FOIL Submission Audit: City of Rochester (High Friction / Mandatory Disclosure)
→ This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The City of Rochester relies on a centralized FOIL portal that requires disclosure of personal identifying and contact information as a condition of submission. While the City provides extensive FOIL guidance, timelines, appeal rights, and subject-matter resources, the submission process itself remains high friction and portal-centric.
How FOIL Requests Are Submitted in the City of Rochester
The City directs requesters to submit FOIL requests through its online FOIL portal, hosted on the JustFOIA platform.
The FOIL webpage emphasizes providing identifying and contact information “to ensure efficient processing” and links directly to the portal for submission.
No clear, parallel instructions are provided on the FOIL page for submitting requests by:
- Plain email without the portal, or
- Written request by mail without use of the form.
Records Access and Accountability (Strength)
The City provides strong procedural transparency, including:
- Physical location of the Law Department
- Phone and fax numbers
- Business hours for inspection
- Detailed explanation of FOIL responses
- Appeal rights and Article 78 information
- Fee schedules
This reflects robust post-submission transparency.
Online FOIL Portal Requirements
The City’s FOIL portal requires completion of multiple fields prior to submission, including:
Mandatory Identifying Information
- Name of requester
- Email address
- Phone number
- Mailing address
- City, state, ZIP code
Request Classification and Context
- Primary record or incident type (e.g., Police)
- Date or date range
- Time or time range
- Property or incident address
- Description of request
- Delivery method selection
Submission cannot proceed without providing personal contact and address information.
⚠️ High Friction Identified
The City conditions FOIL submission on disclosure of personal identifying and contact information that FOIL does not require in order to submit a valid request.
Portal-Centric Intake Model
The City’s FOIL page repeatedly frames portal use as the primary method for submitting requests and emphasizes efficiency, categorization, and routing through the system.
While this may aid internal processing, it also:
- Centralizes submission through a single technical platform
- Limits low-disclosure submission options
- Requires requesters to conform to predefined categories and fields
Subject Matter Lists and Resource Linking (Strength)
The City provides:
- A FOIL subject matter list
- Extensive links to commonly requested records
- Referrals to other agencies when records are not maintained by the City
These resources may reduce unnecessary FOIL requests but also add decision points before submission.
Anonymous or Low-Disclosure Submission
As presented, the City of Rochester’s FOIL process does not clearly support anonymous or low-disclosure submission:
- The portal requires name, address, and contact information
- No alternative submission method is clearly documented on the FOIL page
- Requesters are instructed to “submit a request through the process outlined on this page,” which centers on the portal
Assessment
The City of Rochester demonstrates strong FOIL process transparency and guidance but relies on a portal-centric submission model that imposes high friction at intake.
Key findings include:
- Portal-based submission emphasized
- Mandatory personal identifying information
- Mandatory address and contact fields
- Extensive classification fields
- Clear timelines, fees, and appeal rights
Summary Scorecard
- FOIL portal required (as presented): Yes
- Online submission available: Yes
- Email/mail submission clearly documented: No
- Records Access Officer / office identified: Yes
- Personal information required: Yes
- Anonymous submission clearly supported: No
- Overall assessment: High Friction – Portal-Centric Mandatory Disclosure
Conclusion
As presented, the City of Rochester conditions FOIL submission on use of a centralized online portal requiring disclosure of personal identifying and contact information. While the City provides extensive FOIL guidance, resources, and appeal transparency, the submission process itself introduces significant barriers at intake.
Within the Monroe County FOIL Submission Audit, Rochester represents a high-friction FOIL intake model driven by portal-first design rather than statutory necessity.
Legal & Reference Notes
- New York Public Officers Law §§ 84–90
- City of Rochester FOIL webpage
- City of Rochester FOIL portal (JustFOIA)