FOIL Submission Audit: Town of Webster (High Friction / Mandatory Declarations)
→ This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The Town of Webster requires FOIL requests to be submitted using a standardized request form that includes mandatory declarations and a signature line. While Webster provides clear alternative submission methods (email and mail) and identifies the Records Access Officer, the form conditions submission on information and certifications that FOIL does not require.
The result is a high-friction submission process, though not a deficient one.
How FOIL Requests Are Submitted in the Town of Webster
The Town of Webster instructs requesters to submit FOIL requests by completing a FOIL request form. Completed forms may be submitted by:
- Email to the Town Clerk
- U.S. Mail to the Records Access Officer
- In-person inspection during business hours
Unlike some other agencies, Webster clearly documents non-portal submission options.
Records Access Officer Identified
Webster identifies the Records Access Officer as:
- Town Clerk, Town of Webster
- Address and phone number provided
- Email address provided
This satisfies a core FOIL transparency requirement.
FOIL Request Form Requirements
Webster requires use of a FOIL request form that must be completed and submitted by the requester
The form includes the following required or functionally required elements:
- Description of records requested
- Daytime phone number
- Email address (if electronic delivery is desired)
- Selection of intended use:
- “For solicitation and/or fundraising purposes”
- “NOT for solicitation and/or fundraising purposes”
- Signature and printed name
- Date
The form also asks for a mailing address.
⚠️ High Friction Identified
Submission is conditioned on purpose-based declarations and a signed certification that FOIL does not require in order to submit a request.
Purpose Declaration Requirement
The Webster FOIL form requires the requester to affirmatively select whether the requested records will or will not be used for solicitation and/or fundraising purposes.
FOIL does not require requesters to disclose or certify intended use as a condition of submitting a request. While such information may be relevant in limited fee contexts, requiring this declaration at the submission stage introduces unnecessary friction.
Signature Requirement
The Webster FOIL form includes a signature line and printed name field.
The Town does not state on its website whether a request submitted without a signature would be rejected. For the purposes of this audit, which evaluates submission requirements as presented, the inclusion of a signature line is treated as a required submission element.
This adds an additional formality that is not required by FOIL to submit a request.
Fees and Inspection Information
Webster discloses:
- Copying fees ($0.25 per page or greater as provided by law)
- No charge for electronic records
- Inspection availability during normal business hours
This information is clearly provided and accessible.
Anonymous or Low-Disclosure Submission
Because Webster requires submission of a completed request form that includes contact information, a signature line, and a purpose declaration, the process does not clearly support anonymous or low-disclosure FOIL submission through the documented pathway.
However, the availability of email and mail submission provides some flexibility compared to portal-locked systems.
Assessment
The Town of Webster provides a clear FOIL page, identifies the Records Access Officer, and documents multiple submission methods. However, the required use of a standardized form that includes mandatory declarations and a signature creates high friction at the point of submission.
Key findings include:
- Mandatory form use
- Required purpose declaration
- Signature requirement
- Clear alternative submission methods
- Clear RAO identification and inspection guidance
Summary Scorecard
- FOIL form required: Yes
- Email or mail submission documented: Yes
- Records Access Officer identified: Yes
- Purpose declaration required: Yes
- Signature required (as presented): Yes
- Anonymous submission clearly supported: No
- Overall assessment: High Friction / Mandatory Declarations
Conclusion
As presented, the Town of Webster conditions FOIL submission on completing a signed request form that includes purpose-based declarations not required by FOIL. While Webster provides clear contact information, inspection rights, and alternative submission methods, the submission process itself imposes unnecessary formalities.
Within the Monroe County FOIL Submission Audit, Webster represents a high-friction but procedurally transparent FOIL intake model.
Legal & Reference Notes
- New York Public Officers Law §§ 87–89
- Town of Webster FOIL webpage
- Town of Webster FOIL Request Form (fillable PDF)FOI Req 082025_Fillable_1