Conn. Gen. Stat. § 1-210

Current with legislation from the 2024 Regular and Special Sessions.
Section 1-210 - (Formerly Sec. 1-19). Access to public records. Exempt records
(a) Except as otherwise provided by any federal law or state statute, all records maintained or kept on file by any public agency, whether or not such records are required by any law or by any rule or regulation, shall be public records and every person shall have the right to (1) inspect such records promptly during regular office or business hours, (2) copy such records in accordance with subsection (g) of section 1-212, or (3) receive a copy of such records in accordance with section 1-212. Any agency rule or regulation, or part thereof, that conflicts with the provisions of this subsection or diminishes or curtails in any way the rights granted by this subsection shall be void. Each such agency shall keep and maintain all public records in its custody at its regular office or place of business in an accessible place and, if there is no such office or place of business, the public records pertaining to such agency shall be kept in the office of the clerk of the political subdivision in which such public agency is located or of the Secretary of the State, as the case may be. Any certified record hereunder attested as a true copy by the clerk, chief or deputy of such agency or by such other person designated or empowered by law to so act, shall be competent evidence in any court of this state of the facts contained therein.
(b) Nothing in the Freedom of Information Act shall be construed to require disclosure of:
(1) Preliminary drafts or notes provided the public agency has determined that the public interest in withholding such documents clearly outweighs the public interest in disclosure;
(2) Personnel or medical files and similar files the disclosure of which would constitute an invasion of personal privacy;
(3) Records of law enforcement agencies not otherwise available to the public which records were compiled in connection with the detection or investigation of crime, if the disclosure of such records would not be in the public interest because it would result in the disclosure of (A) the identity of informants or mandated reporters, as described in subsection (b) of section 17a-101, not otherwise known or the identity of witnesses not otherwise known whose safety would be endangered or who would be subject to threat or intimidation if their identity was made known, (B) the identity of minor witnesses, (C) signed or sworn statements of witnesses, (D) information to be used in a prospective law enforcement action if prejudicial to such action, (E) investigatory techniques not otherwise known to the general public, (F) arrest records of a juvenile, which shall also include any investigatory files, concerning the arrest of such juvenile, compiled for law enforcement purposes, (G) the name and address of the victim of a sexual assault under section 53a-70, 53a-70a, 53a-71, 53a-72a, 53a-72b or 53a-73a, voyeurism under section 53a-189a, injury or risk of injury, or impairing of morals under section 53-21 or family violence, as defined in section 46b-38a, or of an attempt thereof, or (H) uncorroborated allegations subject to destruction pursuant to section 1-216;
(4) Records pertaining to strategy and negotiations with respect to pending claims or pending litigation to which the public agency is a party until such litigation or claim has been finally adjudicated or otherwise settled;
(5)
(A) Trade secrets, which for purposes of the Freedom of Information Act, are defined as information, including formulas, patterns, compilations, programs, devices, methods, techniques, processes, drawings, cost data, customer lists, film or television scripts or detailed production budgets that (i) derive independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain economic value from their disclosure or use, and (ii) are the subject of efforts that are reasonable under the circumstances to maintain secrecy; and
(B) Commercial or financial information given in confidence, not required by statute;
(6) Test questions, scoring keys and other examination data used to administer a licensing examination, examination for employment or academic examinations;
(7) The contents of real estate appraisals, engineering or feasibility estimates and evaluations made for or by an agency relative to the acquisition of property or to prospective public supply and construction contracts, until such time as all of the property has been acquired or all proceedings or transactions have been terminated or abandoned, provided the law of eminent domain shall not be affected by this provision;
(8) Statements of personal worth or personal financial data required by a licensing agency and filed by an applicant with such licensing agency to establish the applicant's personal qualification for the license, certificate or permit applied for;
(9) Records, reports and statements of strategy or negotiations with respect to collective bargaining;
(10) Records, tax returns, reports and statements exempted by federal law or the general statutes or communications privileged by the attorney-client relationship, marital relationship, clergy-penitent relationship, doctor-patient relationship, therapist-patient relationship or any other privilege established by the common law or the general statutes, including any such records, tax returns, reports or communications that were created or made prior to the establishment of the applicable privilege under the common law or the general statutes;
(11) Names or addresses of students enrolled in any public school or college without the consent of each student whose name or address is to be disclosed who is eighteen years of age or older and a parent or guardian of each such student who is younger than eighteen years of age, provided this subdivision shall not be construed as prohibiting the disclosure of the names or addresses of students enrolled in any public school in a regional school district to the board of selectmen or town board of finance, as the case may be, of the town wherein the student resides for the purpose of verifying tuition payments made to such school;
(12) Any information obtained by the use of illegal means;
(13) Records of an investigation, including any complaint or the name of a person providing information under the provisions of section 4-61dd or sections 4-276 to 4-280, inclusive;
(14) Adoption records and information provided for in sections 45a-746, 45a-750 and 45a-751;
(15) Any page of a primary petition, nominating petition, referendum petition or petition for a town meeting submitted under any provision of the general statutes or of any special act, municipal charter or ordinance, until the required processing and certification of such page has been completed by the official or officials charged with such duty after which time disclosure of such page shall be required;
(16) Records of complaints, including information compiled in the investigation thereof, brought to a municipal health authority pursuant to chapter 368e or a district department of health pursuant to chapter 368f, until such time as the investigation is concluded or thirty days from the date of receipt of the complaint, whichever occurs first;
(17) Educational records which are not subject to disclosure under the Family Educational Rights and Privacy Act, 20 USC 1232g;
(18) Records, the disclosure of which the Commissioner of Correction, or as it applies to Whiting Forensic Hospital, the Commissioner of Mental Health and Addiction Services, has reasonable grounds to believe may result in a safety risk, including the risk of harm to any person or the risk of an escape from, or a disorder in, a correctional institution or facility under the supervision of the Department of Correction or Whiting Forensic Hospital. Such records shall include, but are not limited to:
(A) Security manuals, including emergency plans contained or referred to in such security manuals;
(B) Engineering and architectural drawings of correctional institutions or facilities or Whiting Forensic Hospital facilities;
(C) Operational specifications of security systems utilized by the Department of Correction at any correctional institution or facility or Whiting Forensic Hospital facilities, except that a general description of any such security system and the cost and quality of such system may be disclosed;
(D) Training manuals prepared for correctional institutions and facilities or Whiting Forensic Hospital facilities that describe, in any manner, security procedures, emergency plans or security equipment;
(E) Internal security audits of correctional institutions and facilities or Whiting Forensic Hospital facilities;
(F) Minutes or recordings of staff meetings of the Department of Correction or Whiting Forensic Hospital facilities, or portions of such minutes or recordings, that contain or reveal information relating to security or other records otherwise exempt from disclosure under this subdivision;
(G) Logs or other documents that contain information on the movement or assignment of inmates or staff at correctional institutions or facilities; and
(H) Records that contain information on contacts between inmates, as defined in section 18-84, and law enforcement officers;
(19) Records when there are reasonable grounds to believe disclosure may result in a safety risk, including the risk of harm to any person, any government-owned or leased institution or facility or any fixture or appurtenance and equipment attached to, or contained in, such institution or facility, except that such records shall be disclosed to a law enforcement agency upon the request of the law enforcement agency. Such reasonable grounds shall be determined (A) (i) by the Commissioner of Administrative Services, after consultation with the chief executive officer of an executive branch state agency, with respect to records concerning such agency; and (ii) by the Commissioner of Emergency Services and Public Protection, after consultation with the chief executive officer of a municipal, district or regional agency, with respect to records concerning such agency; (B) by the Chief Court Administrator with respect to records concerning the Judicial Department; and (C) by the executive director of the Joint Committee on Legislative Management, with respect to records concerning the Legislative Department. As used in this section, "government-owned or leased institution or facility" includes, but is not limited to, an institution or facility owned or leased by a public service company, as defined in section 16-1, other than a water company, as defined in section 25-32a, a certified telecommunications provider, as defined in section 16-1, or a municipal utility that furnishes electric or gas service, but does not include an institution or facility owned or leased by the federal government, and "chief executive officer" includes, but is not limited to, an agency head, department head, executive director or chief executive officer. Such records include, but are not limited to:
(i) Security manuals or reports;
(ii) Engineering and architectural drawings of government-owned or leased institutions or facilities;
(iii) Operational specifications of security systems utilized at any government-owned or leased institution or facility, except that a general description of any such security system and the cost and quality of such system may be disclosed;
(iv) Training manuals prepared for government-owned or leased institutions or facilities that describe, in any manner, security procedures, emergency plans or security equipment;
(v) Internal security audits of government-owned or leased institutions or facilities;
(vi) Minutes or records of meetings, or portions of such minutes or records, that contain or reveal information relating to security or other records otherwise exempt from disclosure under this subdivision;
(vii) Logs or other documents that contain information on the movement or assignment of security personnel; and
(viii) Emergency plans and emergency preparedness, response, recovery and mitigation plans, including plans provided by a person to a state agency or a local emergency management agency or official;
(20) Records of standards, procedures, processes, software and codes, not otherwise available to the public, the disclosure of which would compromise the security or integrity of an information technology system;
(21) The residential, work or school address of any participant in the address confidentiality program established pursuant to sections 54-240 to 54-240o, inclusive;
(22) The electronic mail address of any person that is obtained by the Department of Transportation in connection with the implementation or administration of any plan to inform individuals about significant highway or railway incidents;
(23) The name or address of any minor enrolled in any parks and recreation program administered or sponsored by any public agency;
(24) Responses to any request for proposals or bid solicitation issued by a public agency, responses by a public agency to any request for proposals or bid solicitation issued by a private entity or any record or file made by a public agency in connection with the contract award process, until such contract is executed or negotiations for the award of such contract have ended, whichever occurs earlier, provided the chief executive officer of such public agency certifies that the public interest in the disclosure of such responses, record or file is outweighed by the public interest in the confidentiality of such responses, record or file;
(25) The name, address, telephone number or electronic mail address of any person enrolled in any senior center program or any member of a senior center administered or sponsored by any public agency;
(26) All records obtained during the course of inspection, investigation, examination and audit activities of an institution, as defined in section 19a-490, that are confidential pursuant to a contract between the Department of Public Health and the United States Department of Health and Human Services relating to the Medicare and Medicaid programs;
(27) Any record created by a law enforcement agency or other federal, state, or municipal governmental agency consisting of a photograph, film, video or digital or other visual image depicting (A) (i) a victim of domestic or sexual abuse, (ii) a victim of homicide or suicide, or (iii) a deceased victim of an accident, if disclosure could reasonably be expected to constitute an unwarranted invasion of the personal privacy of the victim or the victim's surviving family members, or (B) a minor, unless disclosure is required in accordance with the provisions of subdivision (2) of subsection (g) of section 29-6d ;
(28) Any records maintained or kept on file by an executive branch agency or public institution of higher education, including documentation prepared or obtained prior to May 25, 2016, relating to claims of or testing for faulty or failing concrete foundations in residential buildings and documents or materials prepared by an executive branch agency or public institution of higher education relating to such records.
(c) Whenever a public agency receives a request from any person confined in a correctional institution or facility or a Whiting Forensic Hospital facility, for disclosure of any public record under the Freedom of Information Act, the public agency shall promptly notify the Commissioner of Correction or the Commissioner of Mental Health and Addiction Services in the case of a person confined in a Whiting Forensic Hospital facility of such request, in the manner prescribed by the commissioner, before complying with the request as required by the Freedom of Information Act. If the commissioner believes the requested record is exempt from disclosure pursuant to subdivision (18) of subsection (b) of this section, the commissioner may withhold such record from such person when the record is delivered to the person's correctional institution or facility or Whiting Forensic Hospital facility.
(d) Whenever a public agency, except the Judicial Department or Legislative Department, receives a request from any person for disclosure of any records described in subdivision (19) of subsection (b) of this section under the Freedom of Information Act, the public agency shall promptly notify the Commissioner of Administrative Services or the Commissioner of Emergency Services and Public Protection, as applicable, of such request, in the manner prescribed by such commissioner, before complying with the request as required by the Freedom of Information Act. If the commissioner, after consultation with the chief executive officer of the applicable agency, believes the requested record is exempt from disclosure pursuant to subdivision (19) of subsection (b) of this section, the commissioner may direct the agency to withhold such record from such person. In any appeal brought under the provisions of section 1-206 of the Freedom of Information Act for denial of access to records for any of the reasons described in subdivision (19) of subsection (b) of this section, such appeal shall be against the chief executive officer of the executive branch state agency or the municipal, district or regional agency that issued the directive to withhold such record pursuant to subdivision (19) of subsection (b) of this section, exclusively, or, in the case of records concerning Judicial Department facilities, the Chief Court Administrator or, in the case of records concerning the Legislative Department, the executive director of the Joint Committee on Legislative Management.
(e) Notwithstanding the provisions of subdivisions (1) and (16) of subsection (b) of this section, disclosure shall be required of:
(1) Interagency or intra-agency memoranda or letters, advisory opinions, recommendations or any report comprising part of the process by which governmental decisions and policies are formulated, except disclosure shall not be required of a preliminary draft of a memorandum, prepared by a member of the staff of a public agency, which is subject to revision prior to submission to or discussion among the members of such agency;
(2) All records of investigation conducted with respect to any tenement house, lodging house or boarding house as defined in section 19a-355, or any nursing home, residential care home or rest home, as defined in section 19a-490, by any municipal building department or housing code inspection department, any local or district health department, or any other department charged with the enforcement of ordinances or laws regulating the erection, construction, alteration, maintenance, sanitation, ventilation or occupancy of such buildings; and
(3) The names of firms obtaining bid documents from any state agency.

Conn. Gen. Stat. § 1-210

(1957, P.A. 428, S. 1; 1963, P.A. 260; 1967, P.A. 723, S. 1; 1969, P.A. 193; 1971, P.A. 193; P.A. 75-342, S. 2; P.A. 76-294; P.A. 77-609, S. 2, 8; P.A. 79-119; 79-324; 79-575, S. 2, 4; 79-599, S. 3; P.A. 80-483, S. 1, 186; P.A. 81-40, S. 2; 81-431, S. 1; 81-448, S. 2; P.A. 83-436; P.A. 84-112, S. 1; 84-311, S. 2, 3; P.A. 85-577, S. 22; P.A. 90-335, S. 1; P.A. 91-140 , S. 2 , 3 ; P.A. 94-246 , S. 14 ; P.A. 95-233 ; P.A. 96-130 , S. 37 ; P.A. 97-47 , S. 4 ; 97-112 , S. 2 ; 97-293 , S. 14 , 26 ; P.A. 99-156 , S. 1 ; P.A. 00-66 , S. 5 ; 00-69 , S. 3 , 4 ; 00-134 , S. 1 ; 00-136 , S. 2 ; June Sp. Sess. P.A. 00-1, S. 20, 46; P.A. 01-26 , S. 1 ; P.A. 02-133 , S. 1 , 2 ; 02-137 , S. 2 ; P.A. 03-200 , S. 17 ; June 30 Sp. Sess. P.A. 03-6, S. 104; P.A. 05-287 , S. 26 ; P.A. 07-202 , S. 12 ; 07-213 , S. 22 ; 07-236 , S. 5 ; P.A. 08-18 , S. 1 ; Sept. Sp. Sess. P.A. 09-5, S. 17; P.A. 10-17 , S. 1 ; P.A. 11-51 , S. 44 , 134 ; 11-242 , S. 37 , 38 ; P.A. 13-311 , S. 1 , 2 ; P.A. 14-217 , S. 18 ; P.A. 15-213 , S. 5 ; P.A. 16-45 , S. 5 ; P.A. 17-211 , S. 1 , 2 ; P.A. 18-86 , S. 6 , 7 .)

Amended by P.A. 24-0056,S. 2 of the Connecticut Acts of the 2024 Regular Session, eff. 7/1/2024.
Amended by P.A. 24-0056,S. 1 of the Connecticut Acts of the 2024 Regular Session, eff. 7/1/2024.
Amended by P.A. 23-0197,S. 1 of the Connecticut Acts of the 2023 Regular Session, eff. 10/1/2023.
Amended by P.A. 21-0120, S. 6 of the Connecticut Acts of the 2021 Regular Session, eff. 7/1/2021.
Amended by P.A. 19-0123, S. 3 of the Connecticut Acts of the 2019 Regular Session, eff. 10/1/2019.
Amended by P.A. 19-0043, S. 1 of the Connecticut Acts of the 2019 Regular Session, eff. 10/1/2019.
Amended by P.A. 18-0086, S. 7 of the Connecticut Acts of the 2018 Regular Session, eff. 6/4/2018.
Amended by P.A. 18-0086, S. 6 of the Connecticut Acts of the 2018 Regular Session, eff. 6/4/2018.
Amended by P.A. 17-0211, S. 2 of the Connecticut Acts of the 2017 Regular Session, eff. 7/1/2017.
Amended by P.A. 17-0211, S. 1 of the Connecticut Acts of the 2017 Regular Session, eff. 7/1/2017.
Amended by P.A. 16-0045, S. 5 of the Connecticut Acts of the 2016 Regular Session, eff. 5/25/2016.
Amended by P.A. 15-0213, S. 5 of the Connecticut Acts of the 2015 Regular Session, eff. 10/1/2015.
Amended by P.A. 14-0217, S. 18 of the Connecticut Acts of the 2014 Regular Session, eff. 6/13/2014.

Annotations to former section 1-19: Cited. 174 Conn. 308 ; 176 C. 622 . Statute provides for exceptions under federal and state statutes. 178 C. 700 . Cited. 181 Conn. 324 . Sales tax delinquent lists are public records not exempt from disclosure under statute. 184 Conn. 102 . Cited. 190 Conn. 235 ; 192 C. 166 ; Id., 310; 201 Conn. 421 . Autopsy reports are not records accessible to general public under section; judgment of Appellate Court reversed. Id., 448. Cited. 204 Conn. 609 ; 205 Conn. 767 ; 206 Conn. 449 ; 207 Conn. 698 ; 208 Conn. 442 ; 209 Conn. 204 ; 210 Conn. 590 (see 217 C. 193 which overruled 210 Conn. 590 to the extent that it required a balancing test for the interpretation of the exemptions contained in Sec. 1-19(b)(2) ); Id., 646; 212 Conn. 100 ; 213 Conn. 126 ; Id., 216; 214 Conn. 312 ; 216 Conn. 253 ; 217 Conn. 153 ; Id., 193; Id., 322; 218 Conn. 256 ; Id., 757; 220 Conn. 225 ; 221 Conn. 217 ; Id., 300; Id., 393; Id., 482; Id., 549; 222 Conn. 621 ; 227 Conn. 641 ; Id., 751; 228 Conn. 158 ; Id., 271; 233 Conn. 28 ; 240 Conn. 1 . Cited. 1 CA 384 ; 4 Conn.App. 468 ; 8 CA 216 ; 14 Conn.App. 380 ; judgment reversed, see 210 Conn. 646 ; 16 Conn.App. 49 ; 18 Conn.App. 212 ; 19 Conn.App. 539 ; Id., 352; 20 Conn.App. 671 ; 22 Conn.App. 316 ; 29 Conn.App. 821 ; 31 CA 178 ; 35 Conn.App. 111 ; 36 Conn.App. 155 ; 37 Conn.App. 589 ; 42 Conn.App. 402 ; 4 3 Conn.App. 1 33. Statute requires evidentiary showing that the records sought are to be used in a law enforcement action and that disclosing such records would be prejudicial to the law enforcement action. 51 Conn.App. 100 . Order that documents be disclosed under section was proper. 54 Conn.App. 373 . A record request that is simply burdensome does not make that request one requiring research; review of records to determine if one is exempt from disclosure does not constitute research. 56 CA 683 . Cited. 31 CS 392 . Construed as permitting public access to raw real estate assessment data. 32 CS 583 . Document need not be connected with an official or completed transaction to be a public record. Id., 588. Cited. 38 CS 675; 39 Conn.Supp. 176 ; 41 Conn.Supp. 31 ; Id., 267; 42 Conn.Supp. 84 ; Id., 129; Id., 291; 43 Conn.Supp. 246 . Presumed legislature, by insertion of exception clause, intended to exclude from operation of statute exclusive power over admission to bar vested in Superior Court by Sec. 51-80 . 4 Conn. Cir. Ct. 313. State's right to inspect records relating to building permits cannot be defeated by city ordinance; section construed broadly in conjunction with statutes creating state boards of registration for professional engineers and architects. Id., 511. When medical files are a public record. 6 Conn. Cir. Ct. 633. Subsec. (a): Woodstock Academy deemed a "public agency" within meaning of statute. 181 Conn. 544 . Cited. 201 C. 448 . Disclosure requirements do not apply to information that may be released under Sec. 29-170 . 204 Conn. 609 . Cited. 205 Conn. 767 ; 207 Conn. 698 ; 211 Conn. 339 ; 213 Conn. 126 . Secs. 5-225 and 5-237 provide exceptions to section. 214 Conn. 312 . Cited. 219 Conn. 685 ; 221 C. 300 ; Id., 393; 222 C. 98 ; 228 Conn. 158 ; 241 Conn. 310 . Cited. 4 Conn.App. 468 . General disclosure requirement of Sec. 1-19(a) does not prevail over specific limitation of disclosure obligations under Sec. 1-83 . 18 Conn.App. 212 . Cited. Id., 291; 22 Conn.App. 316 ; 29 Conn.App. 821 ; 35 CA 384 ; 3 9 Conn.App. 1 54; 41 CA 67 ; 44 CA 611 ; Id., 622; 45 CA 413 . Cited. 42 CS 291 . Subsec. (b): Subdiv. (1): Term "preliminary drafts or notes" relates to advisory opinions, recommendations and deliberations comprising part of process by which government decisions and policies are formulated; they reflect that aspect of the agency's function that precedes formal and informal decision making. 181 Conn. 324 . Cited. 1 82 Conn. 1 42; 186 C. 153 ; 197 Conn. 698 ; 198 Conn. 498 ; 201 Conn. 448 ; 204 Conn. 609 . Subdiv. (4): Commission's order of disclosure proper after city failed to establish on record that information falls within exemption. 205 Conn. 767 . Cited. 210 Conn. 590 (see 217 Conn. 193 which overruled 210 Conn. 590 to the extent that it required a balancing test for the interpretation of the exemptions contained in Subdiv. (2)); 211 Conn. 339 ; 214 Conn. 312 ; 216 Conn. 253 ; 217 Conn. 153 ; Id., 193. Subdiv. (2): Ruling in 210 Conn. 590 overruled to the extent that it required a balancing test for the interpretation of the exemptions contained in Subdiv. 217 Conn. 193 . Subdiv. (11): Permits withholding of names of employees whose student status is a condition of their employment. Id., 322. Subdiv. (2): Section purports to protect an individual's personal privacy; retirees should be afforded opportunity to show a reasonable expectation of privacy in their addresses. 218 Conn. 256 . Subdiv. (2) does not prevent disclosure of substance of public agency vote on motion concerning personnel matter. 221 Conn. 217 . Cited. Id., 300; Id., 393; Id., 482; Id., 549. Subdiv. (2): Municipal permits to carry pistols or revolvers in public are not "similar" files entitled to exemption from disclosure under section. 222 Conn. 621 . Cited. 224 C. 325 ; 226 Conn. 618 ; 227 Conn. 641 ; Id., 751. Subdiv. (2): Records request under FOIA for disclosure of numerical data concerning employees' attendance records including sick leave does not constitute invasion of personal privacy within meaning of statute. 228 Conn. 158 . Cited. Id., 271; 233 Conn. 28 ; Id., 37; 234 Conn. 704 . Subdiv. (4): Section applicable to bar disclosure of the report in question; judgment of Appellate Court in 42 Conn.App. 39 reversed. 241 Conn. 310 . Cited. 242 Conn. 79 . Under Subdiv. (1), unfinished report by attorney hired by municipality, as well as interview summaries and affidavits created solely to serve as supporting documentation for that report, constituted "preliminary drafts or notes"; under Subdiv. (10), documents prepared by attorney hired by a public agency are protected from disclosure as privileged attorney-client communications if certain conditions are met. 245 C. 149 . Cited. 4 Conn.App. 216 . Subdiv. (3): Autopsy report was not exempt from disclosure under statute. Id., 468. Cited. 14 Conn.App. 380 ; judgment reversed, see 210 Conn. 646 ; 19 Conn.App. 489 . Subdiv. (2): Shield of confidentiality protects records of prisoner applicants for pardons. Id., 539. Cited. Id., 671; 23 CA 479 ; 35 Conn.App. 384 ; 3 9 Conn.App. 1 54; 41 Conn.App. 67 ; Id., 649; 42 Conn.App. 39 ; judgment reversed, see 241 Conn. 310 ; 4 3 Conn.App. 1 33; 44 Conn.App. 611 . Subdiv. (3): Legislature has determined that disclosure would not be in the public interest and that no balancing is required; legislature has not required a balancing test prior to determination that a document is exempt from disclosure. Id., 622. Disclosure of the names of employees disciplined by Department of Children and Families in connection with death of infant who was the subject of department investigation does not constitute an invasion of their personal privacy. 48 CA 467 . Freedom of Information Act and rules of discovery provide independent methods of obtaining information except when it would limit discovery rights; legislative change from "effect" to "limit" discussed. 52 CA 12. Cited. 39 Conn.Supp. 176 . Subdiv. (6): Test questions and examination data already administered as well as those not yet administered are included in the exemption from disclosure; the exemption is characterized as "absolute". Id., 257. Cited. 42 Conn.Supp. 84 ; Id., 129; Id., 291. Subsec. (c): Cited. 211 Conn. 339 . Subdiv. (1): Legislature did not intend to require disclosure of drafts of memoranda prepared by persons who, although not staff members of the public agency, are hired on a contractual basis to perform tasks that are indistinguishable from those which may be performed by agency personnel. 245 Conn. 149 . Cited. 44 Conn.App. 611 . Annotations to present section: Federal Copyright Act is federal law exempt from state Freedom of Information Act to the extent state and federal laws impose conflicting legal obligations; commission must allow opportunity for public safety assessment of release of non-exempt data under Subsec. (b)(19) when ordering segregation from exempt data. 307 C. 648 . Order that documents be disclosed under section was proper. 54 Conn.App. 373 . Subsec. (a): Questions of discovery under Federal Rules of Civil Procedure are not what is meant by the phrase "otherwise provided by any federal law". 252 C. 377. A public record may be precluded from disclosure if such preclusion is provided for by another statute. 298 C. 703 . Document that Department of Correction obtained from the National Crime Information Center re person detained at correctional center was not subject to disclosure under Subsec. because its disclosure was barred by federal law; interpretation of federal regulation by promulgating federal agency, and not interpretation of Subsec. by state Freedom of Information Commission, is entitled to deference by the court. 307 C. 53. PowerPoint materials prepared by instructors in master gardener program at University of Connecticut not prepared, owned, used, received or retained by university not held to be records maintained or kept on file by public agency. 90 Conn.App. 101 . Because Sec. 17a-101k mandates confidentiality of information regarding child abuse, records of child abuse, wherever located, are exempted from the general rule of disclosure. 104 CA 150. One public agency may not be held responsible for disclosing the public records in the custody of another public agency. 116 CA 171 . Individual seeking copy of public record must make request in writing in accordance with Subsec. 130 Conn.App. 448 . Records defined in Sec. 17a-28 concerning child protection activities fall within express exemption of Subsec. and are exempt from disclosure; Freedom of Information Commission lacks jurisdiction to determine rights of access under Sec. 17a-28 . 136 CA 76 . Limitations placed on disclosure of National Crime Information Center rap sheet data by federal law are mirrored in Sec. 29-164f , and the National Crime Information Center printout in this case fell under the exemption in Subsec. 144 CA 821 . Subsec. (b): Irrespective of the facts, complainant's identity and related information in a sexual harassment complaint is not always exempt from disclosure. 255 C. 651 . Home addresses of public employees held not subject to disclosure where no public interest was served by exposing such information and the employees had taken significant steps to keep such information private. 256 C. 764. Subdiv. (10) does not violate separation of powers clause because it preserves powers of the judicial branch and does not delegate to Freedom of Information Commission the power to define attorney-client privilege. 260 C. 143 . Subdiv. (2): Freedom of Information Act does not provide private right of action for FOIA violations. 267 Conn. 669 . Party claiming exemption pursuant to Subdiv. (19) has burden of seeking public safety determination from Commissioner of Public Works. 274 C. 179 . Communications are privileged by the attorney-client relationship where the attorney is acting in a professional capacity for the agency, the communications are made to the attorney by current employees or officials of the agency, the communications relate to the legal advice sought by the agency from the attorney, and the communications are made in confidence. 300 C. 511. Subdiv. (5): "Trade secret" definition focuses exclusively on nature and accessibility of the information, not on status or characteristics of entity creating and maintaining the information; public agency need not engage in a "trade" to avail itself of trade secret exemption if information in question would constitute a trade secret if created by a private entity. 303 C. 724 . Subdiv. (10): Medical and dental records created by an inpatient mental health facility during the treatment of a patient are exempt from disclosure under Sec. 52-146e as records protected by the psychiatrist-patient privilege. 318 Conn. 769 . Subdiv. (19): The safety risk assessment must be performed by the department in the first instance, after consulting with the head of the relevant state agency, and both the commission and the trial court should defer to the department's assessment unless the party seeking disclosure establishes that the determination was frivolous, patently unfounded or in bad faith. 321 C. 805 . In determining whether a communication in which an attorney gives business or other nonlegal professional advice is exempt from disclosure under subdivision (10) as privileged by the attorney-client relationship, it must be determined whether the primary purpose of the communication was seeking or providing legal advice and whether incidentally privileged matters could be redacted to allow for disclosure of nonprivileged matters. 323 C. 1 . Any and all public records consisting of preliminary drafts eligible for nondisclosure under Subsec. regardless of where originated; consideration of abandonment of project on nondisclosure of preliminary drafts. 73 CA 89 . Disclosure of PowerPoint materials prepared by instructors in master gardener program at University of Connecticut that are not exempted under Subsec. is not required because exemption applies only to public records, and materials determined initially not to be public records. 90 Conn.App. 101 . Subdiv. (1): There is no requirement that public agency provide its rationale for withholding disclosure of applicable records at a specific time. 91 CA 521 . Subdiv. (10): Introduction of extrinsic evidence does not supersede an analysis of elements in 245 Conn. 149 for purposes of determining privilege, but court may review extrinsic evidence in camera and use it as evidence to determine privilege. 116 Conn.App. 171 . Subdiv. (2): An inquiry under the fourth and fourteenth amendments to U.S. Constitution as to the reasonableness of governmental access to private information is not applicable when evaluating a claim for exemption from disclosure under Subdiv.; records concerning egregious off duty communications of a police officer and documentation from internal affairs investigation implicated his job as a public official, pertained to legitimate matters of public concern and were not exempt from disclosure under Subdiv. 136 CA 496.