~ government employee job applications ~

Subscribers to the California First Amendment Coalition (CFAC) are periodically sent emails with answers by their lawyers to questions about public records access. A recent query concerned government employee job applications.

Are employment applications of current or past employees of government bodies that are subject to the Brown Act open to public disclosure? I assume that some information falls under the personnel privacy exemption (e.g. SSN) but would the government body be required by the Brown Act to provide a redacted employee application if so requested?

CFAC concludes that these records fall under the California Public Records Act (PRA) but that personal identifiers such as social security numbers could be redacted. They cite the following case.

"[I]nformation as to the education, training, experience, awards, previous positions and publications of the [employee] is routinely presented in both professional and social settings, ... and implicates no applicable privacy or public policy exemption." Eskaton Monterey Hospital v. Myers, 134 Cal. App.3d 788 (3d Dist. 1982).

A good source for access laws in all 50 states is the Citizen Access Project.