Disclosure of a List Including Addresses and Social Security Numbers
In Bargeron v. Department of Labor and Industry, 720 A.2d 500 (Pa. Cmwlth. 1998), an attorney requested access to a list containing the names and addresses of parties involved in unemployment compensation litigation for the purpose of soliciting business.
Even though this Court held that the appellant had not shown the requested documents to be public records, we went on to hold that the personal security exception would otherwise have prevented disclosure. Bargeron, 720 A.2d at 503.
Applying the balancing test, the Court found that disclosure would constitute an invasion of personal privacy because the list included the addresses and social security numbers of claimants and employers, and that dissemination of the information would not further any public interest. Id. at 504.
In Weaver v. Department of Corrections, 702 A.2d 370 (Pa. Cmwlth. 1997), an inmate sought release of the Pennsylvania Additive Classification Tool (PACT) Manual used by the Department to assess inmates to determine the "level of danger posed by or to the inmate or the prison staff." Weaver, 702 A.2d at 372-373. Because the Department considers certain personality traits exhibited by the inmates when making this assessment, this Court found that an inmate with knowledge of the criteria used could manipulate the Department's assessment, to the danger of both staff and inmates. Id. at 373.
Indeed, this Court concluded that the PACT Manual was used to make "the most critical decision regarding a prisoner--what level of custody is appropriate regarding an assessment of the individual." Weaver, 702 A.2d at 372.
The Court therefore affirmed the Department and denied release of the PACT Manual.
Bargeron and Weaver are distinguishable.
Unlike Bargeron, where the requested records contained addresses and social security numbers--which could be used directly to invade the personal privacy of another--the definition of "inclement weather" does not implicate privacy or personal security in any way.