FOIL Submission Audit: Village of Churchville (High Friction / Deficient Submission)
→ This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The Village of Churchville provides an online FOIL request form but fails to disclose basic FOIL process information required by law, including timelines, appeal rights, records access officer identification, fees, and lawful alternative submission methods. The result is a deficient submission process that obscures requester rights and forces unnecessary disclosure.
How FOIL Requests Are Submitted in the Village of Churchville
The Village of Churchville accepts FOIL requests through a single online form titled “Request for Public Records.”
The FOIL page does not explain whether requests may also be submitted by:
- Fax
- In-person delivery
Nor does it state that such alternatives are permitted under FOIL.
Required Fields and Mandatory Disclosure
The online form requires the requester to provide:
- Name
- Address
- Phone number
- Property location (street address or tax identifiers)
- Department being requested from
- Description of records sought
- CAPTCHA verification
FOIL does not require a requester to provide their name, address, phone number, or property location for a valid request. The form does not explain which fields are legally required versus administratively preferred.
This forces the issue of disclosure without informing the requester of their rights.
Records Access Officer and Appeals (Not Disclosed)
The FOIL page does not identify:
- The Records Access Officer
- The FOIL Appeals Officer
- How or where to file an appeal
- Appeal deadlines
Under New York FOIL, agencies are required to disclose appeal rights and designate responsible officials. That information is absent from Churchville’s FOIL submission page.
Timelines, Fees, and Process Transparency (Not Disclosed)
The Village of Churchville FOIL page does not disclose:
- The five-business-day acknowledgment requirement
- The twenty-business-day response framework
- Any fee schedule or copy costs
- Whether records may be inspected in person
- Whether electronic delivery is available
Without this information, requesters cannot reasonably assess cost exposure or compliance obligations.
Anonymous or Low-Disclosure Submission
The Village of Churchville FOIL page does not state whether anonymous FOIL requests are accepted.
Because no alternative submission methods are described and the form mandates personal information, the practical effect is to discourage anonymous or low-disclosure requests, even though FOIL permits them.
Overall Assessment
The Village of Churchville’s FOIL submission process is deficient, not merely inconvenient.
The issue is not the existence of an online form. The issue is that the Village:
- Omits required FOIL disclosures
- Obscures lawful submission alternatives
- Requires unnecessary personal information
- Fails to explain appeal rights or timelines
This mirrors the same structural deficiencies observed in the Village of Pittsford audit.
Classification Summary
- Submission Method Available: Yes (online form only)
- Mandatory Personal Information Required: Yes
- Records Access Officer Identified: ❌ No
- Appeals Process Disclosed: ❌ No
- Statutory Timelines Explained: ❌ No
- Fees Disclosed: ❌ No
- Lawful Alternative Submission Methods Explained: ❌ No
Overall Classification: High Friction / Deficient Submission
Conclusion
The Village of Churchville provides a way to submit FOIL requests, but does not provide the information necessary for the public to understand or exercise their rights under the law.
By presenting a form without required FOIL context, the Village shifts the burden onto the requester and undermines transparency. Publishing basic FOIL disclosures alongside the submission form would materially improve compliance without increasing administrative burden.
Legal & Reference Notes
- New York Public Officers Law §89(3) — requirements for FOIL requests
- New York Public Officers Law §89(4) — appeal rights and timelines
- Committee on Open Government (COOG) FOIL guidance