General Records Exemptions
74 Illinois PAC opinions and determination letters about general records exemptions.
General Records Exemptions: what the decisions show
General records exemptions cover public body claims that requested records may be withheld as private information, preliminary or deliberative material, commercial or trade secret information, or otherwise protected from disclosure. The requests in these decisions involved settlement agreements, license applications, utility bills, development and construction submissions, correspondence, datasets, videos, and medical or technical records.
Across these decisions, the Public Access Counselor has generally rejected broad or unsupported exemption claims and found violations where bodies withheld entire records or redacted names and factual material without showing the exemption applied. Limited exceptions were recognized where engineers’ technical submissions qualified as construction-related technical documents, and where records sought as copies were already available for inspection.
At a glance: 74 documents from 2014 to 2025(21 binding opinions, 53 determination letters). Outcome: 38 found a violation (in whole or part), 33 found none. Most often cited alongside: 7(1)(f) (Preliminary drafts, notes, and deliberative materials) (22); 7(1)(c) (Personal privacy) (19); 7(1)(a) (Federal/State-law confidentiality — or public defender case files, for documents issued under the other amendment version) (12); 7(1)(b) (Private information) (11); 7(1)(g) (Trade secrets and confidential commercial/financial information) (6).
Recurring issues
- Public bodies withheld settlement agreements based on confidentiality, nondisparagement, or privacy language in the agreements. (Settlement agreements for legal counsel payments, A settlement agreement in a federal lawsuit, Settlement agreements under the personal privacy exemption)
- Public bodies redacted names, addresses, and occupancy or licensing details as private information or under other confidentiality provisions. (Excel file of scattered-site unit addresses and occupancy status, Residential parking exception letters with names, Applications for cannabis cultivation center licenses)
- Public bodies withheld developer budgets, non-disclosure agreements, venue contracts, and test results as commercial, trade secret, or proprietary information. (A non-disclosure agreement for a commercial development project, Developer cost records for a city-funded redevelopment project, Contracts and correspondence for a concert at a public arena)
- Public bodies withheld correspondence, traffic data, presentations, and legal-related letters as preliminary, deliberative, attorney-client, or settlement-negotiation material. (Email attachments between school board members, Communications about a zoning change with a private applicant, Traffic count data from roadway monitoring)
Practical points
- A private confidentiality or nondisparagement provision does not by itself establish that a settlement agreement is exempt.
- Names and purely factual material should not be withheld without showing private, confidential, predecisional, or otherwise exempt circumstances.
- Construction-related technical submissions and records already made available for inspection have been treated differently from general commercial or administrative records.
Summary drafted from the linked decisions and checked against them; read the decisions themselves before relying on it. Not legal advice.
- Email attachments between school board membersBinding opinionViolation found
Improperly withheld records
- Construction documents for a solar facility permitBinding opinionNo violation
No violation found
- Settlement agreements for legal counsel paymentsBinding opinionViolation found
Improperly withheld records
- Excel file of scattered-site unit addresses and occupancy statusBinding opinionViolation found
Improperly withheld records
- A non-disclosure agreement for a commercial development projectBinding opinionViolation found
Improperly withheld records
- A private attorney's letter to a city law departmentBinding opinionViolation found
Improperly withheld records
- Communications about a zoning change with a private applicantBinding opinionViolation found
Improperly withheld records
- Residential parking exception letters with namesBinding opinionViolation found
Improperly withheld records
- Applications for cannabis cultivation center licensesBinding opinionViolation found
Improperly withheld records
- A school district's customer account information for water utilityBinding opinionViolation found
Violation found
- Developer cost records for a city-funded redevelopment projectBinding opinionViolation found
Improperly withheld records
- Traffic count data from roadway monitoringBinding opinionViolation found
Violation found
- A settlement agreement in a federal lawsuitBinding opinionViolation found
Improperly withheld records
- Contracts and correspondence for a concert at a public arenaBinding opinionViolation found
Improperly withheld records
- Surveillance video of a fatal rest-area accidentBinding opinionViolation found
Improperly withheld records
- Budget presentation for staff trainingBinding opinionViolation found
Improperly withheld records
- Settlement agreements under the personal privacy exemptionBinding opinionViolation found
Improperly withheld records
- Administrative directives available for inspection in a prison libraryBinding opinionNo violation
No violation found
- Autopsy reports for high-profile suicide deathsBinding opinionViolation found
Improperly withheld records
- Medical test results for workers' compensation claimsBinding opinionViolation found
Improperly withheld records
- Names of first-time freshmen and graduation statusesBinding opinionViolation found
Improperly withheld records
- Internal audit manual sections for tax enforcementDetermination letterNo violation
No violation found
- Records on animal use in a medical residency programDetermination letterNo violation
No violation found
- Construction cost projections for parking garagesDetermination letterViolation found
Improperly withheld records
- Animal research protocol and medical recordsDetermination letterViolation found
Improperly withheld records
- Technical specifications for a waste water treatment plantDetermination letterNo violation
No violation found
- Budget reports by a state budget office consultantDetermination letterViolation found
Improperly withheld records
- University records claimed exempt under personal privacyDetermination letterNo violation
Improperly withheld records
- Public aid assistance recordsDetermination letterNo violation
No violation found
- Blueprints for condominium unitsDetermination letterNo violation
No violation found
- Correspondence between state attorneys general on environmental policyDetermination letterNo violation
No violation found
- A proposed biogas production agreementDetermination letterNo violation
No violation found
- A corrections department's gang renunciation program recordsDetermination letterViolation found
Violation found
- Consultant's review of university athletics operations and contractDetermination letterNo violation
No violation found
- Internal policies and incident reporting procedures for a mental health centerDetermination letterViolation found
Improperly withheld records
- A city's bid proposal for a corporate headquartersDetermination letterNo violation
No violation found
- Staff Intensity Scale scores for intermediate care facilitiesDetermination letterViolation found
Improperly withheld records
- Correspondence about classroom observations and integrationDetermination letterPartial violation
Improperly withheld records
- Training presentation on sexual harassmentDetermination letterNo violation
No violation found
- Investment banking pitchbooks for pension bond salesDetermination letterNo violation
No violation found
- Security camera footage from a school eventDetermination letterPartial violation
Improperly withheld records
- A consultant's study of a fire department's operationsDetermination letterNo violation
No violation found
- Building permits and inspection records for commercial structuresDetermination letterNo violation
No violation found
- A mayor's text messages with city officialsDetermination letterPartial violation
Partial violation found
- An email about an incident logDetermination letterViolation found
Improperly withheld records
- A slide deck on civil unrest emergency response strategiesDetermination letterPartial violation
Improperly withheld records
- Parking ticket data fields from 2015 to 2022Determination letterViolation found
Improperly withheld records
- Emails from non-city accounts used by the mayorDetermination letterViolation found
Violation found
- A drainage district's maintenance assessment rolls and collector's booksDetermination letterViolation found
Improperly withheld records
- A summary of responses to an Invitation for ProposalsDetermination letterViolation found
Improperly withheld records
- Disciplinary case files of a state regulatory agencyDetermination letterNo violation
No violation found
- A private hospitality company's financial pro formaDetermination letterNo violation
No violation found
- Pension fund's redacted Real Estate Strategic PlanDetermination letterNo violation
No violation found
- GIS shapefiles of Combined Sewer Outfall pointsDetermination letterNo violation
No violation found
- Statistical data on FOID card issuance by year and areaDetermination letterNo violation
No violation found
- Emails withheld under attorney-client privilege and insurance exemptionsDetermination letterNo violation
No violation found
- Train platform video of a fall onto the tracksDetermination letterClosed no further action
Closed, no further action
- Athletic department correspondence with an NIL groupDetermination letterPartial violation
Partial violation found
- Redacted qualification test questions from emailsDetermination letterNo violation
No violation found
- Applications, scores, and evaluation notes for cultural districts programDetermination letterNo violation
No violation found
- List of adult library cardholdersDetermination letterClosed no further action
No violation found
- Investigative reports on sexual harassment allegationsDetermination letterPartial violation
No violation found
- Inventory records of lost or stolen electronic devicesDetermination letterNo violation
No violation found
- A school district's tip-line policies and security protocolsDetermination letterNo violation
No violation found
- Internal communications on a property development projectDetermination letterNo violation
No violation found
- A risk management report on building safetyDetermination letterNo violation
No violation found
- Emails with a contractor about curb and gutter workDetermination letterViolation found
Violation found
- Draft advertisements for a public safety sales taxDetermination letterNo violation
No violation found
- Waterfowl banding locations and identification numbersDetermination letterNo violation
No violation found
- A proprietary cost table in assessment softwareDetermination letterNo violation
No violation found
- Communications and a legal memo from a city planning departmentDetermination letterPartial violation
Improperly withheld records
- Juror names and addresses from a trialDetermination letterClosed no further action
Closed, no further action
- A university lecture recording used in a courseDetermination letterNo violation
No violation found
- Interview questions for teacher candidatesDetermination letterNo violation
No violation found