Monroe County FOIL Submission Audit

How Local Agencies Make (or Block) Public Records Access

What This Audit Is

The Monroe County FOIL Submission Audit reviews how local government agencies accept Freedom of Information Law (FOIL) requests — with a specific focus on submission barriers that are not required by New York law.

While FOIL guarantees the right to request public records, the practical ability to submit a request often depends on how agencies design their intake processes.

This audit examines those processes agency by agency.

Note: This audit evaluates how FOIL requests are submitted, not how agencies respond to or decide FOIL requests.

Update Status
Jan 29, 2026: FJan 29, 2026: Findings from this audit were used to submit a request for guidance to the New York Committee on Open Government regarding FOIL submission portal requirements. → View submission

What We Are Evaluating

Each agency review looks at the same core questions, using a consistent format so readers can compare practices easily.

Key factors include:

Whether FOIL requests can be submitted by email
Whether an online form is used
What fields are required to submit a request
Whether personal identifying information is mandatory
Whether anonymous requests are possible
Whether the agency publishes a subject matter list
Whether accessibility or equity concerns are present

The audit focuses on process, not the content of individual FOIL responses.

Why This Matters

FOIL does not require:

A requester’s name
A physical address
A phone number
Account creation
Identity verification

When agencies require these anyway, the effect can be:

Chilling anonymous or sensitive requests
Creating barriers for disabled requesters
Excluding people without stable housing
Discouraging journalists, advocates, and residents

The purpose of this audit is to document those barriers — and to highlight agencies that show they are unnecessary.

Methodology (Brief)

For each agency, Transparent Law Enforcement reviews:

The agency’s FOIL webpage
Online FOIL submission forms (if used)
Required vs. optional form fields
Published guidance, timelines, and appeal instructions

Screenshots and links are archived where appropriate.
Agencies are evaluated as presented to the public at the time of review.

Friction Levels Explained

Low Friction: Minimal required fields; email or free-text submission supported
Moderate Friction: Forms request additional information but alternative methods exist
High Friction: Mandatory personal data, certifications, or portals with no clear alternatives
Deficient Submission: Submission method omits required FOIL disclosures or obscures lawful alternatives
Mandatory Disclosure: Submission method requires the requester to provide personal, categorical, or certification information not required by FOIL as a condition of submitting a request.

These categories are descriptive, not punitive.

Benchmark Agency

One Monroe County agency already demonstrates that low-barrier FOIL submission is achievable:

🟢 Town of Henrietta — Low Barrier / Best Practice

Requires only a description of records
Allows anonymous requests
Publishes a subject matter list
Provides clear timelines, fees, and appeal rights

→ Read the full review:
FOIL Submission Audit: Town of Henrietta

Henrietta serves as the baseline comparator for this audit.

Agency Reviews (Alphabetical)

(This section will grow over time.)

What Happens Next

As additional agencies are reviewed:

This hub page will be updated
Individual agency posts will link back here
Patterns across Monroe County will be summarized

Where appropriate, findings may be:

Shared with the Committee on Open Government
Referenced in policy discussions
Used to encourage voluntary agency improvements

About Transparent Law Enforcement

Transparent Law Enforcement is an independent public-interest project focused on practical transparency, accessibility, and accountability in local government processes.

This audit is part of a broader effort to ensure that the right to know is meaningful in practice, not just on paper.