Adopted 10/08/2014; amended 06/12/2024, 08/14/2024
It is the policy of the Jefferson County Library District (“District”) to release records of the District in compliance with the Washington State Public Records Act, set forth in Chapter 42.56 of the Revised Code of Washington (“RCW”), and any other applicable provisions of federal or state law. The Public Records Request Policy applies to all library system records created by staff, administrators, the Board of Trustees, and any third-party records in the District’s possession. The District will maintain its records in a reasonably organized manner. The District will take reasonable actions to protect records from damage and disorganization.
Purpose
The purpose of this process document is to comply with Chapter 42.56 RCW, the Public Records Act. This document provides guidance to public records requesters as well as District employees who respond to such requests.
Public Records Officer
The District has designated the Library Director as the official Public Records Officer (“Officer”) for the library district. The individual serving as the Officer may change through time and current contact information is available on the District’s website. The Officer is responsible for managing library records to ensure compliance with the law, responding to and tracking requests or designating another individual to respond, and serves as the principal contact with any requester making a records request. Any person wishing to inspect District records or seeking assistance in making such a request should contact the Officer as follows:
Public Records Officer
Jefferson County Library District
620 Cedar Ave., Port Hadlock, WA 98339 360-385-6544
Types and Availability of Records
The District makes a variety of records available on the website including board meeting agendas, board meeting minutes, annual reports, and budget documents. The District maintains and destroys records in accordance with state law. Records documenting the process of fulfilling requests and the records responsive to them are retained for the applicable retention periods.
For reasons stated in Resolution No.24-09, adopted by the Board of Trustees on 08/14/2024, and incorporated herein by reference, the District finds that it would be unduly burdensome and would interfere with District operations to maintain an index of records.
Public records are available for inspection and copying at the District’s Administrative Office at the Library in Port Hadlock, WA, from 8:00am-5:00pm, Monday-Friday.
Submitting Requests
All requests should be made in writing and directed to the Officer. The District’s standard and preferred request method is using the Public Records Request Form available on the District’s website. Although requesters are strongly encouraged to use the Form, a requester may also submit a request by postal mail, email, or in person during public access hours at the Library located at 620 Cedar Ave. Port Hadlock, WA 98339.
Any person wishing to inspect or copy public records of the District should include the following information in the request:
- The date and time of the request;
- A means of communicating to the requester, such as mailing address, telephone number, and email address;
- Identification of the public records requested with descriptions that are adequate for the Officer to locate the records; and
- Whether the requester is seeking to inspect the record(s) or if copies are being requested.
The District will respond to all Public Records Act requests within five (5) business days in compliance with RCW 42.56.520. A District response to the Requester may include:
a. Notifying the requester that the documents are available for inspection or copying,
b. Acknowledging the request in writing and providing a reasonable estimate of the time the District will require to respond to the request,
c. Seeking clarification from the Requester,
d. Identifying the physical location or internet site where the documents are available to the public, or
e. Denying the records request.
Processing Requests
The Officer will process requests in an order that allows requests to be processed most efficiently. When the District receives a public record request or at any time while processing a record request, the Officer will determine a reasonable time estimate within which the District can respond to the request that will factor in the nature, volume, and availability of the requested records; the amount of time necessary to respond to a particular request and its effect on the amount of staff time that can be devoted to responding to the requests of other requesters; and the impact on other essential District functions. Specific factors that may affect the response time estimate include, but are not limited to:
a. Number of pending requests from the same requester;
b. Volume of records requested;
c. Complexity or ambiguity of the request;
d. Access to database or electronic system records;
e. Information Technology (IT) staff involvement;
f. Records not easily identified, located, and/or accessible;
g. Current staffing, including any amount of time needed by District staff who are not primarily responsible for public record processing;
h. Third-party notice;
i. Complex review to determine if content is exempt;
j. Extensive and complicated electronic redaction;
k. Legal review;
l. Resolving issues related to retention of responsive records; and/or m. Grouped requests
To provide fullest assistance to all requesters and prevent excessive interference with other essential District functions, the District may allocate specific amounts of time and resources to responding to a request. This may include, but is not limited to, allocating a specific number of hours per week or per month to be spent by public records staff or employees for whom responding to record requests is not among their primary assigned duties. The amount of time shall be based on the factors outlined above.
When a request is for a large volume of records, the District may elect to provide records on an installment basis. If a Requester does not contact the Officer within thirty (30) days to arrange for the review of the installment, the District may deem the request abandoned and stop fulfilling the remainder of the request.
Denial and Appeal
The District has no duty to accept certain automated or bot requests. The District may deny bot requests that are one of multiple requests from a requester in a 24-hour period if responding to multiple requests would cause excessive interference with the District’s other essential functions. Because social media and voicemails may not be monitored daily, the District does not accept record requests via these means.
The District encourages any requester who believes a record has been wrongfully withheld, in whole or in part, to meet and confer with the Public Records Officer prior to seeking judicial review of the District’s response to their request.
Exemptions
The District complies with exemptions for public records requests in alignment with exemptions noted in Washington State law. Some records are exempt from disclosure, in whole or in part. If the District believes that a record is exempt from disclosure and should be withheld, the Officer will state the specific exemption and provide a brief explanation of why the record or a portion of the record is being withheld. If only a portion of a record is exempt from disclosure, but the remainder is not exempt, the Officer will redact the exempt portions, provide the non-exempt portions, and inform the requester why portions of the record are redacted.
For informational purposes, under Washington State law records exempt from disclosure include, but are not limited to:
Library Records of Individual Users. Any library record subject to RCW 42.56.310, as interpreted by the District’s Privacy and Confidentiality Policy, is exempt from disclosure and will not be released under the Public Records Act.
Public Records Act Exemptions. The Public Records Act exempts several categories of documents and records from disclosure under RCW 42.56.210 et seq. A copy of RCW 42.56.210 is available at: http://apps.leg.wa.gov/rcw/default.aspx?cite=42.56. Documents falling into any of these categories may be withheld from disclosure under the Public Records Act.
Commercial Purposes. The District is prohibited from disclosing lists of individuals for commercial purposes as provided in RCW 42.56.070. If a request includes a list of individuals, the District shall require that the requestor provide information necessary to determine if disclosure of the list of individuals is permitted or prohibited by RCW 42.56.070(8). The Commercial Purpose Declaration Form is available on the District’s website.
Address Confidentiality for Victims of Domestic Violence, Sexual Assault, and Stalking. Any employee’s name and other personally identifying information if they or a dependent are survivors of domestic violence, sexual assault, sexual abuse, stalking, or harassment, or if they participate in the address confidential program under chapter 40.24 RCW (RCW 42.56.250(1)(i)).
Other Exemptions. In addition to the exemptions provided under the Public Records Act, Washington provides several additional exemptions that are not listed in the Public Records Act. A non-exclusive list of these exemptions is available at: Public Records Act for Washington Cities, Counties, and Special Purpose Districts (mrsc.org). Documents falling into any exemption recognized by Washington statute, or otherwise under local, state, or federal law, may be withheld under the Public Records Act.
Third Party Rights
Prior to releasing a record, the District may, at its discretion, provide notice to an individual or organization named in a public record or to whom the record specifically pertains (unless notice is required by law) to allow the third party to seek relief pursuant to RCW 42.56.540. The District may take into account any such third-party notification, including the time necessary for any request for injunction or other relief under RCW 42.56.540 to be resolved, in providing an estimate for when the records will be available. Nothing in this document is intended to create any third-party right to notice of Public Records Act requests.
Charges
For reasons stated in Resolution No. 24-10, adopted by the Board of Trustees on 08/14/2024, and incorporated herein by reference, the District finds that it would be unduly burdensome and would interfere with District operations to calculate all actual costs for providing records.
In compliance with RCW 42.56.120, no fees are charged for inspection of documents. Fees for paper or electronic copies will be charged pursuant to the state statutory default copying charges detailed in RCW 42.56.120, which are subject to change without written notice. The current Fee Schedule is attached to the Public Records Request Form.
At their discretion, the Officer may elect to waive these fees. Fees may generally be waived when the expense of billing exceeds the cost of copying and postage.
If charges related to copying have not been paid by the Requester, the Officer may withhold the relevant documents from disclosure until outstanding fees are paid by the Requester.
Law Enforcement Requests
The District will consult with legal counsel before the release of information to law enforcement. Law enforcement will receive access to confidential library records upon receipt of process, order, or subpoena in proper form and with a showing of good cause for its issuance.
Delivery of Records
Documents are available for inspection by appointment the District’s Administrative Office in Port Hadlock, WA, Monday through Friday, 8:00am – 5:00pm, excluding legal holidays or upon official closure of the District. Arrangements for inspection and/or copying must be made in advance. To schedule an appointment, email publicrecords@jclibrary.info or contact the Public Records Officer at 360-385-6544.
Inspection of public records must occur in a non-disruptive manner. No member of the public may remove public records from the viewing area or disassemble or alter any public record. The requester shall indicate which records they wish to have copied using a mutually agreed upon nonpermanent method of marking the desired record.
On request, physical or digital copies may be made available to the requester. The District may determine the method of production for electronic records at its own discretion if the electronic files are too large to be shared via email. The District will not provide records on portable media (e.g. thumb drives) provided by a requester or by uploading to a private file-sharing site.
Failure to Respond
The District will deem a request abandoned in the following circumstances:
1. If a requester fails to respond to a District request to clarify, whether individual or grouped, within thirty (30) days of the request for clarification, and the entire request is unclear;
2. If a requester has elected to inspect records, the request, whether individual or grouped, maybe deemed abandoned:
a. If the requester fails to contact the Office to arrange for the review of the installment within thirty (30) days of making arrangements to inspect the records in person.
b. If the requester misses an appointment to inspect responsive records or any installment of records and fails to contact the Officer to arrange another appointment to inspect within 30 days of the missed appointment.
3. If a requester has elected to receive copies of records, a request, whether individual or grouped, may be deemed abandoned:
a. If the requester fails to open and download within thirty (30) days copies of responsive records or any installment of records provided to the requester electronically.
b. If the requester fails to pick up hard copies of responsive records or any installment of records within thirty (30) days of the date on which such copies are made available for pickup.
c. If the requester fails to pay for copies of any records or any installment of records within thirty (30) days of receiving an invoice for those records; or
d. If the requester fails to pay a deposit, as provided in the Charges section of the Public Records Request Policy, within thirty (30) days of receiving an invoice for such deposit.
Closing the Request
Once all copies of requested records have been provided to the requester, the requester has reviewed the requested records, or thirty (30) days have passed since the requester was notified that the records were available and the requester has failed to contact the Officer to arrange for the review of those records or for payment for copies, the Officer shall close the records request.
Disclaimer of Liability
Neither the District nor any officer, employee, official, or custodian shall be liable, nor shall a cause of action exist, for any loss or damage based upon a release of public records if the person releasing the records acted in good faith in attempting to comply with the Policy or process outlined in this document.