FOIAC's Public Records subcommittee recommendations for 2009

The FOI Advisory Council's subcommittee on Public Records decided not to take any action on a proposal by the Prince William County Schools (PWCS) to exempt from disclosure data collected by its Visitor Identification System (VIS).

Visitors to Prince William schools are required to show some sort of official identification, which is then scanned into the VIS, a software program developed by Raptor Technologies, and matched against nationwide sex offender databases. If a visitor shows up on one of those databases, he or she is "flagged" and barred from school property, even if he or she is the parent of a child. PWCS reported that the system had prevented 11 registered sex offenders from entering school grounds.

The system collects and maintains digital images of the identification cards, as well as a host of personal information.

PWCS first floated the idea of an exemption in 2008, but the full advisory council was skeptical, and no one filed a bill on the school's behalf. When PWCS returned to the full council this year, the council peppered the district's lobbyist, James Council, and its attorney, Mary MacGowan, about the propriety and efficacy of VIS in general, and eventually decided to refer the suggestion to the Personal Records subcommittee.

Noting that many of the comments made at the September meeting were about policy matters outside the scope of FOIA, the subcommittee then pointed out that much of the information that PWCS wanted to protect was already exempt by other Virginia laws, like the exemption for student records, security systems or for the first five digits of a Social Security number.

Craig Fifer, the subcommittee's chair, also suggested that PWCS work with Raptor to better manage their data fields so that exempt information can be quickly identified and/or that unnecessary information is not retained by the system in the first place.