FOIL Submission Audit: Town of Brighton (High Friction / Mandatory Disclosure)
→This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The Town of Brighton provides clear FOIL guidance, timelines, fee information, appeal rights, and publishes a subject matter list. However, Brighton conditions FOIL submission on completion of a mandatory online form that requires extensive personal identifying information.
As presented, the submission process creates high friction by forcing disclosure of information that FOIL does not require as a condition of submitting a request.
How FOIL Requests Are Submitted in the Town of Brighton
Brighton’s FOIL webpage instructs requesters to submit requests by:
“just complete this form”
The page does not describe alternative submission methods such as:
- Email submission without the form
- Mail submission
- In-person submission
As presented, the online form is the primary documented submission pathway.
Online FOIL Submission Requirements
Brighton’s FOIL request form requires the requester to provide the following information in order to submit:
- Requester’s name
- Physical mailing address
- City, state, and ZIP code
- Phone number
- Email address
- Description of records requested
The form will not submit unless all required fields are completed.
⚠️ High Friction Identified
Submission is conditioned on disclosure of personal identifying and contact information that FOIL does not require to submit a request.
Account Creation and Auto-Population
The FOIL form allows users to sign in or create an account, which auto-populates personal information fields. While account creation is optional, the underlying form still requires full personal information even when submitted without an account.
The availability of account features does not reduce the disclosure required to submit a request.
Anonymous or Low-Disclosure Submission
Brighton’s FOIL webpage and submission form do not describe a method for submitting a FOIL request anonymously or with reduced disclosure.
Because the form requires both a physical address and multiple contact fields, requesters cannot submit a FOIL request through the documented process without providing personal identifying information.
FOIL Process Information (Strength)
Brighton’s FOIL page clearly provides:
- Five (5) business day acknowledgment requirement
- Disclosure timelines and extension standards
- Fee schedule
- Appeal rights and appeal contact information
- Identification of the Records Access Officer
These elements reflect strong procedural guidance and transparency after submission.
Subject Matter List (Additional Transparency Feature)
Brighton publishes a subject matter list of records, which may assist requesters in describing records. While helpful for research, this feature does not affect submission requirements.
Assessment
The Town of Brighton demonstrates strong FOIL process documentation but pairs it with a high-friction submission mechanism.
Key findings include:
- Mandatory online form submission
- Required disclosure of name, address, phone number, and email
- No documented alternative submission methods
- No documented anonymous submission option
Summary Scorecard
- Online FOIL form provided: Yes
- Alternative submission methods documented: No
- Personal identifying information required: Yes
- Anonymous submission possible (as documented): No
- FOIL timelines and appeals disclosed: Yes
- Overall assessment: High Friction
Conclusion
As presented on its FOIL webpage, the Town of Brighton conditions submission of FOIL requests on disclosure of personal identifying information that FOIL does not require. While Brighton provides clear guidance on timelines, fees, and appeals, the submission process itself places unnecessary barriers at the point of entry.
This makes Brighton’s FOIL process procedurally complete but submission-restrictive within the Monroe County FOIL Submission Audit.
Legal & Reference Notes
- New York Public Officers Law §§ 87–89
- Town of Brighton FOIL webpage
- Town of Brighton FOIL Request Form