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PR15-11 Paiva v. Rhode Island Department of Corrections -Violation Found

Complainant submitted an APRA request for copies of employment applications and the name and contact information for the doctors' medical insurance carriers. The Department of Corrections ("DOC") denied Complainant's request on the basis that disclosure would constitute a "clearly unwarranted invasion of personal privacy." See R.I. Gen. Laws ยง 38-2-2(4)(A)(I)(b). With respect to one employment application (our investigation revealed that the second employment application did not exist), we concluded that the public interest outweighed the privacy interest asserted by DOC, and that disclosure of the employment application, after redacting the information contained in the employment application that would constitute a "clearly unwarranted invasion of personal privacy," would advance that interest. See Jackson v. Town of Coventry, PR 14-35. With respect to the name and contact information of the doctors' medical insurance carriers, we concluded that the insurance information sought would "reveal[] little or nothing about [DOC's] own conduct," and that even the most minimal privacy interest outweighed the non-existent "public interest." See Reporters Comm., 489 U.S. at 749, 109 S.Ct. at 1481-82. FULL CITE Therefore, we found that DOC violated the APRA when it denied access to the employment application en toto.

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