Sapp Roofing Company, Inc. v. Sheet Metal Workers' International Association, Local Union No. 12

In Sapp Roofing Company, Inc. v. Sheet Metal Workers' International Association, Local Union No. 12, 552 Pa. 105, 110-11, 713 A.2d 627, 629 (1998), a labor union requested access to the payroll records of a school district for the stated purpose of ensuring the school district complied with prevailing wage requirements. In addition to wage information, the payroll records contained personal information, such as names, addresses, social security numbers, and phone numbers of employees. The Supreme Court of Pennsylvania refused to release the personal information stating, "disclosure ... reveals little, if anything, about the government's ... compliance with the Prevailing Wage Act." Sapp Roofing, at 112, 713 A.2d at 630. It did, however, allow disclosure of payroll information in redacted form.