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RESOLUTION Page 13 of 15 <br />4.12 Exemption from Disclosure <br /> <br />Withholding or Redaction of Records <br />Requested records may be subject to exemption from disclosure under the Public Records Act or <br />other statutes. Exempt records shall be withheld or redacted, when necessary, consistent with <br />statutory requirements and the withholding or redaction shall be documented for the requestor <br />in accordance with the requirements of RCW 42.56.210 and this policy and procedure. <br /> <br />The presence of exempt content does not necessarily exempt an entire record from disclosure. <br />Exempt portions of an otherwise disclosable record shall be redacted, when necessary, prior to <br />inspection or copying. <br /> <br />Prior to withholding exempt records or redacting portions of records, the Records Liaison shall <br />consult with the Public Records Officer and City Attorney. Departments may adopt standard <br />procedures for withholding or redacting portions of commonly requested exempt records. <br /> <br />When requested records are redacted, the Records Liaison shall keep a copy of the redacted <br />records for the request file. A listing only of the redacted records provided to the requestor is not <br />sufficient in accordance with the provisions of the official Washington State records retention <br />schedules. <br /> <br />Exemption Log <br />When records are withheld or redacted, the requestor shall be informed in writing of the reason <br />and be provided the statutory citation supporting the exemption. An exemption log shall be <br />prepared for the requestor listing the information withheld and the statutory basis for each <br />redaction or record withheld. Individual occurrences of the same redaction may be listed <br />generally in the exemption log. For example, an exemption log need not list separately every <br />occurrence of the redaction of an individual’s social security number, but may list one time that <br />the number has been redacted throughout the record. <br /> <br />Administrative Review of Denial <br />A requestor may ask for review of a decision to withhold or redact exempt records by submitting <br />a written petition to the Public Records Officer that includes a copy of or detailed description of <br />the City’s statement of withholding. The request for review and any relevant information shall be <br />forwarded immediately to the City Attorney, who shall consider the petition and either reverse or <br />affirm the denial within two days of the City’s receipt of the petition. The City and the requestor <br />may mutually agree to a longer period of time for consideration of a petition for review. If the <br />withholding or redaction is affirmed, the decision shall be considered the City’s final action for the <br />purposes of judicial review. If the decision to withhold or redact is reversed, the Public Records <br />Officer shall make the subject records available to the requestor for inspection in accordance with <br />the provisions of this policy and procedure. <br /> <br />4.13 Requests Log and Retention <br /> <br />Requests Log <br />The Public Records Officer shall maintain a log of all requests and associated documents.