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From: Pro-SF [home@prosf.org]
Sent: Tuesday, November 03, 2009 7:38 AM
To: home@prosf.org
Subject: ProSF MetadataSF Witholding Information (Metadata) About The History,
Tracking / Management of an Electronic Document

Pro-SF Taxpayers Open Government Archive http://www.scribd.com/Public
%20Records%20Information%20Clearinghouse

Address: 250 Ashbury St. SF 94117: E home@prosf.org: Supporting Freedom of
Information, Government Transparancy & Accountability. Providing Public
Information To The Taxpayers/Residents of the City and County of San Francisco

From: kimocrossman@gmail.com [mailto:kimocrossman@gmail.com] On Behalf Of

Kimo Crossman
Sent: Monday, November 02, 2009 6:38 PM
To: Paul Zarefsky; buck.delventhal@sfgov.org; Paula Jesson; Matt Dorsey;

Cityattorney; SF City Attorney Supervisor of Records Adine Varah; Thomas Long;
Theresa Mueller; Pro-SF
Subject: Paul Zarefsky famous through erroneous advice on Metadata and
Public Records developed on city payroll in violation of Sunshine
http://calaware.typepad.com/calaware_today/2009/10/court-buried-metadata-
part-of-the-public-record.html

Friday, October 30, 2009
Court: Buried 'Metadata' Part of the Public Record
OPEN GOVERNMENT -- Are metadata the subsurface but accessible traces as to

\ufffd
the sources, dissemination, editing and other textual history of a Microsoft Word
document part of the public record that must be disclosed under the California
\ufffd
Public Records Act? A Deputy San Francisco City Attorney has been saying
No release Word documents only as inert pdfs. But now Arizona's Supreme Court, for
\ufffd
what it's worth, has ruled to the contrary.
UPDATE 2, 11/1/2009: Richard Knee, Chair of the San Francisco Sunshine
Ordinance Task Force, adds:

Paul Zarefsky's 2007 paper left out some important information. San
Francisco's Sunshine Ordinance (http://sfgov.org/sunshine), Sec. 67.24(a)(1),
declares that except in certain narrowly defined cases, "no preliminary draft or
department memorandum, whether in printed or electronic form, shall be exempt from
disclosure under Government Code Section 6254, subdivision (a) or any other
provision. If such a document is not normally kept on file and would otherwise be
disposed of, its factual content is not exempt under subdivision (a). Only the

recommendation of the author may, in such circumstances, be withheld as exempt."

The city's Sunshine Ordinance Task Force has consistently found in favor of
complainants who have requested electronic documents in their original format.
Besides pointing to 67.24(a)(1), the task force has held that metada are
disclosable public information, and that when a body of metadata contains
information that is barred or exempt from disclosure, the non-disclosable portion
must be segregated/redacted and the disclosable portion must be provided.

The bad news is that the task force has no power to penalize sunshine
scofflaws in city government; it must instead refer cases of willful violation to
the city's Ethics Commission, the Board of Supervisors, the district attorney or
the state attorney general. And those entities have invariably dismissed task
force-referred cases because respondents have said they were acting on advice from
the city attorney's office and were thus not willfully violating the ordinance in
withholding requested information.

The task force is trying to remedy this and other loopholes in the ordinance
through a package of amendments that it hopes to get on the local ballot in June
or November 2010.

UPDATE 10/31/2009: Hat tip to Kimo Crossman and David Akin for pointing up
the following example of what metadata can reveal.
Transparency advocates are excited about the ruling, because among other
\ufffd
things metadata has been useful in revealing the influence of lobbyists and other
\ufffd
special interests on the legislative process:

One of the most famous metadata lobbying goof-ups occurred in 2004, when
Wired busted California Attorney General Bill Lockyer circulating an anti-P2P
[peer-to-peer filesharing] letter that, after a look at its Word metadata,
appeared to have been either drafted or edited by the [Motion Picture Association
of America].

Here's how Deputy City Attorney Paul Zarefsky described the problem for
government agencies in a paper presented at a League of California Cities
conference in 2007.

A Word document, unlike a paper record or an electronic record in PDF form,
contains "metadata"
information about the record that does not appear in the
\ufffd

text but is automatically generated by the software program when a text is
created, viewed, copied, edited, printed, stored, or transmitted using a computer.
Metadata are typically embedded in the record in a manner not readily viewed

and
\ufffd
often not understood
by persons without specialized computer training. Indeed,
\ufffd

many persons who use a computer are unaware that Word documents contain metadata
or that electronic transmission of a Word document in that form includes not
merely the visible text but also the metadata. This paper uses the term
"metadata" broadly to include any information embedded in an electronic record
that is not visible in the text.

Metadata in a city document may include a wide variety of information that
the city has a right
and, in some cases, a duty
to withhold from public view.
\ufffd
\ufffd

For example, earlier versions of the electronic record are typically present in
metadata. Often they include recommendations, suggestions, "trial balloons," and
tentative ideas that have not been thought through; suggested edits, comments, and
criticisms from colleagues and supervisors; and words, phrases, sentences, and
even entire passages that solely reflect the author's thought process because they
were deleted early on by the author and thus never communicated to another person.

Thus, much information in metadata may arguably be withheld from disclosure under Section 6254(a) as preliminary drafts or notes, or under Section 6255(a) and the deliberative process privilege.

A second, different type of example arises from the law's special concern
for privacy rights. (Sections 6250, 6254(c); Cal. Const., Art. I, sec. 1.)
Earlier versions of an electronic record that are present in metadata may include
information the disclosure of which would violate a third party's privacy. A wide
range of types of information may be encompassed within the right of privacy, from
residential phone numbers and Social Security numbers to sensitive medical,
financial, and sexual data to information provided by, and the identity of,
whistleblowers. When a record is finalized and put forward for public view, it
hopefully will have been sufficiently reviewed to be sanitized of private
information. But earlier versions of the record may not have been crafted with
the same sensitivity to privacy that will have gone into the final document.

As a third example, metadata may include confidential communications between
attorney and client that do not appear in the text of the record. The law
protects such communications from disclosure and imposes on attorneys a duty not
to disclose such information. (Cal. Evid. Code 954; Cal. Bus. and Prof. Code

\ufffd
6068(e).) Thus, in response to a public records request of a city attorney's
\ufffdoffice, in many instances an attorney would be duty-bound to search the metadata

in electronic records as to which he or she may have had input, even if the record
on its face does not reveal an attorney-client communication. And if a city
department in custody of an electronic record that had been developed
collaboratively with its attorney disclosed the record as a Word document without
checking the metadata embedded in the record, it would run the risk of
inadvertently disclosing confidential attorney-client communications.

These examples
and more could be cited
merely illustrate the point that
\ufffd
\ufffd

metadata may contain information that is subject to redaction under the Act. If a city were to give a requester a document in Word form, the city would be required to review the metadata embedded in the document

or avoid doing so at its peril,
\ufffd

because failure to conduct this review would risk disclosure of privileged
material. Yet reviewing the metadata would be a laborious and problematic task\ufffd
different in nature and magnitude from the process of reviewing the text to
determine information that should be redacted and information that is reasonably
segregable from that which should be redacted.

While the paper cautions that the author's views are his own and not those of the City Attorney's Office, that office's advice to city agencies has been to convert Word documents to pdfs before release to the public.

Meanwhile, as noted yesterday by Ansley Schrimpf for the Reporter's
Committee for Freedom of the Press,
The Arizona Supreme Court today ruled that metadata
information about the
\ufffd
history, tracking and management of an electronic document
is subject to the
\ufffd
state s public records law.
\ufffd
Several national media organizations supported Phoenix police officer David
Lake s challenge that the city improperly denied his 2006 public records request
\ufffd
for the metadata about documents he had previously requested and received. The
city refused Lake s request, arguing the metadata did not fall within the state s
\ufffd
\ufffd
definition of public records, which a court established in 1952, long before the
advent of electronic documents.
In a unanimous opinion released today, the state s high court held, If a
\ufffd
\ufffd
of 00

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