Can a city release employee names, resumes, job titles, and salaries in response to an Arkansas FOIA request?

Currency note

This opinion was issued in 2013. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Plain-English summary

The City of Little Rock's Labor and Employee Relations Manager, acting as records custodian, asked the Attorney General to confirm that releasing the names, job applications and resumes, job titles, and compensation information of City Manager's Office employees hired from 2001 to the present, in response to a FOIA request, was consistent with the Freedom of Information Act. She had already decided the records were personnel records subject to disclosure and wanted the office's sign-off.

The Attorney General declined to directly review this particular request because of a procedural timing problem with when the review was sought. Instead, the opinion attached two of the office's earlier opinions addressing materially similar requests, which together establish that basic employment information (names, job titles, departments, salaries, job applications, and resumes) is properly classified as a "personnel record" under the FOIA, and that this category of information is open to public inspection unless withholding it is necessary to prevent a "clearly unwarranted invasion of personal privacy," a standard that basic employment and compensation data essentially never satisfies given the public's substantial interest in knowing who works for it and what it pays them.

Background and analysis (as of 2013)

Arkansas's FOIA lets a records custodian, a requester, or the subject of personnel or employee evaluation records ask the Attorney General for an opinion on whether the custodian's disclosure decision is consistent with the Act. Here, the opinion found a procedural defect in the timing of the request and declined to issue a substantive ruling, but attached its 2011 opinion to the state's Office of Personnel Management (concerning statewide salary data below $100,000) and its 2005 opinion to the Mayor of Searcy (concerning police officer personnel and internal affairs files) as directly relevant guidance.

Those enclosed opinions lay out the framework: FOIA's "public records" definition presumptively covers records maintained by public employees within the scope of their employment, and the FOIA's personnel-records exemption only withholds material whose disclosure would be a "clearly unwarranted invasion of personal privacy," a standard requiring a balancing test (from Young v. Rice) that weighs the public's interest in disclosure against the individual's privacy interest, with the custodian bearing the burden of proving any exemption applies. Because the public, as employer, has a substantial and recognized interest in knowing whom it employs and what it pays them, the enclosed opinions found employee names, job titles, departments, and salary figures routinely fail to clear the "clearly unwarranted" bar and must be disclosed. The 2005 Searcy opinion went further, walking through specific categories of documents in police personnel and internal affairs files, redactable items like home addresses, Social Security numbers, driver's license numbers of third parties, and the identities of officers currently working undercover, versus generally releasable items like job applications, resumes, and reference letters (redacted only as needed), while cautioning that any redaction must be visibly indicated on the released record rather than silently blanked out.

Citations and references

Statutes (as they stood in the respective opinion years):

• A.C.A. § 25-19-105(c)(3)(B)(i), authorizing a records custodian, requester, or record subject to seek an Attorney General opinion on a disclosure decision
• A.C.A. § 25-19-103(5)(A), defining "public records" and the presumption that records maintained within the scope of public employment are public
• A.C.A. § 25-19-105(b)(12), the personnel-records exemption for information whose disclosure would be a "clearly unwarranted invasion of personal privacy"
• A.C.A. § 25-19-105(b)(13), the home-address exemption applied in redacting personnel and police files
• A.C.A. § 25-19-105(c)(1), the separate, more protective standard for "employee evaluation or job performance records"

Cases:

• Young v. Rice, 308 Ark. 593 (1992), the balancing test weighing public interest in disclosure against individual privacy interests, and the presumption that records kept within the scope of public employment are public
• Stilley v. McBride, 332 Ark. 306 (1998), an individual's privacy interest in nondisclosure is "not insubstantial" where there's little relevant public interest, and the burden falls on whoever resists disclosure
• Orsini v. State, 340 Ark. 665 (2000), the burden of proving a FOIA exemption rests with the records custodian claiming it

Source

• Landing page: https://arkansasag.gov/divisions/opinions-foia/attorney-general-opinions-search/

Original opinion text

STATE OF ARKANSAS

THE ATTORNEY GENERAL
DUSTIN McDANIEL

Opinion No. 2013-137

October 29, 2013

Ms. Stacey Witherell

Labor and Employee Relations Manager
City of Little Rock

500 West Markham, Suite 130W

Little Rock, Arkansas 72201-1428

Dear Ms. Witherell:

You have requested my opinion regarding the Arkansas Freedom of Information Act ("FOIA"). Your request, which is made as the records custodian, is based on A.C.A. § 25-19-105(c)(3)(B)(i) (Supp. 2013). This subsection authorizes the custodian, requester, or the subject of personnel or employee evaluation records to seek an opinion from this office stating whether the custodian's decision regarding the release of such records is consistent with the FOIA.

Your letter indicates that someone has requested employment information regarding "all regular and limited service, full-time employees and all regular and limited service, part- time employees hired within the City Manager's Office from January 2001 to [the] present date." The information requested includes name, job application and resume, job title, along with other employment information, including compensation. You have determined that the information qualifies as a personnel record of the individual employees and that the FOIA requires the information be released. You ask whether these decisions are consistent with the FOIA.

RESPONSE

I must decline to specifically address your decision due to some procedural irregularities regarding the timeliness of your request for my review. Instead, I will simply enclose for your reference a few past opinions, which indicate that the kind of information being requested here is properly classified as a personnel record and is generally subject to disclosure.

323 CENTER STREET, SUITE 200 * LITTLE ROCK, ARKANSAS 72201 TELEPHONE (501) 682-2007 * FAX (501) 682-8084 INTERNET WEBSITE * http://www.ag.state.ar.us/

Stacey Witherell

City of Little Rock
Opinion No. 2013-137
Page 2

Assistant Attorney General Ryan Owsley prepared this opinion, which I hereby approve. Sincerely,

DUSTIN MCDANIEL
Attorney General

DM:RO/cyh

Enclosures

Enclosure 1:

STATE OF ARKANSAS

THE ATTORNEY GENERAL
DUSTIN McDANIEL

Opinion No. 2011-045

April 4, 2011

Ms. Kay Barnhill Terry

State Personnel Administrator

Office of Personnel Management
Department of Finance and Administration
1509 West Seventh Street, Suite 201

Little Rock, Arkansas 72203-3278

Dear Ms. Terry:

I am writing in response to several requests, made pursuant to A.C.A. § 25-19- 105(c)(3)(B), for my opinion on whether the release of certain records in the Arkansas Administration Statewide Information System or "AASIS" would be consistent with the Arkansas Freedom of Information Act ("FOIA"), codified at A.C.A. §§ 25-19-101 to -110 (Repl. 2002 and Supp. 2009). The requests reference an email to Richard Weiss, Director of Finance and Administration, received from Gavin Lesnick of ArkansasOnline for an electronic copy of the name, job title, department and annual salary of all state employees who make less than $100,000.

It is my understanding that your office intends to release the requested information, to the extent it is included in the requested database.

RESPONSE

My duty under A.C.A. § 25-19-105(c)(3)(B) is to determine whether a custodian's decision regarding the disclosure of certain employee-related documents is consistent with the FOIA. In the present case, the custodian has determined that the requested records are personnel records and should be released. In my opinion the custodian's decision is consistent with the FOIA.

323 CENTER STREET, SUITE 200 * LITTLE ROCK, ARKANSAS 72201 TELEPHONE (501) 682-2007 * FAX (501) 682-8084 INTERNET WEBSITE * http://www.ag.state.ar.us/

Kay Barnhill Terry, State Personnel Admin.
Office of Personnel Management, DF&A
Opinion No. 2011-045

Page 2

The FOIA provides for the disclosure upon request of certain "public records," which the Arkansas Code defines as follows:

"Public records" means writings, recorded sounds, films, tapes, electronic or computer-based information, or data compilations in any medium, required by law to be kept or otherwise kept, and which constitute a record of the performance or lack of performance of official functions which are or should be carried out by a public official or employee, a governmental agency, or any other agency wholly or partially supported by public funds or expending public funds. All records maintained in public offices or by public employees within the scope of their employment shall be presumed to be public records.

A.C.A. § 25-19-103(5)(A) (Supp. 2009).

Given that the subjects of the request are public employees, I believe documents containing the requested information clearly qualify as "public records" under this definition. As one of my predecessor noted: "If records fit within the definition of 'public records' ..., they are open to public inspection and copying under the FOIA except to the extent they are covered by a specific exemption in that Act or some other pertinent law." Op. Att'y Gen. 99-305.

The pertinent exemption in this instance is the one for "personnel records." A.C.A. § 25-19-105(b)(12) (2007). This office has previously opined that "records relating to [an employee's] hiring date and salary information are clearly 'personnel records' for purposes of the FOIA." Op. Att'y Gen. 2004-320. Additionally, as a general rule the name of a public employee, like salary information, is contained in records that are properly classified as "personnel records." Op. Att'y Gen. Nos. 2005-074 and 2003-095, and opinions cited therein.

"Personnel records" are open to public inspection and copying under the FOIA, except "to the extent that disclosure would constitute a clearly unwarranted invasion of personal privacy." A.C.A. § 25-19-105(b)(12) (Supp. 2009). The FOIA does not define the phrase "clearly unwarranted invasion of personal privacy." However, the Arkansas Supreme Court has construed the phrase and adopted a balancing test to determine if it applies, weighing the interest of the

Kay Barnhill Terry, State Personnel Admin.
Office of Personnel Management, DF&A
Opinion No. 2011-045

Page 3

public in accessing the records against the individual's interest in keeping the records private. Young v. Rice, 308 Ark. 593, 826 S.W.2d 252 (1992). If the public's interest outweighs the individual's interest, the custodian must disclose the personnel records. As the court noted in Young:

The fact that section 25-19-105(b)(10) [now subsection 105(b)(12)] exempts disclosure of personnel records only when a clearly unwarranted personal privacy invasion would result, indicates that certain "warranted" privacy invasions will be tolerated. Thus, section 25-19-105(b)(10) requires that the public's right to knowledge of the records be weighed against an individual's right to privacy.... Because section 25-19-105(b)(10) allows warranted invasions of privacy, it follows that when the public's interest is substantial, it will usually outweigh any individual privacy interests and disclosure will be favored.

308 Ark. at 598. (Emphasis added).

However, as the court noted in Stilley v. McBride, 332 Ark. 306, 312, 965 S.W.2d 125 (1998), when there is "little relevant public interest" in disclosure, "it is sufficient under the circumstances to observe that the employees' privacy interest in nondisclosure is not insubstantial." Given that exemptions from disclosure must be narrowly construed, it is the burden of an individual resisting disclosure to establish that his privacy interests outweighed that of the public's under the circumstances presented. Id. at 313.

At issue, then, is whether disclosing documents that record an employee's name, job title, department and salary would amount to a "clearly unwarranted invasion of personal privacy" under this balancing test. In my opinion, it would not. Numerous previous opinions of this office support the conclusion that the public interest in this type of basic employment information is substantial and any potential privacy interest does not outweigh it. E.g., Op. Att'y Gen. 2008-050, citing Op. Att'y Gen. Nos. 2007-001, 2005-194, 2005-057, 2004-225, and 2002-

87. See also Op. Att'y Gen. 2005-074 (citing a number of previous opinions to
    the effect that the names of public employees are generally subject to disclosure, including Op. Att'y Gen. 90-335 ("[t]he 'public' is the employer of these individuals, and pays their salaries [and] [i]t is not unreasonable to expect that an

Kay Barnhill Terry, State Personnel Admin.
Office of Personnel Management, DF&A
Opinion No. 2011-045

Page 4

employer would have an interest in knowing whom it employs[;]") and Op. Att'y Gen. 95-220 ("[c]ourts have found relatively little privacy interest in records revealing names of public employees.")); Op. Att'y Gen. 2003-298 ("[T]he public interest in obtaining salary information relating to public employees, including the identity of particular employees, outweighs the employees' privacy interests."); 98-126 ([S]alary information is clearly subject to disclosure, as such information does not constitute a "clearly unwarranted invasion of personal privacy[,]" citing Op. Att'y Gen. Nos. 96-205, 95-242, 95-070, and 94-198.).

It is therefore my opinion that the public interest prevails with respect to this basic employment information and the custodian's decision to release a record listing employees' names, job titles, departments and salaries is consistent with the FOIA.

Deputy Attorney General Elisabeth A. Walker prepared the foregoing opinion, which I hereby approve.

Sincerely,

DUSTIN MCDANIEL
Attorney General

DM:EAW/cyh

Enclosure 2:

THE ATTORNEY GENERAL
STATE OF ARKANSAS
MIKE BEEBE

Opinion No. 2005-268

November 21, 2005

The Honorable Belinda LaForce
Mayor, City of Searcy

401 West Arch Avenue

Searcy, AR 72143-5202

Dear Mayor LaForce:

You have requested my opinion regarding application of the Arkansas Freedom of Information Act ("FOIA"), A.C.A. §§ 25-19-101 to -109 (Repl. 2002 and Supp. 2005). You have submitted your request pursuant to A.C.A. § 25-19-105(c)(3)(B), which authorizes the custodian, requester, or subject of personnel or evaluation records to seek an opinion from the Attorney General as to whether the custodian's determination regarding the release of the requested records is consistent with the FOIA.

You state that the City of Searcy has received a request from The Daily Citizen, a newspaper in White County, for personnel files of five (5) Searcy police officers. You state that "[b]ecause the records requested are personnel records which contain private information in which the employee holds a valid privacy interest, the City of Searcy requests an opinion addressing the following questions:"

1) Whether this request poses an unwarranted invasion of personal privacy because it makes no showing of a valid public interest in disclosure of these personnel files;

2) Whether the file maintained by the city as the "police file" is subject to release as a personnel file;

3) In the event the city is required by FOIA to disclose its

employees' personnel files, has the city fairly and accurately

323 CENTER STREET, SUITE 1100 * LITTLE ROCK, ARKANSAS 72201

TELEPHONE (501) 682-2007 * FAX (501) 682-8084
INTERNET WEBSITE * http://www.ag.state.ar.us/

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 2

redacted the information so that it is disclosing only that content required to be disclosed and, therefore, not in violation of the employee's privacy rights ... and

4) In the event the city is required by FOIA to disclose its employees' "police" files, has the city fairly and accurately redacted the information so that it is disclosing only that content required to be disclosed and, therefore, not in violation of the employee's privacy rights[?]

You have provided complete copies of all of the employees' "personnel files" and "police files" for my review and have enclosed separate copies with proposed redactions and omissions for each (comprising three volumes and several hundred pages).

RESPONSE

I must note that you have not indicated what your decision is concerning the release of the requested records. I am directed by law to evaluate the determination that is made by the custodian of the records concerning the release of requested records. A.C.A. § 25-19-105(c)(3)(B). My statutory duty under A.C.A. § 25-19-105(c)(3)(B) is to state whether the custodian's decision is consistent with the FOIA. As a consequence, I am not authorized or required to answer specific questions posed by custodians. I am not authorized to advise the custodian in making his or her decision. Such advice should be obtained from the city attorney.

Nevertheless, because you have expressed a concern about violating the privacy interests of these city employees, I will respond to your questions to the extent necessary to set forth the principles that should govern a decision concerning the release of the requested records. To summarize my conclusion with regard to release of these files, as I have previously concluded, "a number of documents contained in personnel files are typically releasable . . . with appropriate redactions." Op. Att'y. Gen. 2004-058. See also, Op. Att'y. Gen. 2005-011.

As an initial matter, an FOIA requester is not required to "make[] [a]... showing of a valid public interest in disclosure" as you suggest in your first question. The public policy behind the FOIA indicates that public records are presumed to be open. See Young v. Rice, 308 Ark. 593, 596, 826 S.W.2d 252 (1992) ("[u]nder our

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 3

FOIA, records kept in the scope of public employment are presumed to be public records"). The records are to be closed only if they fit within one of the specific exemptions. Id. See also, Ops. Att'y. Gen 1997-071 and 1991-390. It is clear with regard to the exemptions for personnel and evaluation records that "the keeper of the requested records has the burden of proving the records are exempt from disclosure." Young v. Rice, 308 Ark. 593, 596, 826 S.W.2d 252 (1992). See also, Orsini v. State, 340 Ark. 665, 670, 13 S.W.3d 167 (2000) ("[t]he burden of proving exemptions to the FOIA rests with the keeper of the requested records claiming the exemption").

With regard to the distinction you make between the "personnel files" and the "police files" of the officers in question, I will repeat my conclusion in Op. Att'y. Gen. 2003-316 as follows:

It should be noted that the fact that a record is not maintained in an employee's personnel file does not preclude a conclusion that it constitutes a personnel record or an employee evaluation/job performance record. This office has consistently opined that the location of documents is not determinative of how a document should be classified, and the location of documents should be irrelevant when considering the application of particular exemptions under the FOIA. See, e.g., Ops. Att'y Gen. Nos. 2000-225; 1998-127; 1992-237 at n. 2; 91-123; 91-100.

Id. at 3.

You state that the newspaper has made "an oral request for the personnel files" of the various officers. (Emphasis added). The only possible relevance of a distinction between any records contained in the "personnel files" and the records contained in the "police files" would be for purposes of determining whether the records in the police files have in fact been requested by the newspaper. Because the request was an oral one, I am not in a position to make any determination with regard to this issue. In any event, that matter may presumably be quickly determined by further communication with the requester.

The FOIA provides an exemption for "personnel records to the extent that disclosure would constitute a clearly unwarranted invasion of personal privacy." A.C.A. § 25-19-105(b)(12) (Supp. 2005). "Employee evaluation or job

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 4

performance records," on the other hand, are releasable only upon final administrative resolution of a suspension or termination proceeding, where the records formed a basis for the suspension or termination, and there is a compelling public interest in disclosure. A.C.A. § 25-19-105(c)(1) (Supp. 2005).

With regard to any appropriate redactions or omissions in the area of personnel records, I have previously stated that:

A number of documents contained in personnel files are typically releasable under this standard, with appropriate redactions. Over the years, the Attorney General's Office has issued numerous opinions discussing the public nature of various types of documents contained in personnel files. Recent opinions on this topic are posted on our official website (www.ag.state.ar.us) and may assist the Department and its counsel in making determinations as to particular records. The fact that the employee considers the "items in his personnel file to be of no public interest and mostly personal in nature" is irrelevant to the Department's decision with regard to release of the records. See, e.g., Ops. Att'y Gen. 2004-258; 2001-112; 2001-022; 1994-198; 1994-178; and 1993-055.

Opinion 2005-011 at 3-4.

In the area of employee evaluations or job performance records, the records may not be released absent a suspension or termination and fulfillment of all the remaining factors.

Finally, I will note that the redacted copies of records you include do not appear to comply with A.C.A. § 25-19-105(j)(3) (Supp. 2005), which requires that the "amount of information deleted shall be indicated on the released portion of the record and, if technically feasible, at the place in the record where the deletion was made." The redactions you have made, for the most part, leave blank spaces on various forms and records. There is no black-lining or other obvious indication as to where information has been redacted. The information to be redacted has simply been shielded temporarily and then copied over. It will not always be possible for the requester to tell from these redactions where redactions were made, or whether in fact particular blank spaces also were left blank in the

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 5

complete un-redacted record. Any redactions, if technically feasible, should be "indicated" on the released portion of the record. A.C.A. § 25-19-105(j)(3). In my opinion, if possible, this requirement must accommodate the requester's right to know if and where information was redacted.

Turning now to the records in question, you have made a number of required redactions to comply with the FOIA and the exemptions thereto. Although in large measure, the redactions are consistent with the FOIA, I have identified a few items that you have redacted that in my opinion should not be redacted and a few items that you have not redacted that should in my opinion be redacted. Specifically, I will list below a few items where I deem your proposed redactions (or lack thereof), inconsistent with the FOIA:

1st Officer
Police File

Items that should not be redacted

• Reference to political candidacy on a biographical questionnaire. In my
  opinion this reference is contained in a "personnel record" and its release would not give rise to a "clearly unwarranted invasion of personal privacy." A.C.A. § 25-19-105(b)(12) (Supp. 2005).

• October 1, 2003 letter from federal government. This document appears to
  be a personnel record the release of which would not in my opinion give rise to a clearly unwarranted invasion of personal privacy. Id. Prudence may dictate consultation with the federal agency to determine whether any federal law requires its confidentiality, however.

Additional items that should be redacted

• Photocopy of citizen driver's license. See Op. Att'y. Gen. 2005-202,
  (citing the federal "Drivers' Privacy Protection Act").

• Home address on duplicate oath. See A.C.A. § 25-19-105(b)(13) (Supp.
  2005).

• One un-redacted training score on "internal audit report." See Ops. Att'y.
  2005-113 and 2004-178.

• Any reference to the identities of officers "currently" working undercover.
  See A.C.A. § 25-19-105(10)(A) (Supp. 2005). I cannot tell whether this exemption applies to the references in question.

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 6

Documents that should not be withheld entirely

• Verification of address. This document should be redacted in my opinion,
  rather than withheld entirely.

2nd Officer
Personnel file
Items that should not be redacted

• Race or ethnic group on initial employment report. See Op. Att'y. Gen.
  2005-1001 and 2004-256.

Additional items that should be redacted

• Scores on Department of Health letter (dated January 3, 1986). See Ops.
  Att'y. 2005-113 and 2004-178.

Documents that should not be withheld entirely

• Personal history statement. See Op. Att'y. Gen. 2001-080. This document
  should be released with appropriate redactions.

• December 5, 1982 letter regarding completion of background investigation.
  Cf Op. Att'y Gen. 2001-080.

3rd Officer
Police file

Additional items that should be redacted

• One un-redacted training score on "Internal Audit Report." See Ops. Att'y.
  2005-113 and 2004-178.

Documents that should not be withheld entirely

• Job application documents. See e.g., Op. Att'y. Gen. 2005-004 (exempt
  information should be redacted).
• Resume. See e.g., Op. Att'y. Gen. 2001-091 (exempt information should be
  redacted).

The Honorable Belinda LaForce
Mayor, City of Searcy
Opinion No. 2005-268

Page 7

Handwritten supervisor note of 5-5-92 (appears to be a disclosable personnel record). See A.C.A. § 25-19-105(b)(12).

Document evidencing completion of psychological examination. See Op. Att'y. Gen. 2001-080.

Personal history statement. See Op. Att'y. Gen. 2001-080. This document should be released with appropriate redactions.

Initial employment report. Cf Op. Att'y. Gen. 2001-080. This document should be released with appropriate redactions.

4th Officer

Police file

Items that should not be redacted

Ethnic group on Initial Employment Report. See e.g., Ops. Att'y Gen. 2005-100 and 2004-256.

Additional items that should be redacted

Home address on "Personal Information Data" form. See A.C.A. § 25-19- 105(b)(13) (Supp. 2005).

Scores on September 9, 1985 training letter. See Ops. Att'y. 2005-113 and 2004-178.

Social security number on September 4, 1985 letter from Commission on Law Enforcement.

Several separate references to driver's license numbers of citizens. See Op. Att'y. Gen. 2005-202 (citing the federal "Drivers' Privacy Protection Act"). Any reference to the identities of officers "currently" working undercover. See A.C.A. § 25-19-105(10)(A) (Supp. 2005). I cannot tell whether this exemption applies to the references in question.

Documents that should not be withheld entirely

September 10, 1985 letter regarding completion of background investigation. Cf Op. Att'y Gen. 2001-080.

Document evidencing completion of psychological examination. See Op. Att'y. Gen. 2001-080.

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 8

• Personal history statement. See Op. Att'y. Gen. 2001-080. This document
  should be released with appropriate redactions.

Personnel File

Additional items that should be redacted

• Un-redacted home address on Verification of Address form. See A.C.A. §
  25-19-105(b)(13) (Supp. 2005).

Documents that should not be withheld entirely

• Confidential employee history. Cf Op. Att'y Gen. 2001-080. This
  document should be released with appropriate redactions.

Documents that should be withheld

• Three consecutive documents regarding certain payroll deductions.

5th Officer
Police File
Items that should not be redacted

• Race or ethnic group on Application for Police Training. See Op. Att'y.
  Gen. 2005-100 and 2004-256.

Documents that should not be withheld entirely

• Letter of recommendation dated April 23, 1984. See Op. Att'y. Gen. 2003-
  016.

• Authorization to Release Information Form (dated April 6, 1984). In my
  opinion this form is a personnel record the release of which would not give rise to a "clearly unwarranted invasion of personal privacy."

• Personal history statement. See Op. Att'y. Gen. 2001-080. This document
  should be released with appropriate redactions.

• Form letter seeking references. In my opinion this form letter is a
  personnel record the release of which would not give rise to a "clearly unwarranted invasion of personal privacy."

The Honorable Belinda LaForce
Mayor, City of Searcy

Opinion No. 2005-268

Page 9

Deputy Attorney General Elana C. Wills prepared the foregoing opinion, which I hereby approve.

Sincerely,

MIKE BEEBE
Attorney General

MB:ECW/cyh