Disclosure of Cell Phone Records of Private Citizens In Pennsylvania
In Tribune-Review Publ'g Co. v. Bodack, 875 A.2d 402 (Pa. Cmwlth. 2005) the Court considered that cell phone records of a member of a city council fit within the personal security exception because disclosing the identities and telephone numbers of private citizens who called and were called would violate a legitimate expectation of privacy and could impair their reputations or threaten their security.
The Pennsylvania Higher Education Assistance Agency (PHEAA) asserts that several documents contain the names of private citizens who met with PHEAA officials or attended retreats who have not consented to disclosure and who had a reasonable expectation that their identities would be kept confidential.
The Reporters reply that PHEAA retreats are not conducted in secret, nor was any evidence offered of any attendee's expectation of privacy or efforts to shield identities.