FOIL Submission Audit: Village of Webster (Moderate–High Friction)
→ This post is part of the Monroe County FOIL Submission Audit.
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TL;DR
The Village of Webster publishes a comprehensive FOIL policy that clearly explains requester rights, timelines, appeal procedures, and identifies responsible officials. However, the Village conditions FOIL submission on completion of a standardized application form that includes personal information fields and a signature line.
The result is a form-centric submission process with moderate to high friction, mitigated by strong procedural transparency.
How FOIL Requests Are Submitted in the Village of Webster
The Village of Webster directs requesters to submit FOIL requests by completing a FOIL Application available for download on its website.
The site states:
“A written request shall be completed for all records requests.”
Completed FOIL applications may be submitted by traditional means (email or mail), but the use of the application itself is presented as mandatory.
Records Access Officer and Accountability (Strength)
The Village clearly identifies its Records Access Officer:
- Heather Halstead, Village Clerk
- Address and email provided
The Village also identifies:
- The appeals authority (Village Mayor)
- A complete appeal process
- The requirement that appeals be forwarded to the Committee on Open Government
This reflects strong procedural compliance and transparency.
FOIL Application Requirements
The Village’s FOIL Application includes the following fields
- Description of records requested
- Name
- Address
- Phone number
- Signature
- Date
The application also asks whether the requester seeks to inspect or obtain copies of records.
⚠️ Submission Friction Identified
The Village conditions FOIL submission on completion of a standardized application that includes personal identifying information and a signature, neither of which are required by FOIL to submit a request.
Signature Requirement
The FOIL Application includes a signature line, creating an additional formality at the submission stage.
The Village does not state on its website whether an unsigned request would be rejected. For purposes of this audit—which evaluates requirements as presented—the inclusion of a signature line is treated as a functional submission requirement.
Subject Matter List (Additional Transparency Feature)
The Village’s FOIL policy states that:
- A subject matter list is maintained
- It is updated annually
- It is intended to assist requesters in identifying records
This reflects a best practice in FOIL transparency, though it does not affect submission requirements.
Fees, Timelines, and Appeals (Strength)
The Village’s FOIL policy clearly explains:
- No fees for inspection or search
- Copying fees consistent with FOIL
- Electronic retrieval expectations
- Five-business-day acknowledgment requirement
- Twenty-business-day disclosure framework
- Appeal rights and timelines
- COOG notification requirements
This is among the most complete FOIL policy disclosures reviewed in the audit.
Anonymous or Low-Disclosure Submission
Because the Village requires use of a standardized FOIL application that includes personal information fields and a signature, the process does not clearly support anonymous or low-disclosure FOIL submission as presented.
While FOIL does not require requesters to identify themselves, the Village’s published process creates friction for those seeking to submit requests with minimal disclosure.
Assessment
The Village of Webster pairs excellent FOIL policy transparency with a form-centric submission model that introduces unnecessary friction at intake.
Key findings:
- Mandatory use of a FOIL application
- Personal information fields included
- Signature requirement
- Clear RAO identification
- Clear timelines and appeal rights
- Subject matter list maintained
Summary Scorecard
- FOIL application required: Yes
- Alternative submission methods documented: Limited (form-dependent)
- Records Access Officer identified: Yes
- Timelines and appeal rights disclosed: Yes
- Signature required (as presented): Yes
- Anonymous submission clearly supported: No
- Overall assessment: Moderate–High Friction / Procedurally Transparent
Conclusion
As presented on its website, the Village of Webster requires FOIL requests to be submitted using a standardized application that includes personal identifying information and a signature. While the Village demonstrates strong transparency around FOIL rights, timelines, and appeals, the submission process itself introduces unnecessary formality and disclosure requirements.
Within the Monroe County FOIL Submission Audit, the Village of Webster represents a procedurally transparent but form-dependent FOIL intake model.
Legal & Reference Notes
- New York Public Officers Law §§ 87–89
- Village of Webster FOIL Policy webpage
- Village of Webster FOIL Application