FOIL Submission Audit: Town of Irondequoit (High Friction / Deficient Submission)
→ This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The Town of Irondequoit requires FOIL requests to be submitted using a standardized request form and has affirmatively instructed requesters not to submit FOIL requests by email, despite FOIL permitting email submission. The Town’s public-facing FOIL page and staff communications together establish a form-only intake model that discourages lawful submission methods.
This constitutes a deficient FOIL submission process.
How FOIL Requests Are Submitted in the Town of Irondequoit
Irondequoit’s FOIL webpage instructs requesters to:
“Just complete the Freedom of Information Request Form (PDF).”
The page does not document email submission as an acceptable alternative. Instead, requesters are directed to contact the Town Clerk for assistance describing records, not for submission itself.
The current FOIL intake process relies on a mandatory form submission model.
Documented Discouragement of Email Submission
In direct correspondence with the Town Clerk’s Office, Irondequoit has explicitly instructed requesters to stop submitting FOIL requests by email and instead use the online or PDF form.
Examples include:
“Please start using the correct FOI form (can be found on our website) for all future requests.”
— Town Clerk, December 9, 2025
And earlier:
“Please fill out the Freedom of Information Request form on our website below or use the attached form.”
— Town Clerk, March 26, 2025
These instructions were issued in response to valid FOIL requests submitted by email.
⚠️ Deficiency Identified
Irondequoit has affirmatively discouraged a lawful FOIL submission method (email) and directed requesters to use a specific form instead.
Online FOIL Request Form Requirements
Irondequoit’s current FOIL intake relies on an online form that requires completion of multiple personal identifying fields, including:
- Full name
- Mailing address
- Email address
- Daytime phone number
- Request description
- Date range
- Police-department designation (yes/no)
Submission cannot proceed without providing this information.
Records Access Officer and Process Information
The Town identifies the Town Clerk as responsible for FOIL requests and provides:
- Five (5) business day acknowledgment timeframe
- Fee information
- Appeal rights
However, these procedural disclosures do not cure the intake deficiency created by mandatory form use and discouragement of email submission.
Anonymous or Low-Disclosure Submission
As presented and enforced, Irondequoit’s FOIL submission process does not support anonymous or low-disclosure requests:
- Email submission is discouraged
- Form completion is required
- Personal identifying information is mandatory
This places Irondequoit among the most restrictive FOIL intake models reviewed in the audit.
Assessment
Irondequoit goes beyond high friction and enters deficient submission territory due to:
- Mandatory form-only intake
- Active discouragement of lawful email submission
- Required personal identifying information
- Lack of documented non-form submission alternatives
This is not merely poor design; it is submission gatekeeping.
Summary Scorecard
- FOIL form required: Yes
- Online submission available: Yes
- Email submission accepted as submitted: No
- Email submission discouraged by staff: Yes
- Records Access Officer identified: Yes
- Personal information required: Yes
- Anonymous submission clearly supported: No
- Overall assessment: High Friction / Deficient Submission
Conclusion
As presented on its website and enforced in practice, the Town of Irondequoit conditions FOIL submission on use of a specific form and has instructed requesters not to submit FOIL requests by email. This conflicts with FOIL’s allowance for email submission and creates a submission process that discourages lawful access to records.
Within the Monroe County FOIL Submission Audit, Irondequoit represents a deficient FOIL intake model characterized by form-only submission and active discouragement of alternative methods.
Legal & Reference Notes
- New York Public Officers Law § 89(3)
- Town of Irondequoit FOIL webpage
- Town Clerk email correspondence (December 2025; March 2025)