Code § 552.353(b)-(c).

 

(3)        It is an affirmative defense to prosecution for failing to provide proper access to public records that the defendant is the agent of an officer for public information and that the agent reasonably relied on the written instruction of the officer for public information not to disclose the public information requested.

 

Tex. Gov’t Code § 552.353(d).