HomeMy WebLinkAboutPolicy 05-B - Records Policy and Procedures - AccessibilityOTAY WATER DISTRICT
BOARD OF DIRECTORS POLICY
Subject Policy
Number
Date
Adopted
Date
Revised
RECORDS POLICY AND PROCEDURES -
ACCESSIBILITY 05-B 02/03/10 05/01/19
Page 1 of 5
PURPOSE
To set forth the procedures that will facilitate the process for
responding to requests under the California Public Records Act
(“CPRA”).
POLICY
The CPRA permits local agencies to adopt regulations stating the
procedures to be followed when making their records available to the
public. The Otay Water District’s Board of Directors desires to set
forth the procedures by which such records will be made available to
the public. The Board is mindful of the constitutional right of privacy
accorded to individuals and it is the intent of the Board to promulgate
a policy that strikes an appropriate balance between the objectives of
open government and the individual’s right of privacy.
PROCEDURES
Records Available for Inspection and Copying
Except for records exempt from disclosure by express provisions of
law, records available for inspection and copying include any
writing containing information relating to the conduct of the
public’s business that is prepared, owned, used, or retained by
the District, regardless of the physical form and characteristics.
The records do not have to be written but may be in another format
that contains information such as computer tape or disc or video
or audio recording.
“Writing” includes any handwriting, typewriting, printing,
photographing, and every other means of recording upon any form of
communication or representation such as letters, words, pictures,
sounds, or symbols, as well as all papers, maps, magnetic or paper
tapes, photographic films and prints, and electronic mail.
Making a Request for Records
There is no specific form that must be used to request records.
Requests may be made orally or in writing and may be delivered in
person, through the mail, via e-mail or via facsimile. The request
must contain a reasonable description of the desired records.
When an oral request is received, the District may request that
the public records request be confirmed in writing. The District
may also follow-up verbally or in writing to clarify or eliminate
OTAY WATER DISTRICT
BOARD OF DIRECTORS POLICY
Subject Policy
Number
Date
Adopted
Date
Revised
RECORDS POLICY AND PROCEDURES -
ACCESSIBILITY 05-B 02/03/10 05/01/19
Page 2 of 5
any confusion concerning a request. Requests must be submitted to
the District Secretary.
Locating and Identifying Records
Public records are open to inspection at all times during regular
District business hours. The District Secretary shall be
responsible for responding to records requests and coordinating
with the various departments within the District to compile
documents and information responsive to such requests.
If a request for records seeks the production of records or
documents that are not in existence at the time the request is
made, the District is not obligated to create a document in order
to respond to the request.
Form of Records Provided
Records will be made available in their original form or by a true
and correct copy. Audio, photographic and computer data, or any
other such records, shall be exact replicas unless the District
determines it is impracticable to provide exact replicas. Any
reasonably segregable portion of a record shall be provided to the
public after deletion of portions that are deemed exempt from
disclosure.
Common Exemptions
Certain categories of documents are generally not subject to
disclosure. These include, but are not limited to: (1) preliminary
drafts of certain documents that are not retained by the District
in the ordinary course of business; (2) records related to pending
litigation; (3)attorney-client communications; (4) personnel
records, medical information, or other similar records the
disclosure of which would constitute an unwarranted invasion of
personal privacy; (5) corporate financial and proprietary
information, including trade secrets; and (6) records protected by
State or Federal law.
Time for Response
Upon receipt of a request for records, the District shall make the
records promptly available to the requestor. When a copy of a
record is requested, the District shall determine within ten (10)
calendar days whether to comply with the request, and shall
OTAY WATER DISTRICT
BOARD OF DIRECTORS POLICY
Subject Policy
Number
Date
Adopted
Date
Revised
RECORDS POLICY AND PROCEDURES -
ACCESSIBILITY 05-B 02/03/10 05/01/19
Page 3 of 5
promptly inform the requestor of the District’s decision and
reasons therefor.
In unusual circumstances, as defined in the CPRA, the initial ten
(10) calendar day period to make a determination may be extended
for up to an additional fourteen (14) calendar days. If so, the
District will inform the requestor of the extension, in writing,
within the initial ten (10) day period, setting forth the reasons
for the extension, along with the estimated date of the District’s
further response.
If a written request for information is denied in whole or in
part, the denial shall be in writing and shall contain the reasons
for denial of access to the subject records.
Fees and Charges
The District charges for the direct costs of duplicating records)
and for the direct cost of postage and other delivery methods as
set forth on Appendix A to the District’s Code of Ordinance.
Requestors of electronic records shall pay for production costs,
including the cost to construct the record and the cost of
programming and computer services necessary to produce the copy if
response to the request requires the immediate production of a
record that is otherwise only produced at regularly scheduled
intervals, or if data compilation, extraction, or programming is
required to produce the requested record. However, the District
will not charge for access to electronic data that is accessible
in its existing form (including PDF copies of agenda items that
are provided in the form previously made available on the
District’s website) and that does not require staff to locate,
identify or extract data or to incur other costs to the District.
Responding to Requests for Particular Documents
The following procedures shall apply when responding to requests
for these particular categories of documents:
Disclosure of Litigation Materials
OTAY WATER DISTRICT
BOARD OF DIRECTORS POLICY
Subject Policy
Number
Date
Adopted
Date
Revised
RECORDS POLICY AND PROCEDURES -
ACCESSIBILITY 05-B 02/03/10 05/01/19
Page 4 of 5
1.When litigation in which the District is a party is finally
adjudicated or otherwise settled, records of communications
between the District and the adverse party in the litigation shall
be subject to disclosure including the text and terms of any
settlement agreement between the parties.
2.Such disclosure shall not apply to records that are otherwise
privileged under federal or state law, such as attorney-client
communications, or to records sealed by the court or where
disclosure is otherwise limited by the court.
Disclosure of Information Relating to Contracts, Bids and
Proposals
1.Records of contractors’ bids shall be available for
inspection immediately following the opening of bids.
2.Responses to Requests for Proposals, Qualifications or
Quotations and similar submittals shall be regarded as public
records and are available for inspection after District staff’s
recommendation has been made public, unless there are elements in
the proposal which are defined by the proposer as business or
trade secrets and plainly marked as “Confidential,” Trade Secret,”
or “Proprietary.” Although trade secret information may be exempt
from disclosure, the District typically is not in a position to
establish whether the information that a proposer has submitted is
a trade secret. If a request is made for information marked
“Confidential,” “Trade Secret,” or “Proprietary”, the District
will provide the proposer who submitted the information with
reasonable notice to allow the proposer to seek protection from
disclosure by a court or government agency of competent
jurisdiction.
3.When an individual, firm or organization is awarded a
contract, information including financial information which was
submitted to the District during the bid or proposal process from
all proposers will be subject to disclosure unless otherwise
exempt.
Budgetary Information
Budgetary information including bills or records of payments,
which are submitted to the District’s Board or other body having
budgetary authority, shall be subject to disclosure unless the
record is confidential or privileged under State or Federal law.
OTAY WATER DISTRICT
BOARD OF DIRECTORS POLICY
Subject Policy
Number
Date
Adopted
Date
Revised
RECORDS POLICY AND PROCEDURES -
ACCESSIBILITY 05-B 02/03/10 05/01/19
Page 5 of 5
Personal Information
Requests for records and documents containing personal information
such as social security numbers, home addresses, home telephone
numbers, financial matters, and medical or employment history,
should be reviewed on a case by case with the District’s General
Counsel. The District may respond to requests for personal
information in one or more of the following ways:
1.delete or redact those portions of the records that include
personal information and make the remaining portion of the record
available for inspection if the remaining portion of the record is
not otherwise exempt from disclosure;
2.notify the party whose personal information is being sought
and provide the party with the opportunity to initiate legal
proceedings or other appropriate process to prevent the release of
such information;
3.seek a judicial determination as to whether or not the
requested personal information should be disclosed; or
4.disclose the information where permitted, allowed or
compelled to do so.
Complaints and Complaint Information
Information regarding complaints shall be made available. However,
specific information about complainants shall be redacted from any
record furnished if necessary in order to protect the privacy
rights and safety of individuals making complaints and to protect
an individual’s right to petition government for redress of
grievances.
Electronic Mail
E-mail shall be treated the same as other written documents. If
the e-mail is kept in the ordinary course of business, it is a
public record unless it falls within some exception to disclosure
under the CPRA.