Office of Information Practices

U Memo 22-05
June 30, 2022
Confidential Sources’ Names in a Completed Investigation

A former employee of the City and County of Honolulu (City) appealed the redaction of witness names from a completed investigation by the City’s Department of Human Resources’s (HR-HON).  OIP concluded that whether the request was treated as one for personal records or for government records, HR-HON was not entitled to withhold the names and identifying information of individuals named in the responsive records as confidential sources because HR-HON had not met its burden to factually establish either that they spoke under an express or implied promise of confidentiality or that they would have been reluctant to speak without such a promise.  However, HR-HON was entitled to redact direct business email addresses under the UIPA’s frustration exception to the extent they had not been previously published.