Office of Information Practices

U Memo 25-18
May 7, 2025
Sensitive Location Data

The Department of Land and Natural Resources (DLNR), sought an opinion on whether it may withhold “sensitive location data” under part II of the UIPA.  DLNR explained that it was developing a program in which community groups would voluntarily share data related to fisheries and marine resources, and that the community groups may be concerned that if the location data was released to the public it could be exploited by fishers from outside the communities.

Section 92F-13(3), HRS, allows agencies to deny access to records when disclosure would result in the frustration of a legitimate government function.  Here, OIP concluded that DLNR may redact sensitive location data under section 92F-13(3), HRS, when community groups voluntarily provide DLNR with location data based on an understanding that the data would not be made public, and disclosure would impair DLNR’s ability to receive similar information in the future.