STRIKING A BALANCE BETWEEN PUBLIC INTEREST OF
TRANSPARENCY OF GOVERNMENT AND THE PRIVACY
OF PERSONAL IDENTIFICATION AND SECURITY
INFORMATION: AN EXAMINATION OF TRIBUNE-REVIEW
PUBLISHING CO. V BODACK
I. INTRODUCTION
Pennsyivanians generally want the government to work
properly and to be free from corruption. They also generally want
to know how tax dollars are spent and how efficiently the
government works. The Right-to-Know Law provides access to
state government public records to any individual or entity that
properly requests them. ' The purpose of this law is to give a level
of transparency to the inner workings of the state government.^
However, this right to access public records could lead to the
inadvertent disclosure of important personal identification and
security information of innocent, private citizens.
Under the Right-to-Know Act, the state court system took
responsibility for determining not only what fits into the definition
of a "public record," but also whether the public interest in the
information outweighs the possible " 'impairment of a person's
reputation or personal security' " by the disclosure of that
information.^ Because, historically, Pennsylvania courts have
broadly interpreted the public record definition, individuals are at a
' Right-to-Know Law, 65 PA. STAT. ANN. §§ 67.101- .1102 (West Supp.
2009). The Right-to-Know Law completely overhauled public records access in
Pennsylvania, effective January 1, 2009. Id. §67.101. However, this act only
applies to requests for public records after December 31, 2008. Id. § 67.3101. So
any case pending with a request for information prior to December 31, 2008,
should be decided under the former Right-to-Know Act. The implications of the
revised Right-to-Know Law are discussed in the evaluation section. See infra pt.
IV.
' Pa. State Univ. v. State Employees' Ret. Bd. {Penn State), 935 A.2d 530,
533 (Pa. 2007) (citing Sapp Roofmg Co. v. Sheet Metal Workers' Int'l Ass'n,
Local Union No. 12, 713 A.2d 627, 629 (Pa. 1998)).
^ Id. at 538 (quoting § 66.1(2), repealed by Right-to-Know Law, 65 PA.
STAT. ANN. §67.102 (West Supp. 2009)) (citing Goppelt v. City of Phila.
Revenue Dep't, 841 A.2d 599, 603-04 (Pa. Commw. Ct. 1998)).
577
578 WiDENER LAW JOURNAL [Vol. 19
greater risk of having personal identification and security
information released to the public; and therefore, the courts have
been forced to carefully balance the competing interests of the
public and of the private individual.'*
This survey will examine how Pennsylvania courts have
attempted to achieve a balance between the public's interest in the
transparency of government and the private individual's interest in
the confidentiality of personal identification and security
information. Part II examines the case law prior to Tribune-Review
Publishing Co. v. Bodaclê as well as the development of the
exception to the required disclosure of information in public
records. Part III discusses Tribune-Review Publish.
Running Head THE PATRIOT ACT OF THE USTHE PATRIOT ACT OF THE .docxtodd521
Running Head: THE PATRIOT ACT OF THE US
THE PATRIOT ACT OF THE US
THE PATRIOT ACT OF THE US
Abstract
This project will research the USA PATRIOT Act including its history and the impact the act has had on the American citizens` rights. The paper will also determine the different provisions found in the Act. After determining the Bill`s wording, this research will look at whether the rights and the constitution of the American citizens are violated by the provisions. This paper will also find out the different reauthorizations performed to the law including changes to the provisions. The advantages and disadvantages of the law are going to be explored and the conclusion will determine the law`s constitutionality and if it is easy to take the government`s powers gained and check if the power has shifted to an extent of not going back now.
Thesis Statement
The PATRIOT Act analysis will tell if the Act was written with genuine interest of the US citizens or it was written with the aim of stripping off our rights that are taken for granted by many individuals.
Body
The USA PATRIOT Act was new legislation that was formed by the Government agencies and the public to respond to the growing fears of an attack that they had during the September 11th, 2001 terrorist attacks. The USA PATRIOT acronym stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism”. The Bill was meant for implementing policies and plans with the aim of preventing a terrorist attack on our country in the near future. The Bill was also intended for the implementation of policies and plans for our citizens and interests throughout the globe (USA PATRIOT Act, 2017). There exist some controversial provisions in the power of conducting seizures and searches with the absence of “probable cause”, the gathering and interception of private communication involving text messages, email and voice call as well as the indefinite detention of terrorists who are suspected. It enabled easy access to an individual`s medical and financial records and fewer restrictions are involved in accessing court documents.
The PATRIOT Act was signed by President George W. Bush on October 26, 2001, and the act was made a necessity for keeping us safe from attacks that may occur in the future. However, there was an emergence of some concerns where some civil liberties were ignored by the Act. The law has been altered time and again since it was enacted.
According to McCarthy (2002), the Act is divided into nine categories namely surveillance, prevention of terrorism by anti-money laundering practices, improved intelligence, domestic security against terrorism, putting away judicial obstacles to investigation, border security, victims of terrorism compensation, establishment of criminal law of terrorism and terrorism classification as criminal offense. The surveillance provision has particularly brought problems regarding rights. Restrict.
SharonsDefaultJudgmentvsCitySt.Paul,MN 5 jul07ratasslegal 22Sharon Anderson
Sharon Anderson aka Peterson Scarrella decades fighting City St. Paul,MN Filing for Office to Make Government Accountable current on the MN Ballot Republican 4 MN Attorney General http://sharon4mnag.blogspot.com Civil Rights Activist Forensic Files also at http://sharon4anderson.org
1 (Slip Opinion) OCTOBER TERM, 2017
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CARPENTER v. UNITED STATES
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE SIXTH CIRCUIT
No. 16–402. Argued November 29, 2017—Decided June 22, 2018
Cell phones perform their wide and growing variety of functions by con-
tinuously connecting to a set of radio antennas called “cell sites.”
Each time a phone connects to a cell site, it generates a time-stamped
record known as cell-site location information (CSLI). Wireless carri-
ers collect and store this information for their own business purposes.
Here, after the FBI identified the cell phone numbers of several rob-
bery suspects, prosecutors were granted court orders to obtain the
suspects’ cell phone records under the Stored Communications Act.
Wireless carriers produced CSLI for petitioner Timothy Carpenter’s
phone, and the Government was able to obtain 12,898 location points
cataloging Carpenter’s movements over 127 days—an average of 101
data points per day. Carpenter moved to suppress the data, arguing
that the Government’s seizure of the records without obtaining a
warrant supported by probable cause violated the Fourth Amend-
ment. The District Court denied the motion, and prosecutors used
the records at trial to show that Carpenter’s phone was near four of
the robbery locations at the time those robberies occurred. Carpen-
ter was convicted. The Sixth Circuit affirmed, holding that Carpen-
ter lacked a reasonable expectation of privacy in the location infor-
mation collected by the FBI because he had shared that information
with his wireless carriers.
Held:
1. The Government’s acquisition of Carpenter’s cell-site records
was a Fourth Amendment search. Pp. 4–18.
(a) The Fourth Amendment protects not only property interests
but certain expectations of privacy as well. Katz v. United States, 389
U. S. 347, 351. Thus, when an individual “seeks to preserve some-
thing as private,” and his expectation of privacy is “one that society is
2 CARPENTER v. UNITED STATES
Syllabus
prepared to recognize as reasonable,” official intrusion into that
sphere generally qualifies as a search and requires a warrant sup-
ported by probable cause. Smith v. Maryland, 442 U. S. 735, 740 (in-
ternal quotation marks and alterations omitted). The analysis re-
garding which expectations of privacy are entitled to protection is
informed by historical understandings “of what was deemed an un-
reasonable search and seizure when [the Fourth Amendment] was
adopted.” Carroll v. United States, 267 U. S..
Here are the slides used in my presentation to the Toronto Computer Lawyers Group earlier today, The Year in Review: Developments in Computer, Internet and E-Commerce Law (2010-2011). It covers significant developements since my talk last spring.
Survivimg the great Bank Robbery
Burgeoning NPAs of banks can be tackled by creating a "bad" bank and allowing distressed compnaies to be restructed by specialised experts from the private sector
EXAMPLE OF STUDENT IRAC ANALYSIS (This is to show you the .docxSANSKAR20
EXAMPLE OF STUDENT IRAC ANALYSIS
(This is to show you the basic format only. If you happen to be assigned this same case do not
copy this example. Do your own analysis)
************************************************************************************************
Student Name
Date
ACCT 261-01
Ayers
IRAC Analysis
United States v. Stewart (pg. __)
Issue(s)
Issue 1
The issue in the case United State v. Stewart is whether or not Stewart has
confidentiality rights to protect her from submitting an email she sent to her
attorney and her daughter to the United States. For this case, the court is
deciding if Stewart is protected by attorney-client privilege, or work product
privilege.
Issue 2 (or 3 or 4) (If there is more than one)
Rule(s)
Rule as to Issue 1
The United States argued that any attorney-client privilege Stewart had in this
case was surrendered when she forwarded the email to a third party. The work
product privilege states that all materials that an attorney is using to prepare for
a case, are protected from subpoena.
Rule as to Issue 2 (or 3 or 4) (If there is more than one)
Analysis
Rule 1, Issue 1
The United States was right that Stewart had waived her attorney-client
privilege, however, the work product privilege still applies unless she takes an
action that increases the risk that the United States would gain access to such
materials. The court had to decide on whether or not forwarding the email to a
close family member is considered an action that would increase such risk.
Rule 2 (or 3 or 4), Issue 2 (or 3 or 4) (If there is more than one)
Conclusion
The court ruled that Stewart did not in fact have to submit any emails to the
United States, for use in court. The court found that forwarding an email to a
close family member does not reasonably increase the risk that the government
would gain access to it.
What I Learned from this Case
From this case I learned the finer details on both the attorney-client privilege,
and the work product privilege. It helped illustrate both rules and how they are
applied. I also learned how you can forfeit one right but not the other, and that
an action such as sharing a document from your own legal case with a family
member can void a protection you have against that document’s seizure.
Page 569
121 Wn.App. 569 (Wash.App. Div. 2 2004)
89 P.3d 717
STATE of Washington, Appellant,
v.
Matthew Allen STINTON, Respondent.
No. 29474-5-II.
Court of Appeals of Washington, Division 2.
May 4, 2004
[89 P.3d 718]
[121 Wn.App. 570] Eleanor Marie Couto, Longview, WA,
for Respondent.
Michelle L. Shaffer, Cowlitz Co. Pros. Attorney Office,
Kelso, WA, for Appellant.
SEINFELD, J.
The trial court dismissed a residential burglary charge
against Matthew A. Stinton, reasoning
Page 571
that the State lacked proof of Stinton's intent to commit a
crime inside th ...
Our unstable world has left many American’s to consider the costs and benefits of national security and civil rights. This paper briefly reviews the States Secret Privilege, Foreign Intelligence Surveillance Act (FISA), and The Patriot Act. In response to the attacks to our financial capital in New York and our nation’s defense department, The Patriot Act was enacted. These expansive powers granted to protect our security are examined in terms of how the impact upon potential limitations to our Constitutional Rights.
Student answer The French and the German were a bit different w.docxjohniemcm5zt
Student answer
The French and the German were a bit different when it came down to decentralized and centralized characteristics. The French on one hand had very high forms of decentralization. One said by Alexis de Tocqueville "Decentralization has, not only an administrative value, but also a civic dimension, since it increases the opportunities for citizens to take interest in public affairs; it makes them get accustomed to using freedom. And from the accumulation of these local, active, persnickety freedoms, is born the most efficient counterweight against the claims of the central government, even if it were supported by an impersonal, collective will.” This shows us how decentralization occurred in France. On the other hand Germany focused more on centralization their value of though was a bit different. About 439 districts have adapted to the centralization characteristics while there were other districts in Germany that still opposed this ideology. There is still a debate whether to adapt to centralization or decentralization even till the year 2005, so I would say that try both characterizes and see what is best for ones country. There is never a exclusively correct answer to any power or characteristics however, one must find where they fit best.
b.) Minimum wage law in Germany, France, Britain and the US were quite different. According to research I have found that in Germany construction workers, electrical workers, janitors, roofers, painters, and letter carriers were set off for minimum wage by the method of collective bargaining agreement. So basically in Germany you choose at what wage you want to work and its wage is decided for you, there is no set rule marked for what you will receive in the minimum wage criteria. On the other hand Britain, U.S. and France have a set minimum wage policy and this provides the nation with order and the workers with security, in case of economic fluctuation their pay will not be affected.
c.) Germany’s rules about co-determination are for the benefit of the working class. Unions were formed and they gave the workers a voice and the power to decide what is beneficial for the company, and thus they can cause the profit margin to either go up or down. I am quite fascinated with this policy, for one if I knew that I will have a say as well as power in a matter of escalating at my work place I would work extremely hard and make my workers and company better. This will not only make the economy stronger but also the society worth of value. The board and the work place level gave the people of Germany a podium to stand on and shine. So if one had any concerns with any matter in relations to the company they can step up and voice their opinion. All employees in a private sector firm are not covered by work counsel even though the law required it because of employee relations is standing on collective bargaining issues so there is no cue in where there should be a clause of protection. Its one s.
Student Answer and Work Form Unit 4 Ver. AStudent Name (required.docxjohniemcm5zt
Student Answer and Work Form Unit 4 Ver. A
Student Name (required): _______________________________
1a. Answer: _______________
1a. Key work steps
1b. Answer: _______________
1b. Key work steps
1c. Answer: _______________
1c. Key work steps
1d. Answer: _______________
1d. Key work steps
2a. Answer: _______________
2a. Key work steps
2b. Answer: _______________
2b. Key work steps
2c. Answer: _______________
2c. Key work steps
2d. Answer: _______________
2d. Key work steps
2e. Answer: _______________
2e. Key work steps
3a. Answer: _______________
3a. Key work steps
3b. Answer: _______________
3b. Key work steps
3c. Answer: _______________
3c. Key work steps
3d. Answer: _______________
3d. Key work steps
MTH133
Unit 4– Individual Project – A
1. Use the graph of ( ) to match the function to its corresponding graph. In words describe the
transformation that occurs (ex: The graph of f(x) is shifted 6 units to the left).
( )
Choose from the following functions:
( ) ( ) ( ) ( ) ( ) ( ) ( )
a)
Answer:
Function:
Description of transformation:
b)
Answer:
Function:
Description of transformation:
-4
-3
-2
-1
0
1
2
3
4
5
-3 -2 -1 0 1 2 3
-4
-3
-2
-1
0
1
2
3
4
5
-5 -4 -3 -2 -1 0 1 2 3
-4
-3
-2
-1
0
1
2
3
4
5
-3 -2 -1 0 1 2 3
Name:
c)
Answer:
Function:
Description of transformation:
d)
Answer:
Function:
Description of transformation:
2. Find the domain of the function and express the answer in interval notation. Explain in words or show the
calculations.
a) ( )
Answer:
Show Work or Explain in Words:
b) ( )
Answer:
-2
-1
0
1
2
3
4
5
6
7
-3 -2 -1 0 1 2 3
-3
-2
-1
0
1
2
3
4
5
-3 -2 -1 0 1 2 3 4 5
Show Work or Explain in Words:
c) ( ) √
Answer:
Show Work or Explain in Words:
d) ( )
Answer:
Show Work or Explain in Words:
e) ( )
Answer:
Show Work or Explain in Words:
3. Find the specified asymptotes of the following functions. Recall that asymptotes are lines therefore the
answer must be given as an equation of a line.
a) Find the vertical asymptote of the function ( )
Answer:
Show Work or Explain in Words:
b) Find the horizontal asymptote of the function ( )
Answer:
Show Work or Explain in Words:
c) Find the vertical and horizontal asymptotes of the function ( )
Answer:
Vertical:
Horizontal:
Show Work or Explain in Words:
d) Find the vertical and horizontal asymptotes of the function ( )
Answer:
Vertical:
Horizontal:
Show Work or Explain in Words:
.
More Related Content
Similar to STRIKING A BALANCE BETWEEN PUBLIC INTEREST OFTRANSPARENCY OF.docx
Running Head THE PATRIOT ACT OF THE USTHE PATRIOT ACT OF THE .docxtodd521
Running Head: THE PATRIOT ACT OF THE US
THE PATRIOT ACT OF THE US
THE PATRIOT ACT OF THE US
Abstract
This project will research the USA PATRIOT Act including its history and the impact the act has had on the American citizens` rights. The paper will also determine the different provisions found in the Act. After determining the Bill`s wording, this research will look at whether the rights and the constitution of the American citizens are violated by the provisions. This paper will also find out the different reauthorizations performed to the law including changes to the provisions. The advantages and disadvantages of the law are going to be explored and the conclusion will determine the law`s constitutionality and if it is easy to take the government`s powers gained and check if the power has shifted to an extent of not going back now.
Thesis Statement
The PATRIOT Act analysis will tell if the Act was written with genuine interest of the US citizens or it was written with the aim of stripping off our rights that are taken for granted by many individuals.
Body
The USA PATRIOT Act was new legislation that was formed by the Government agencies and the public to respond to the growing fears of an attack that they had during the September 11th, 2001 terrorist attacks. The USA PATRIOT acronym stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism”. The Bill was meant for implementing policies and plans with the aim of preventing a terrorist attack on our country in the near future. The Bill was also intended for the implementation of policies and plans for our citizens and interests throughout the globe (USA PATRIOT Act, 2017). There exist some controversial provisions in the power of conducting seizures and searches with the absence of “probable cause”, the gathering and interception of private communication involving text messages, email and voice call as well as the indefinite detention of terrorists who are suspected. It enabled easy access to an individual`s medical and financial records and fewer restrictions are involved in accessing court documents.
The PATRIOT Act was signed by President George W. Bush on October 26, 2001, and the act was made a necessity for keeping us safe from attacks that may occur in the future. However, there was an emergence of some concerns where some civil liberties were ignored by the Act. The law has been altered time and again since it was enacted.
According to McCarthy (2002), the Act is divided into nine categories namely surveillance, prevention of terrorism by anti-money laundering practices, improved intelligence, domestic security against terrorism, putting away judicial obstacles to investigation, border security, victims of terrorism compensation, establishment of criminal law of terrorism and terrorism classification as criminal offense. The surveillance provision has particularly brought problems regarding rights. Restrict.
SharonsDefaultJudgmentvsCitySt.Paul,MN 5 jul07ratasslegal 22Sharon Anderson
Sharon Anderson aka Peterson Scarrella decades fighting City St. Paul,MN Filing for Office to Make Government Accountable current on the MN Ballot Republican 4 MN Attorney General http://sharon4mnag.blogspot.com Civil Rights Activist Forensic Files also at http://sharon4anderson.org
1 (Slip Opinion) OCTOBER TERM, 2017
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CARPENTER v. UNITED STATES
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE SIXTH CIRCUIT
No. 16–402. Argued November 29, 2017—Decided June 22, 2018
Cell phones perform their wide and growing variety of functions by con-
tinuously connecting to a set of radio antennas called “cell sites.”
Each time a phone connects to a cell site, it generates a time-stamped
record known as cell-site location information (CSLI). Wireless carri-
ers collect and store this information for their own business purposes.
Here, after the FBI identified the cell phone numbers of several rob-
bery suspects, prosecutors were granted court orders to obtain the
suspects’ cell phone records under the Stored Communications Act.
Wireless carriers produced CSLI for petitioner Timothy Carpenter’s
phone, and the Government was able to obtain 12,898 location points
cataloging Carpenter’s movements over 127 days—an average of 101
data points per day. Carpenter moved to suppress the data, arguing
that the Government’s seizure of the records without obtaining a
warrant supported by probable cause violated the Fourth Amend-
ment. The District Court denied the motion, and prosecutors used
the records at trial to show that Carpenter’s phone was near four of
the robbery locations at the time those robberies occurred. Carpen-
ter was convicted. The Sixth Circuit affirmed, holding that Carpen-
ter lacked a reasonable expectation of privacy in the location infor-
mation collected by the FBI because he had shared that information
with his wireless carriers.
Held:
1. The Government’s acquisition of Carpenter’s cell-site records
was a Fourth Amendment search. Pp. 4–18.
(a) The Fourth Amendment protects not only property interests
but certain expectations of privacy as well. Katz v. United States, 389
U. S. 347, 351. Thus, when an individual “seeks to preserve some-
thing as private,” and his expectation of privacy is “one that society is
2 CARPENTER v. UNITED STATES
Syllabus
prepared to recognize as reasonable,” official intrusion into that
sphere generally qualifies as a search and requires a warrant sup-
ported by probable cause. Smith v. Maryland, 442 U. S. 735, 740 (in-
ternal quotation marks and alterations omitted). The analysis re-
garding which expectations of privacy are entitled to protection is
informed by historical understandings “of what was deemed an un-
reasonable search and seizure when [the Fourth Amendment] was
adopted.” Carroll v. United States, 267 U. S..
Here are the slides used in my presentation to the Toronto Computer Lawyers Group earlier today, The Year in Review: Developments in Computer, Internet and E-Commerce Law (2010-2011). It covers significant developements since my talk last spring.
Survivimg the great Bank Robbery
Burgeoning NPAs of banks can be tackled by creating a "bad" bank and allowing distressed compnaies to be restructed by specialised experts from the private sector
EXAMPLE OF STUDENT IRAC ANALYSIS (This is to show you the .docxSANSKAR20
EXAMPLE OF STUDENT IRAC ANALYSIS
(This is to show you the basic format only. If you happen to be assigned this same case do not
copy this example. Do your own analysis)
************************************************************************************************
Student Name
Date
ACCT 261-01
Ayers
IRAC Analysis
United States v. Stewart (pg. __)
Issue(s)
Issue 1
The issue in the case United State v. Stewart is whether or not Stewart has
confidentiality rights to protect her from submitting an email she sent to her
attorney and her daughter to the United States. For this case, the court is
deciding if Stewart is protected by attorney-client privilege, or work product
privilege.
Issue 2 (or 3 or 4) (If there is more than one)
Rule(s)
Rule as to Issue 1
The United States argued that any attorney-client privilege Stewart had in this
case was surrendered when she forwarded the email to a third party. The work
product privilege states that all materials that an attorney is using to prepare for
a case, are protected from subpoena.
Rule as to Issue 2 (or 3 or 4) (If there is more than one)
Analysis
Rule 1, Issue 1
The United States was right that Stewart had waived her attorney-client
privilege, however, the work product privilege still applies unless she takes an
action that increases the risk that the United States would gain access to such
materials. The court had to decide on whether or not forwarding the email to a
close family member is considered an action that would increase such risk.
Rule 2 (or 3 or 4), Issue 2 (or 3 or 4) (If there is more than one)
Conclusion
The court ruled that Stewart did not in fact have to submit any emails to the
United States, for use in court. The court found that forwarding an email to a
close family member does not reasonably increase the risk that the government
would gain access to it.
What I Learned from this Case
From this case I learned the finer details on both the attorney-client privilege,
and the work product privilege. It helped illustrate both rules and how they are
applied. I also learned how you can forfeit one right but not the other, and that
an action such as sharing a document from your own legal case with a family
member can void a protection you have against that document’s seizure.
Page 569
121 Wn.App. 569 (Wash.App. Div. 2 2004)
89 P.3d 717
STATE of Washington, Appellant,
v.
Matthew Allen STINTON, Respondent.
No. 29474-5-II.
Court of Appeals of Washington, Division 2.
May 4, 2004
[89 P.3d 718]
[121 Wn.App. 570] Eleanor Marie Couto, Longview, WA,
for Respondent.
Michelle L. Shaffer, Cowlitz Co. Pros. Attorney Office,
Kelso, WA, for Appellant.
SEINFELD, J.
The trial court dismissed a residential burglary charge
against Matthew A. Stinton, reasoning
Page 571
that the State lacked proof of Stinton's intent to commit a
crime inside th ...
Our unstable world has left many American’s to consider the costs and benefits of national security and civil rights. This paper briefly reviews the States Secret Privilege, Foreign Intelligence Surveillance Act (FISA), and The Patriot Act. In response to the attacks to our financial capital in New York and our nation’s defense department, The Patriot Act was enacted. These expansive powers granted to protect our security are examined in terms of how the impact upon potential limitations to our Constitutional Rights.
Student answer The French and the German were a bit different w.docxjohniemcm5zt
Student answer
The French and the German were a bit different when it came down to decentralized and centralized characteristics. The French on one hand had very high forms of decentralization. One said by Alexis de Tocqueville "Decentralization has, not only an administrative value, but also a civic dimension, since it increases the opportunities for citizens to take interest in public affairs; it makes them get accustomed to using freedom. And from the accumulation of these local, active, persnickety freedoms, is born the most efficient counterweight against the claims of the central government, even if it were supported by an impersonal, collective will.” This shows us how decentralization occurred in France. On the other hand Germany focused more on centralization their value of though was a bit different. About 439 districts have adapted to the centralization characteristics while there were other districts in Germany that still opposed this ideology. There is still a debate whether to adapt to centralization or decentralization even till the year 2005, so I would say that try both characterizes and see what is best for ones country. There is never a exclusively correct answer to any power or characteristics however, one must find where they fit best.
b.) Minimum wage law in Germany, France, Britain and the US were quite different. According to research I have found that in Germany construction workers, electrical workers, janitors, roofers, painters, and letter carriers were set off for minimum wage by the method of collective bargaining agreement. So basically in Germany you choose at what wage you want to work and its wage is decided for you, there is no set rule marked for what you will receive in the minimum wage criteria. On the other hand Britain, U.S. and France have a set minimum wage policy and this provides the nation with order and the workers with security, in case of economic fluctuation their pay will not be affected.
c.) Germany’s rules about co-determination are for the benefit of the working class. Unions were formed and they gave the workers a voice and the power to decide what is beneficial for the company, and thus they can cause the profit margin to either go up or down. I am quite fascinated with this policy, for one if I knew that I will have a say as well as power in a matter of escalating at my work place I would work extremely hard and make my workers and company better. This will not only make the economy stronger but also the society worth of value. The board and the work place level gave the people of Germany a podium to stand on and shine. So if one had any concerns with any matter in relations to the company they can step up and voice their opinion. All employees in a private sector firm are not covered by work counsel even though the law required it because of employee relations is standing on collective bargaining issues so there is no cue in where there should be a clause of protection. Its one s.
Student Answer and Work Form Unit 4 Ver. AStudent Name (required.docxjohniemcm5zt
Student Answer and Work Form Unit 4 Ver. A
Student Name (required): _______________________________
1a. Answer: _______________
1a. Key work steps
1b. Answer: _______________
1b. Key work steps
1c. Answer: _______________
1c. Key work steps
1d. Answer: _______________
1d. Key work steps
2a. Answer: _______________
2a. Key work steps
2b. Answer: _______________
2b. Key work steps
2c. Answer: _______________
2c. Key work steps
2d. Answer: _______________
2d. Key work steps
2e. Answer: _______________
2e. Key work steps
3a. Answer: _______________
3a. Key work steps
3b. Answer: _______________
3b. Key work steps
3c. Answer: _______________
3c. Key work steps
3d. Answer: _______________
3d. Key work steps
MTH133
Unit 4– Individual Project – A
1. Use the graph of ( ) to match the function to its corresponding graph. In words describe the
transformation that occurs (ex: The graph of f(x) is shifted 6 units to the left).
( )
Choose from the following functions:
( ) ( ) ( ) ( ) ( ) ( ) ( )
a)
Answer:
Function:
Description of transformation:
b)
Answer:
Function:
Description of transformation:
-4
-3
-2
-1
0
1
2
3
4
5
-3 -2 -1 0 1 2 3
-4
-3
-2
-1
0
1
2
3
4
5
-5 -4 -3 -2 -1 0 1 2 3
-4
-3
-2
-1
0
1
2
3
4
5
-3 -2 -1 0 1 2 3
Name:
c)
Answer:
Function:
Description of transformation:
d)
Answer:
Function:
Description of transformation:
2. Find the domain of the function and express the answer in interval notation. Explain in words or show the
calculations.
a) ( )
Answer:
Show Work or Explain in Words:
b) ( )
Answer:
-2
-1
0
1
2
3
4
5
6
7
-3 -2 -1 0 1 2 3
-3
-2
-1
0
1
2
3
4
5
-3 -2 -1 0 1 2 3 4 5
Show Work or Explain in Words:
c) ( ) √
Answer:
Show Work or Explain in Words:
d) ( )
Answer:
Show Work or Explain in Words:
e) ( )
Answer:
Show Work or Explain in Words:
3. Find the specified asymptotes of the following functions. Recall that asymptotes are lines therefore the
answer must be given as an equation of a line.
a) Find the vertical asymptote of the function ( )
Answer:
Show Work or Explain in Words:
b) Find the horizontal asymptote of the function ( )
Answer:
Show Work or Explain in Words:
c) Find the vertical and horizontal asymptotes of the function ( )
Answer:
Vertical:
Horizontal:
Show Work or Explain in Words:
d) Find the vertical and horizontal asymptotes of the function ( )
Answer:
Vertical:
Horizontal:
Show Work or Explain in Words:
.
Student 1 Random Student Mrs. Wilson Expository W.docxjohniemcm5zt
Student 1
Random Student
Mrs. Wilson
Expository Writing
5 Dec. 2014
Technology and Video Games – Does The Good Outweigh The Bad?
Video Games may actually improve cognitive ability by up to 20% over non-gamers says
a recent study by The University of Southern California. Despite this evidence, Ed Bell believes,
although admitting that technology has improved some aspects of society, that we do not know
how to distinguish the good uses of technology from the bad. Ed Bell’s assertion that everything
was better back in the “good ole days” is misleading. Although technology is sometimes used
indiscriminately, as Ed Bell believes in Technology, Movement, and Sound; the benefit that
technology has had on our society, I believe, outweighs the cons – although there are cons.
Teachers in America are under constant pressure to improve test scores, and raise
achievement, yet in a society tethered to technology, they are losing the battle to keep kids
engaged. Ed Bell’s discourse about a leaf blower and noise pollution left much to be desired, yet
his appreciation of the “good ole’ days,” may be agreed upon by many teachers. Back in the
“good ole days,” teachers had fewer distractions from their instruction other than the occasional
note-passing or whispering during the lesson. In today’s society, teachers have to contend with
the constant struggle to keep kids engaged in more than the latest app or text from their friend or
parent. The problem has become almost epidemic, leading to kids learning less in addition to
impeding the progress of class. This sometimes makes it necessary to reteach what the students
fail to absorb because they had their head in their phone during the lesson. Unfortunately, this is
not the only negative effect technology has had on our society.
Student 2
Although Ed Bell’s diatribe seems to wage war on technology, it is the message of
inactivity that I think is the greater take-away from the article. For years, with the increasing
presence of modern conveniences in our daily lives, society’s activity level has steadily
decreased. The U.S. Department of Health and Human Services recommends that American
adults should get the equivalent of two and a half hours of moderate-to-vigorous physical activity
each week. Children should get about an hour a day. With the popularity of games, and the
advancement of time-saving technology, there is less of this activity than there used to be – but
that is not all. With the advancement of computers and automation in the workplace, the
American employee is not working as hard either – well, not laboriously, anyway. In 1950,
thirty percent of Americans worked in high-activity occupations; by 2000, that proportion had
dropped to only twenty-two percent, according to a Harvard School of Public Health article. Ed
Bell’s article is seemingly mostly negative, but there are some positive benefits to technology as
well. .
Student Answer and Work Form Unit 3 Ver. CStudent Name ________.docxjohniemcm5zt
Student Answer and Work Form Unit 3 Ver. C
Student Name: ______________________________________
1a. Answer: _______________
1a. Key work steps
1b. Answer: _______________
1b. Key work steps
1c. Answer: _______________
1c. Key work steps
2a. Answer: _______________
2a. Key work steps
2b. Answer: _______________
2b. Key work steps
3a. Answer: _______________
3a. Key work steps
3b. Answer: _______________
3b. Key work steps
4a. Answer: _______________
4a. Key work steps
4b. Answer: _______________
4b. Key work steps
4c. Answer: _______________
4c. Key work steps
Project Proposal
·
· Introduction:
· What you want to do and why you want to do this project
· Lit Review:
· How have other people addressed similar projects?
· Methodology:
· How are you going to do what you plan to do?
· Deliverables:
· Besides a project report, what else are you going to show me when you are done?
· Project plan:
· Meta-analysis of your project. Including timeline and what parts will be hard and what will be easy.
Introduction
In general, cloud computing is the main concern for most of the organizations around the world because it makes their information available and reachable in any where they are. Actually it is a software resource that is delivered on demand as a service. There are different storages of cloud computing such as Dropbox, SkyDrive and amazon cloud drive. Cloud computing has many advantages like saving large files, back up of stored files, file sharing and access from different devices.
The study was designed with an aim of creating a website that can help people in information technology (IT) lo learn through the website and at the same time make money for having knowledge in the areas that they are good in. With this idea in mind, we took advantage of Amazon cloud equipments such as servers, switches and other networking tools to create our own website. To design and create the pages, we used the Adobe CS5 which includes Photoshop and Dreamweaver then used the Amazon web server to upload and publish the website on the browser in order for it to be accessible to everyone on the browser. The researchers had an aim wanted to undertake this project so as to help people in IT help each other learn new things and at the same time benefit financially from passing their knowledge to other people.
Goals
The main goal of this project is to make learning life easier and at the same time make people more helpful to the other people who need helps in IT field. Furthermore, this website will give the chance to earn money from providing lessons to people who wish to learn IT. Another goal that we focused on is when some companies have workload or need some people to do they can just submit it on our website and contact with who is able to be responsible to do it.
Why did we choose this project?
We choose this project to be done in this course to implement .
Student answer A. (1) Use Mancur Olsons theory to explain the b.docxjohniemcm5zt
Student answer
A. (1) Use Mancur Olson's theory to explain the behavior of Angola's government, elite, and general public with respect to the CIF and CSIH's contracts.
Angola’s government and political elite according to Mancur Olson’s theory are seen as distributional coalitions. Both parties have an incentive to partner with the CIF. China requires natural resources and the Angolan government and its elite want money. The funding is distributed amongst the group and society does not benefit at all. This behavior will continuously impede Angola’s economic growth. There is no funding for projects that create jobs to improve infrastructure. The general public suffers at the hands of this partnership. There is no trust of the government.
(2) What is stadium diplomacy? How does it fit Olson's theory?
A form of cultural diplomacy that China uses as a means to gain access to another country’s market. They are presented as gifts or constitute some sort of partnership between China and the host country. What developing country wouldn't want a newly constructed stadium? The return on a project such as this is assumes to be greater than the cost. That being to China shall we say.
B. (1) Are there parallels between China's treatment of miners in Mozambique and Zambia and Eastover Mining Company's treatment of workers in Harlan County, Kentucky? Explain.
There absolutely are parallels between China’s treatment of the Mozambique and Zambia miners and the workers in Harlan County. In both cases the workers were subjected to unsafe working conditions, unfair labor practices, and indecent wages. Fortunately, the Harlan County workers were able to strike and make a difference. In Mozambique and Zambia the state owned companies and the government swept it under the rug.
(2) Use Olson's model to explain the Chinese government's indifference to Aolong's mistreatment and near enslavement of Chinese workers in Gabon.
The main goal of the Chinese government is to increase its presence globally and strengthen its own economy. China has increased in economic strength over the past three decades. The workers that complained to the embassy regarding the treatment they received from Aolong was addressed as a nuisance. The Chinese government has a bigger incentive to turn a blind eye to the treatment of the workers. The cost of improving working conditions and overall treatment of the workers aren't seen as beneficial.
(3) Is Chinese unionism up to the task of defending Chinese workers in situations like Aolong?
It looks as those the state owned companies are protected by the government and has no incentive of changing its labor practices. Unfortunately, because of the relationship between unions and the government, the workers voice will not be heard.
(4) Why haven't Chinese unions worked to improve conditions for non-Chinese workers in places like Zambia?
Chinese unions have no incentive to improve working conditions for the non-Chinese worker. As long as the.
Student 1StudentProfessor ENG 10827 June 2014Instruments.docxjohniemcm5zt
Student 1
Student
Professor
ENG 108
27 June 2014
Instruments of Fate in No Country for Old Men
In this movie, No Country for old men, there are three main characters. Anton Chigurh of a killer, Llewelyn Moss of a welder and Vietnam veteran, and Ed Tom Bell of a soon-to-retire country sheriff. Each of the three men has the fate of their lives. Especially, some instruments in this movie play very important roles to decide the fates of Chigurh and Moss. In this movie, Chigurh and Moss are the completely different characters. While Chigurh is a cold-blooded and kills many people, Moss is a typical Amarican who is a Vietnam veteran, has wife, and fearless man. The only common thing between Chigurh and Moss is that money and gun strongly affect both of their lives and fates. Both of them try to get something they want by using guns, but finally the desires leads them to deaths.
In this movie, money plays an important role as a tool for Chigurh to do coin toss. He uses this tool, or coin when he makes his actions and decisions. He often says, “Call it” to people and bets whether he kills them or not by the result of his coin tosses. For example, he says, “Call it” when he goes to a store and talks to an old man. Fortunately, the man wins and is not killed by Chigurh. This action, coin toss, shows us Chigurh’s power, which can control other people’s fates easily without any coherent reasons. We can also say that the coin toss is the way to escape the responsibility to kill people.
The last time that he says “Call it” to someone is when he meets Moss’s wife, Carla Jean. Jean finds that Chigurh is sitting down on the chair on the corner of a bedroom. Although everyone is afraid of him and said which side of the coin, Jean denies calling the coin. Instead of calling the result of coin toss; she criticizes Chigurh’s actions. She says, “The coin don't have no say. It's just you”(Coen). She argues that he chooses his decisions, not by coin, but by himself. She wants to say that a coin does not have any power to change him. In this scene, many audiences may have the questions about Chigurh. For example, “why did he start to kill people? ”, “does he have any purpose to kill people?” and so on. Thinking the reason why he is doing coin toss, we feel that Chigurh is actually lonely and normal person who want to rely on something. It seems Chigurh is not like a usual human beings because of his behavior, looking, and talking way. However, he actually very looks like a modern people, especially Americans who are isolated rather than independent. American people are becoming to do many things by themselves because of the high technologies such as the Internet, and iPhones. Nowadays, people can find any solutions by searching the information on the Internet. Moreover phones can even hear people’s voice and answer their questions. The coin is like an iPhone for Chigurh, who does not have any relationship with others and want to rely on something.
Although he decid.
Student Project There is no extension of the due date for t.docxjohniemcm5zt
Student Project
There is no extension of the due date for the project. Late projects will not be accepted. A grade of zero will be given if the project is not turned in on time. Hard copy of the paper must be turned in to this instructor on or before the due date . No electronic submission
Paper Requirements
Use the DSM V to identify a coded disorder and use the symptoms of that disorder to create a client and case vignette. The client you create should meet all the criteria for the diagnosis you select. See following page
Student project paper organization and points distribution:
· 2 pts APA cover (page 1)
· 3 pts APA format entire paper (running heads and citations etc.)
· 20pts Accurately completed Multiaxial sheet (page2)
· 50 pts Create a client and present your client in a narrative using clinical language and terminology to describe symptoms of a DSM disorder. DSM V guidelines and criteria. This section must be at least 4 pages long and no longer than 5 pages (pages 3, 4, 5, 6) you will be penalized 5 points for each ½ page short of the 4 page narrative.
Make this person real…
· What do you observe when you meet and speak with this client
· What does this client say and how do they say it
· Describe symptoms of your client that represent indicators for an Axis I diagnosis
· Include medical issues. You must include at least one medical from Axis III
· Describe background and environmental contributors to the diagnosis at least three Axis IV factors Also provide demographics, age, race, sex etc…
· Discussion of the GAF explains criteria as it relates to your client (a paragraph 5pts.)
· You must give your client at least one assessment/ inventory/test relevant to confirming your diagnosis (depression inventory, substance abuse, OCD, bipolar or anxiety inventory etc...)
· Discuss and explain the results of the inventory ( a paragraph 5pts)
· Justify your diagnosis using DSM V criteria, terms and rule outs.( a paragraph 5pts)
· Use information secured from your two peer reviewed journal articles on the subject of the diagnosis to support your diagnosis,(a paragraph for each article 10pts)
· 10pts APA Resource/ reference page (page 7or 8) you must use and document the following:
· DSM V
· You must use, document and cite in text, at least two peer review journal articles on the topic of your diagnosis.
· The articles appear in reputable psychological research journals.
· Articles must have a publication date of 2001 to present.
· Document where you secured your assessment
· 10pts Appendix Place a copy of the inventory/assessment you used with your client in the appendix
Multiaxial Assessment
Multiaxial Evaluation Report Form
AXIS I: Clinical Disorders
Other Conditions That May Be a Focus of Clinical Attention
Diagnostic code DSM-IV name
___________ ___________________________________________
AXIS II: Personality Disorders Mental Re.
Studding abroad has become a major priority to for the higher educ.docxjohniemcm5zt
Studding abroad has become a major priority to for the higher education sectors of many counties. Because studying abroad will make students advance in many aspects of their life. Studying abroad will help students to will help students become better in their life in many aspects it will cater their academic , personal, cultural and carrier growth. Education is the most important thing in life. Without education it is impossible to accomplish anything in life. Students who get a chance to study abroad should not miss this opportunity because it is once in a lifetime opportunity due to the benefits it has.
One primary incentive of studying abroad is better education. Studying abroad ensures better educational opportunities’ compared to my home country due to a wider selection of study options to choose from. This will enable students to better specialize in their carrier that they chose. International education is also better because in many Asian countries the teaching method is more focused on theoretical knowledge more than practical. The result of this teaching style will make students gain a vast amount of information will no clue on how to use or apply them correctly. On the other hand the education system in west countries such as the united states will focus on both gaining knowledge and making sure that a student knows how to apply them correctly, so international education is better because it will make students gain a balance education between gaining a lot of knowledge and on how to apply them correctly, this will result in a balance and better rounded education.
Apart from getting better education studding abroad will help make students more independent and will make them get out from their comfort zone and face life. It will also make students to face various situations and crisez that they have to resolve with the help of the parents. And students will have to manage their on money and manage their own life which will help make students more mature. For example when I was back home at Kuwait everything was managed by my parents, such as paying bills, buying grocery. And other life aspects were also done by other people, such as cleaning the house, doing the dishes and cleaning my clothers. All those things I have never done befor in my life because we have house mades which help to do the chores. But when I came to the United states by self and I have never traved befor. I came to a foreign country when I was 18 years old and never had any responsablity to do back in Kuwait. But when I first landed I knew that I was by self and I had to take care of my own self; I searched to apartments and rented one within a weak or two from arriving, I stated to pay my own bills for water, electricity and many other responsibilities that I had to take care of. I have learned in one month to manage my life and became mature and I am grateful for this.
Other great aspect of studying abroad is that it will provide a great chance for cultural .
Student 1Student ENG 11008 March 2015The King of Equalit.docxjohniemcm5zt
Student 1
Student
ENG 1100
8 March 2015
The King of Equality Comment by Katie: Thoughtful title!
On August 28, 1936 Martin Luther King Jr. gave one of the best known speeches in American history. When people commemorate the “I Have a Dream” speech, as it has come to be identified, they recall King’s powerful message about civil rights and the true meaning of freedom in America. In the famous “I Have a Dream” speech, Martin Luther King Jr. uses a number of rhetorical devices in order to match his word choice to the strength of his message. Numerous examples of allusion, parallelism, and anaphora are used as tactics to amplify the intensity of his message. Comment by Katie: Great thesis—it makes a clear claim and provides a forecast of your paper’s outline.
King begins his speech with a reference to the Gettysburg address, “Five score years ago…” (King par. 2).The opening allusion is exceptionally moving given that King spoke in front of the Lincoln Memorial. King uses examples of allusions, or references to a person, place, thing or idea of historical, cultural, literary or political significance. Allusions can be direct or indirect, and are often used to broaden the reader’s understanding. The Gettysburg Address is not the only historical piece referenced in King’s speech; the Declaration of Independence is also referenced in paragraph four of the “I Have a Dream” speech. The speech reads, “This note was a promise that all men, yes, black men as well as white men, would be guaranteed the ‘unalienable Rights’ of ‘Life, Liberty and the pursuit of Happiness’" (King par. 4). Martin Luther King Jr. addresses the Declaration of Independence in order to get his supporters to recognize the equal rights that they deserve as Americans. In order to provide an honorable basis, King uses numerous biblical allusions. Two examples of biblical allusions used in the speech include Psalms 30:5 and Jeremiah 2:13. King cries ‘It came as a joyous daybreak to end the long night of their captivity.” (King par. 2) referring to Psalms 30:5, “For his anger is but for a moment; his favor is for a lifetime. Weeping may linger for the night, but joy comes with the morning” (Dlugan, Andrew). Martin Luther King Jr. is expressing that the struggle for the black community was long and hard but the freedom they will receive will last a lifetime. Jeremiah 2:13 was also a biblical verse King evokes in his speech proclaiming, “Let us not seek to satisfy our thirst for freedom by drinking from the cup of bitterness and hatred,” (King par. 8) referring to Jeremiah 2:13, “For my people have committed two evils: they have forsaken me, the fountain of living water, and dug out cisterns for themselves, cracked cisterns that can hold no water” (Dlugan, Andrew). King is using this biblical verse to explain to his people that they must fight peacefully, without violence and hatred, and if they do they will be rewarded for their peaceful behavior. Comment by Katie: It may be a good .
Studcnft Cl.nthiaEdnads fnrtructor: HilaryCla* Assignmenf W2:Homeworlqpt I
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Structure!Thesis British politics were changed in such a fa.docxjohniemcm5zt
Structure!
Thesis: British politics were changed in such a fashion because the changes caused something.
If these changes had not occurred, it is possible that x could have happened!
Before the 19th century Reform Acts, British politics possessed a conservative, statesmanlike,
and stable character. The Reform Acts introduced modern republicanism without significant
disruption because the working class British that became incorporated respected British
hierarchical society and the parliamentary system. Furthermore, many of the substantial social
changes from the 19th-20th centuries occurred because of substantial economic changes, not
political reform. If the franchise had not been enlarged to eventually encompass the working
class, it is quite possible that radical political movements, such as the Charterists, would have
gained a political hold.!!
Bagehot and Government!
Bagehot writes from within the period studied!
Bagehot takes an aristocratic view of government!
Ruling takes education, experience, and sobriety--this is what he calls “statesmanship”!
Statesmanship!
The job of the political elites is to provide sober judgment on issues!
His condemnation of American politics largely rests on the inability of the Americans to reach
sober conclusions on politically necessary issues!
Because the President and Congress are in constant competition, there can be no
statesmanship (37)!
The introduction of the working class endangers this statesmanship!
Bagehot writes, “I am exceedingly afraid of the ignorant multitude of the new constituencies.” (p.
17)!
The introduction of the working class would require specific actions on the parts of the
statesmen, and provide a real danger!
However, while Bagehot is anxious about reform, he does not dismiss it out of hand -- it is a
challenge but could provide reasonable results of the Parliament is followed!
Was he right or wrong? Were his concerns justified?!
Bagehot’s concerns are legitimate. The course of other countries’ attempts to reform would
demonstrate that. However, organized, radical labor movements did not form in Britain!
1832 Reform Act!
On its face, the 1832 Reform Act was substantial!
It brought 10-pound householders into the vote!
Functionally, this extended the franchise!
In practice, Bagehot, argues, it was not so extreme!
In the first place, constitutional changes take time to be discovered, as generational changes
matter (7)!
Most of the pre-1832 elites, such as Lord Pemberton, remained in power until the mid-1860s (7)!
Secondly, England is a “deferential society,” argues Bagehot.!
The newly-incorporated members did not participate directly in politics -- they remained
shopkeepers (8)!
“If a hundred small shopkeepers had by miracle been added to any of the ‘32 Parliaments, they
would have felt outcasts there.” (8)!
Parliament remained the space of the elite!
The newly-incorporated did not vote to push their personal interest in politics at the national
level!
They voted .
Student #1 I have chosen to write about the history of data anal.docxjohniemcm5zt
Student #1
I have chosen to write about the history of data analysis for the Los Angeles Police Department. While I currently reside in Colorado Springs, Colorado and work as a deputy sheriff in Denver, Colorado I grew up in the greater Los Angeles area and I know that they should have a large amount of data to draw from.
Currently the Los Angeles Police Department uses COMPSTAT to compile their data. They have a unit, known as the COMPSTAT unit, whose sole job is to compile crime statistics and analyze the data (Los Angeles Police Department, 2016) COMPSTAT is short for computer statistics. COMPSTAT was developed by Police Commissioner William Bratton in 1994 for use by the New York Police Department. According to the University of Maryland by the year 2000 over a third of police agencies with over 100 officers were utilizing some sort of COMPSTAT like program (University of Maryland, 2015). In 2002 William Bratton became the Chief of Police for the Los Angeles Police Department and brought with him the concept of COMPSTAT. During the first six years of his tenure Los Angeles saw a steady decrease in the cities crime rates thanks largely in part to COMPSTAT policing.
Mean, mode and median play a large part in analyzing criminal data. The mean is the average number. An example of this for crime data analysis would be in neighborhood C there was 14 robberies committed on Monday between 1 and 3 AM, 17 robberies on Tuesday at the same time period and 9 on Wednesday during the same time period. The mean would be 13.3 robberies per night for those 3 nights. Knowing this is high for the city the data could be used to justify extra police presence in Neighborhood C. An example of the mode would be if in the same neighborhood in the same week there were 17 robberies on both Friday and Saturday, 12 on Thursday and 11 on Sunday. The mode would be 17 and it would also be a reason to add extra police presence in the neighborhood until a significant decrease was seen in the amount of robberies taking place. Finally we come to the median. This is simply line the numbers up for the week and take the number that falls in the middle. In the case of the robberies occurring in neighborhood C the number would be 14. All of this data can be combined to show watch commanders and captain’s areas where they should be focusing their officer’s time. If there is a neighborhood that has seen only one or two robberies during the week, it is definitely not in as much need of a heavy police presence as Neighborhood C is.
Student #2
Beginning in the mid-1990’s, police in New York began to run statistical analysis of the city’s crime reports, arrests and other police activity known as COMPSTAT. Law enforcement agencies since this analysis began, has implemented their own data-driven approaches to tracking and adapting to crime trends. The LAPD is both heavily armed and thoroughly computerized. The Real-Time Analysis and Critical Response Division is its central processor..
Student answer (a) In US business unionism focuses on benefits t.docxjohniemcm5zt
Student answer
(a) In US business unionism focuses on benefits to existing members, (opposed to other countries like Britain) employers’ organizations are not prominent at any level, however, employer’ organizations that seek to maintain unions away from employees have been prominent.
(b) Diversity creates a wider range of variation employment practices, (to mention one factor) but Britain lacks such factor, in addition, the government does not support employment regulation as it happens in US. (i) New modernized methods of union organizing have been implemented such as intensive direct communication with prospective members through young well-educated organizers. (ii) In the US diversity has been a strong factor leading to wider employment arrangements.
(c) (i) (i) according to Olson the likelihood of cross-national cooperation confronts different barriers such as, divergent interests, national differences in language, culture, law and union structure. However the potential exists.
Student answer
US employers are amongst the most anti union employers in the world because unions tend to hurt productivity and reduce profit margin.
Business Unionism uses the principle that unions should operate like a business. It has been attractive to the US employees because business union jobs pay better wages than non-union equivalents. It is operated by employers and employees, therefore the interest of all parties is advocated.
To expand union membership, the US confederation, the AFL-CIO tried to modernise and broaden issues that attract union members such as child care and equal pay. They have also used young well-educated organisers and involve extensive direct communication with prospective members and links to community groups such as churches.
The union density plummeted in the US because of the split of the major unions forming a coalition called the CTW - change to win coalition. In the UK the fall was due to state labour policies, management resistance and workplace practices, changing composition employment and the labour force and issues internal to unionism.
Non union personnel practices have developed the furthest in the US.
Cross-national cooperation is possible through trade and treaty agreements. The major difference between liberal and coordinated is the ability to obtain capital without having to plead with a bank. The liberal has the access to capital via public markets such as stocks and bonds while this is not so with the coordinated.
Olson will say that cross-national cooperation will break barriers and economic incentives such as increased trade will be gained.
Student answer
(a) The U.S. operates on "Employment at will" where employers do not have to provide just cause for dismissal, reasonable notice or severance pay on dismissal of an employee. The U.S. business unionism, focuses narrowly on providing benefits to existing members.
(b) The AFL-CIO tried to modernize and broaden issues that attract union members, (.
Structured Query Language for Data Management 2 Sructu.docxjohniemcm5zt
Structured Query Language for Data Management 2
Sructured Query Language for Data Management 6
Table of Contents
Phase 1- Database Design and DDL 3
Business Rules & Entity Tables 3
Entity Tables: 4
SQL CODE: 4
Screenshots: 8
Phase 2 – Security and DML 13
Task 1 14
Task 2 15
Task 3 16
Task 4 17
Task 5 18
Phase 3 - DML (Select) and Procedures 19
Task 1 19
Task 2 20
Task 3 21
Task 4 22
Task 5 23
Phase 4 – Architecture, Indexes 27
Step 1: CREATE TABLE [Degrees] 27
Step 2: Re-create ‘Classes’ TABLE to add ‘DegreeID’ column and INSERT 6 classes 29
Step 3: ALTER TABLE [Students] 31
Step 5: DML script to INSERT INTO the ‘Students’ table ‘DegreeID’ data 33
Step 6: Display ERD 36
Phase 5 – Views, Transactions, Testing and Performance 37
References 38
Phase 1- Database Design and DDL
My team was recently contracted to design and develop a database for CTU that will store personal and confidential university data. This database is expected to provide the back-end architecture for a front-end web application with an intuitive User/Interface (U/I) to be used by the university HR department. We’ve decided to use Microsoft SQL Server 2012 given the nature of data to be stored because it will be more secure, and it also provides a suite of server maintenance tools to be left behind with the IT Department once the database and web application have been tested and accepted by university stakeholders.
During our preliminary meetings, CTU’s requirements were defined and adequately scoped to begin creation of the database. The following sections contain the business rules and entity tables developed during the preliminary meetings, as well as copies of all the SQL code used to build the database and create the Entity Relationship Diagram (ERD). Business Rules & Entity Tables
Business Rules:
· A student has a name, a birth date, and gender.
· You must track the date the student started at the university and his or her current GPA, as well as be able to inactivate him or her without deleting information.
· For advising purposes, store the student's background/bio information. This is like a little story.
· An advisor has a name and an e-mail address.
· Students are assigned to one advisor, but one advisor may service multiple students.
· A class has a class code, name, and description.
· You need to indicate the specific classes a student is taking/has taken at the university. Track the date the student started a specific class and the grade earned in that class.
· Each class that a student takes has 4 assignments. Each assignment is worth 100 points.Entity Tables:
SQL CODE:
Create Database:
CREATE DATABASE [Cameron_CTU]
CONTAINMENT = NONE
ON PRIMARY
( NAME = N'Cameron_CTU', FILENAME = N'c:\Program Files\Microsoft SQL Server\MSSQL11.SCAMERON_CTU\MSSQL\DATA\Cameron_CTU.mdf' , SIZE = 3072KB , FILEGROWTH = 1024KB )
LOG ON
( NAME = N'Cameron_CTU_log', FILENAME = N'c:\Program Files\Microsoft SQL Server\MSSQL11.SCAMERON_CTU\MSSQL\DATA\Cameron_CTU_.
strict
man-
lPer-
)nger
,n Of
raced
rhfies
s the
rator,
nore,
L best
e was
eaker
I was
ctive
utive
lP99r
df-
rated
ettle-
tially
iih a
weie
igz).
Iow-
I the
the
ies.
rably
)rm-
:es as
kers,
:ived
nore
shed
rda
dren
nent
roth-
lblic
967;
hted
rent,
:articularly the importance of organization and
:uldraising. In fact, in their early years, their
appeal was enhanced by the application of cor-
:orate and scientific methods to social reform,
:articularly among the educated middle and
:nper classes. Unlike the COS, however, settle-
=ents lacked clarity on their basic organizational
:i- rm and struggled with persistent contradic-
:Lans between their democratic values and their
,-::iance on elites for funding and political sup-
f,ort (Wenocur & Reisch, 1989).
During World War I, most local nonprofits
:egan to be coordinated by business-dominated
-cmmunity Chests, the antecedents of today's
lfited Way. The presence of business leaders
qstlred the primary of corporate methods and
r"r.-ues in the private human services field
i,:illiant, 1990). As these agencies professional-
-red during the 1920s, this federated structure
xrtr&me the logical vehicle to rationalize philan-
lrropv and help nonprofit human services orga-
'r'nv* tions survive fi nancially.
-{t the same time, there was a shift in the over-
iunc.t of public services, from volunte er organiza-
tr:ns administered by boards to executive-based
,Ffl',ffi.rns of supervision. This reflected an increase
m frate and local government involvement in and
a'ntol of societal change. The emergence of the
fdc of public administration led to increased
um:ressionalism in government departments of
lmu*::-l rr'elfare. These bureaucracies were receptive
m 3e expertise social workers had acquired in
umr'ersities and private charitable organizations.
fhe appearance of "welfare capitalism" in the
rrn= of company unions and other employee
mm,edt packages during the 1920s, however,
rum:e,rmined advocates of governmental inter-
tmtron in the social welfare arena by promoting
ffic rage of the socially responsible corporation
urr,ru:se profits were linked to American progress
mrc mell-being (Berkowitz & McQuaid, 1980).
imer developments that shaped human services
mnmrn rlistration in this era included the expansion
m rrecialized organizations in such fields as
mreadon, mental health, juvenile and criminal
nuum=" child welfare, and occupational social
General Themes in the Evolution of HSA 33
work; the formation of a professional infrastruc-
ture through such organizations as the American
Association for Organizing Family Social Work,
the Child Welfare League of America, the
National Social Work Council, the Community
Chests and Councils of America, and a wide range
of professional associations; the nearly 3O0o/o
increase in the number of schools of social work
between World War I and the Great Depression;
the growth of professional journals; and the use
of the medical model and corporate.
Strengths Insight and Action-Planning Guide SURVEY COMPLETION DA.docxjohniemcm5zt
Strengths Insight and Action-Planning Guide SURVEY COMPLETION DATE: 09-29-2015
xxxxxxxxxxx
Your Top 5 Themes
Responsibility Relator Competition Analytical Futuristic
What's in This Guide?
Section I: Awareness
A brief Shared Theme Description for each of your top five themes
Your Personalized Strengths Insights, which describe what makes you stand out from others with the same theme in their top five
Questions for you to answer to increase your awareness of your talents
Section II: Application
10 Ideas for Action for each of your top five themes Questions for you to answer to help you apply your talents
Section III: Achievement
Examples of what each of your top five themes "sounds like" -- real quotes from people who also have the theme in their top five
Steps for you to take to help you leverage your talents for achievement
Section I: Awareness
Responsibility
Shared Theme Description
People who are especially talented in the Responsibility theme take psychological ownership of what they say they will do. They are committed to stable values such as honesty and loyalty.
Your Personalized Strengths Insights
What makes you stand out?
By nature, you prefer to work with teammates who share your concern about doing everything correctly and ethically. It’s very likely that you bring an exceptionally mature perspective to your team. Most people regard you as the dependable and reliable one. Because of your strengths, you sometimes open yourself to diverse types of people. You ordinarily welcome individuals who otherwise would feel out of place or ignored. Instinctively, you may reject the idea that telling a falsehood about something unimportant is acceptable. Perhaps you refuse to make an innocent social excuse to protect someone’s feelings. Driven by your talents, you experience pangs of remorse when you realize you failed to do something you promised to do. You feel awful when you do not do something correctly. You probably regret having compromised your basic values about right and wrong.
Questions
As you read your personalized strengths insights, what words, phrases, or lines stand out to you?
Out of all the talents in this insight, what would you like for others to see most in you?
Relator
Shared Theme Description
People who are especially talented in the Relator theme enjoy close relationships with others. They find deep satisfaction in working hard with friends to achieve a goal.
Your Personalized Strengths Insights
What makes you stand out?
Because of your strengths, you have the ability to instruct, train, or offer suggestions to people who look to you for assistance. It’s very likely that you probably are quite willing to welcome all kinds of individuals regardless of their appearance, education, social class, native language, religious preference, or political persuasion. This explains why your circle of friends or acquaintances is so diverse and interesting. Your openness might encourage people to seek your c.
Strategy Project/.DS_Store
__MACOSX/Strategy Project/._.DS_Store
Strategy Project/EXAMPLECompleted Strategy Team Project.docx
Issue: Given the success of being one of the world’s largest global payments technology companies, MasterCard has an opportunity to enter into the country of North Korea to expand its technology basis and help build the North Korean economy.
Recommendation: MasterCard should research and investigate the costs and benefits of expanding itself into North Korea.
Justification: In its current state, MasterCard is the second largest global payments technology organization and could use this strength to enter into North Korea to help build their economy not only by introducing its products and services into the country, but to help a weak economy become stronger with the proper use of a global payment technology.
Issue: Attempting to expand into other third world countries increases the security threat. The security at MasterCard needs an update to prevent their customers from becoming targets of credit card breaches and fraud.
Recommendation: MasterCard should design a new digital debit/credit card that uses a thumbprint to authorize the use of the card.
Justification: Fingerprints are a unique feature that can provide great security assurance when dealing with theft. The fact that no two fingerprints are identical will make it hard for fraud to take place.
Task 1: A Research and Development (R & D) team will be established for a 12 month period beginning May 2014 and continuing through May 2015 to determine what areas within North Korea would be in the best interest for MasterCard to locate. The team would consist of accountants, lawyers, management, and several other individuals who would work solely on this project for the year. The estimated cost for this project could reach up to $2 million. The current budget is listed at $2.5 million. All correspondence and findings will be reported to the current CEO, CFO, and COO as well as the Board of Directors.
Throughout the year, the R & D team will spend ample time traveling and speaking with the delegates of North Korea to get a good feel of the acceptance of a large corporation entering into their country. Travel expenses during the complete project are estimated to be a total of $150,000 of the expected budget.
The initial expense per visit to North Korea is a $1000 required tour that does not include any other amenities such as airfare, hotel, or food. The estimated complete “tour” expense for the year is $5,000. The flight expense during the year for the R & D team estimates the cost of $18,150 during the year. It is estimated that each ticket would cost $726 and no more than 5 team members would travel at a time, with an estimated 5 trips per year. A budget of $25,000 has been allotted for flight expenses alone due to the current trips per year estimation. As the end of the research gets closer, there may need to be an additional trip or two that need.
STRAYER BUS475 WEEK 10 QUIZ 10Report this Question as Inappropri.docxjohniemcm5zt
STRAYER BUS475 WEEK 10 QUIZ 10
Report this Question as Inappropriate
Question 1
Which of the following sectors receives the largest percentage of corporate cash and in-kind contributions?
Health and human services.
Education.
Civic and community.
Culture and arts.
Question 2
Which company paid its employees to volunteer in their communities two days a week after a tsunami in Japan disrupted operations at its U.S. facilities?
General Electric.
UPS.
Sony.
Honda Motor Company.
Question 3
As communications improve and people around the world are able to witness the horrors of natural disasters, terrorism, and war, international relief efforts by corporations are becoming:
Less important.
More important.
Obsolete because of social media.
A liability because of negative media.
Question 4
Which company donates 5 percent of its branches or stores’ total sales revenue to a worthy local nonprofit organization three days a year?
H&M.
Whole Foods Markets.
Bank of America.
Citigroup.
Question 5
What company gives all of its earnings to charity?
Seventh Generation.
The Body Shop.
Newman’s Own.
Patagonia.
Question 6
Foreign-owned corporations use foundations:
More frequently than U.S. firms.
Less frequently than U.S. firms.
About as often as U.S. firms.
Only for setting up disaster relief.
Question 7
Which of the following non-profit, locally funded and controlled organizations offer housing rehabilitation and financial services to neighborhood residents?
General Electric.
UPS.
Sony.
Honda Motor Company.
Question 8
Habitat for Humanity is considered a:
Corporation.
Government division.
Nongovernmental organization.
Program for the homeless.
Question 9
According to a Harvard Business Review study, which of the following is not an area in which corporate contributions are most likely to enhance a company’s competitiveness?
Context for strategy and rivalry.
Demand conditions.
Stakeholder management.
Factor conditions.
Question 10
The term civic engagement describes:
The active involvement of businesses and individuals in improving communities.
A competitive, free market environment.
Strong governmental regulation to control businesses at the municipal level.
A close and collaborative business-government relationship.
Question 11
What percentage of AT&T’s procurement spending went to minority, women, and disabled veteran-owned businesses in 2011?
1 percent.
5 percent.
15 percent.
25 percent.
Question 12
The share of all giving made up by in-kind contributions of products and services has been:
Rising steadily over the past decade.
Declining steadily over the past decade.
Remaining relatively constant over the past decade.
Declining sharply over the past decade.
Question 13
Another term for corporate giving is corporate:
Welfare.
Goodwill.
Philanthropy.
Citizenship.
Question 14
Which region received the most U.S. international charitable contributions in 2011?
Europe
Africa
Asia-Pacific.
Latin America-Caribbean.
Question 15
Which company provided one million fre.
Strayer University 2.13 (Discussion #1) Yahoo! CEO Bans Tele.docxjohniemcm5zt
Strayer University : 2.13 (Discussion #1) Yahoo! CEO Bans Telecommuting
https://strayer.mindedgeonline.com/content.php?cid=40776[10/11/2013 9:15:57 AM]
Business Ethics (BUS 309)→Week 2: Normative Theories of Ethics→2.13 (Discussion #1) Yahoo! CEO Bans Telecommuting
Business Ethics (BUS 309)
(Discussion #1) Yahoo! CEO Bans Telecommuting
After reading the case study, answer the questions below.
In 2013, the chief executive officer at Yahoo!, Marissa Mayer, announced a policy banning
employees from telecommuting. Since assuming her role as CEO less than a year before, Mayer had
sought to increase Yahoo!'s productivity and revitalize the company's image.
Mayer's decision to ban telecommuting and demand that employees show up to their desks was seen
as part of her effort to revive Yahoo! Some employees were said to be abusing the telecommuting
option by not being productive when working from home, and some had even begun running start-
ups on the side while still on Yahoo!'s payroll. In general, there was a sense that telecommuting
employees generally did less then employees working in the office. This has become a common
worry for many employers as telecommuting has grown more popular.
In the memo circulated to Yahoo! employees announcing the company's new policy, the company
cited other reasons for the restriction. The memo read:
To become the absolute best place to work, communication and collaboration will be
important, so we need to be working side-by-side. That is why it is critical that we are
all present in our offices. Some of the best decisions and insights come from hallway
and cafeteria discussions, meeting new people, and impromptu team meetings. Speed
and quality are often sacrificed when we work from home. We need to be one Yahoo!,
and that starts with physically being together. - Jackie Reses, Yahoo head of HR.
Those involved in the decision to ban telecommuting chose to highlight the need for in-person
collaboration to spark creativity and productivity. They stressed that in order for Yahoo! to be a
cohesive company, employees should physically share a space and see each other on a daily basis.
Yahoo!'s decision to ban telecommuting bucked industry trends. Telecommuting has become
increasingly popular in recent years. According to the U.S. Census Bureau, 5.82 million Americans
worked from home as of 2010, constituting nearly 4.35 percent of the overall workforce. Many
companies cite telecommuting as a reflection of a more family-friendly work environment.
Critics argued that Mayer's ban on telecommuting was misguided. They noted that when employees
are not working efficiently, it's likely a problem with management and not with the location of the
employees.
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Palestine last event orientationfvgnh .pptxRaedMohamed3
An EFL lesson about the current events in Palestine. It is intended to be for intermediate students who wish to increase their listening skills through a short lesson in power point.
Model Attribute Check Company Auto PropertyCeline George
In Odoo, the multi-company feature allows you to manage multiple companies within a single Odoo database instance. Each company can have its own configurations while still sharing common resources such as products, customers, and suppliers.
Students, digital devices and success - Andreas Schleicher - 27 May 2024..pptxEduSkills OECD
Andreas Schleicher presents at the OECD webinar ‘Digital devices in schools: detrimental distraction or secret to success?’ on 27 May 2024. The presentation was based on findings from PISA 2022 results and the webinar helped launch the PISA in Focus ‘Managing screen time: How to protect and equip students against distraction’ https://www.oecd-ilibrary.org/education/managing-screen-time_7c225af4-en and the OECD Education Policy Perspective ‘Students, digital devices and success’ can be found here - https://oe.cd/il/5yV
Instructions for Submissions thorugh G- Classroom.pptxJheel Barad
This presentation provides a briefing on how to upload submissions and documents in Google Classroom. It was prepared as part of an orientation for new Sainik School in-service teacher trainees. As a training officer, my goal is to ensure that you are comfortable and proficient with this essential tool for managing assignments and fostering student engagement.
The Roman Empire A Historical Colossus.pdfkaushalkr1407
The Roman Empire, a vast and enduring power, stands as one of history's most remarkable civilizations, leaving an indelible imprint on the world. It emerged from the Roman Republic, transitioning into an imperial powerhouse under the leadership of Augustus Caesar in 27 BCE. This transformation marked the beginning of an era defined by unprecedented territorial expansion, architectural marvels, and profound cultural influence.
The empire's roots lie in the city of Rome, founded, according to legend, by Romulus in 753 BCE. Over centuries, Rome evolved from a small settlement to a formidable republic, characterized by a complex political system with elected officials and checks on power. However, internal strife, class conflicts, and military ambitions paved the way for the end of the Republic. Julius Caesar’s dictatorship and subsequent assassination in 44 BCE created a power vacuum, leading to a civil war. Octavian, later Augustus, emerged victorious, heralding the Roman Empire’s birth.
Under Augustus, the empire experienced the Pax Romana, a 200-year period of relative peace and stability. Augustus reformed the military, established efficient administrative systems, and initiated grand construction projects. The empire's borders expanded, encompassing territories from Britain to Egypt and from Spain to the Euphrates. Roman legions, renowned for their discipline and engineering prowess, secured and maintained these vast territories, building roads, fortifications, and cities that facilitated control and integration.
The Roman Empire’s society was hierarchical, with a rigid class system. At the top were the patricians, wealthy elites who held significant political power. Below them were the plebeians, free citizens with limited political influence, and the vast numbers of slaves who formed the backbone of the economy. The family unit was central, governed by the paterfamilias, the male head who held absolute authority.
Culturally, the Romans were eclectic, absorbing and adapting elements from the civilizations they encountered, particularly the Greeks. Roman art, literature, and philosophy reflected this synthesis, creating a rich cultural tapestry. Latin, the Roman language, became the lingua franca of the Western world, influencing numerous modern languages.
Roman architecture and engineering achievements were monumental. They perfected the arch, vault, and dome, constructing enduring structures like the Colosseum, Pantheon, and aqueducts. These engineering marvels not only showcased Roman ingenuity but also served practical purposes, from public entertainment to water supply.
2024.06.01 Introducing a competency framework for languag learning materials ...Sandy Millin
http://sandymillin.wordpress.com/iateflwebinar2024
Published classroom materials form the basis of syllabuses, drive teacher professional development, and have a potentially huge influence on learners, teachers and education systems. All teachers also create their own materials, whether a few sentences on a blackboard, a highly-structured fully-realised online course, or anything in between. Despite this, the knowledge and skills needed to create effective language learning materials are rarely part of teacher training, and are mostly learnt by trial and error.
Knowledge and skills frameworks, generally called competency frameworks, for ELT teachers, trainers and managers have existed for a few years now. However, until I created one for my MA dissertation, there wasn’t one drawing together what we need to know and do to be able to effectively produce language learning materials.
This webinar will introduce you to my framework, highlighting the key competencies I identified from my research. It will also show how anybody involved in language teaching (any language, not just English!), teacher training, managing schools or developing language learning materials can benefit from using the framework.
Ethnobotany and Ethnopharmacology:
Ethnobotany in herbal drug evaluation,
Impact of Ethnobotany in traditional medicine,
New development in herbals,
Bio-prospecting tools for drug discovery,
Role of Ethnopharmacology in drug evaluation,
Reverse Pharmacology.
The Indian economy is classified into different sectors to simplify the analysis and understanding of economic activities. For Class 10, it's essential to grasp the sectors of the Indian economy, understand their characteristics, and recognize their importance. This guide will provide detailed notes on the Sectors of the Indian Economy Class 10, using specific long-tail keywords to enhance comprehension.
For more information, visit-www.vavaclasses.com
We all have good and bad thoughts from time to time and situation to situation. We are bombarded daily with spiraling thoughts(both negative and positive) creating all-consuming feel , making us difficult to manage with associated suffering. Good thoughts are like our Mob Signal (Positive thought) amidst noise(negative thought) in the atmosphere. Negative thoughts like noise outweigh positive thoughts. These thoughts often create unwanted confusion, trouble, stress and frustration in our mind as well as chaos in our physical world. Negative thoughts are also known as “distorted thinking”.
STRIKING A BALANCE BETWEEN PUBLIC INTEREST OFTRANSPARENCY OF.docx
1. STRIKING A BALANCE BETWEEN PUBLIC INTEREST OF
TRANSPARENCY OF GOVERNMENT AND THE PRIVACY
OF PERSONAL IDENTIFICATION AND SECURITY
INFORMATION: AN EXAMINATION OF TRIBUNE-REVIEW
PUBLISHING CO. V BODACK
I. INTRODUCTION
Pennsyivanians generally want the government to work
properly and to be free from corruption. They also generally
want
to know how tax dollars are spent and how efficiently the
government works. The Right-to-Know Law provides access to
state government public records to any individual or entity that
properly requests them. ' The purpose of this law is to give a
level
of transparency to the inner workings of the state government.^
However, this right to access public records could lead to the
inadvertent disclosure of important personal identification and
security information of innocent, private citizens.
Under the Right-to-Know Act, the state court system took
responsibility for determining not only what fits into the
definition
of a "public record," but also whether the public interest in the
information outweighs the possible " 'impairment of a person's
reputation or personal security' " by the disclosure of that
information.^ Because, historically, Pennsylvania courts have
broadly interpreted the public record definition, individuals are
at a
2. ' Right-to-Know Law, 65 PA. STAT. ANN. §§ 67.101- .1102
(West Supp.
2009). The Right-to-Know Law completely overhauled public
records access in
Pennsylvania, effective January 1, 2009. Id. §67.101. However,
this act only
applies to requests for public records after December 31, 2008.
Id. § 67.3101. So
any case pending with a request for information prior to
December 31, 2008,
should be decided under the former Right-to-Know Act. The
implications of the
revised Right-to-Know Law are discussed in the evaluation
section. See infra pt.
IV.
' Pa. State Univ. v. State Employees' Ret. Bd. {Penn State), 935
A.2d 530,
533 (Pa. 2007) (citing Sapp Roofmg Co. v. Sheet Metal
Workers' Int'l Ass'n,
Local Union No. 12, 713 A.2d 627, 629 (Pa. 1998)).
^ Id. at 538 (quoting § 66.1(2), repealed by Right-to-Know Law,
65 PA.
STAT. ANN. §67.102 (West Supp. 2009)) (citing Goppelt v.
City of Phila.
Revenue Dep't, 841 A.2d 599, 603-04 (Pa. Commw. Ct. 1998)).
577
578 WiDENER LAW JOURNAL [Vol. 19
greater risk of having personal identification and security
3. information released to the public; and therefore, the courts
have
been forced to carefully balance the competing interests of the
public and of the private individual.'*
This survey will examine how Pennsylvania courts have
attempted to achieve a balance between the public's interest in
the
transparency of government and the private individual's interest
in
the confidentiality of personal identification and security
information. Part II examines the case law prior to Tribune-
Review
Publishing Co. v. Bodaclê as well as the development of the
exception to the required disclosure of information in public
records. Part III discusses Tribune-Review Publishing Co. in
more
depth and examines the facts, procedural history, and the
Supreme
Court of Pennsylvania's rationale and holding. In part IV, the
ramifications and future impact of the Tribune-Review
Publishing
Co. decision is examined in light of prior case law as well as
new
legislation. Finally, a brief conclusion follows in part V.
11. BACKGROUND
Transparency is a key concept that is necessary for democracy
to work. In order for there to be transparency in government,
the
public needs to have access to public records.^ The Sunshine
Act,
combined with the Right-to-Know Act, was meant to provide
some
transparency to the inner workings of the government. The
4. Sunshine Act was enacted based on the following government
findings:
[t]he right of the public to be present at all meetings of
agencies and to witness the deliberation, policy formulation
and decisionmaking of agencies is vital to the enhancement and
proper functioning of the democratic process and that secrecy
in public affairs undermines the faith of the public in
" See Tribune-Review Publ'g Co. v. Bodack, 961 A.2d 110, 114
(Pa. 2008)
(citing Penn State, 935 A.2d at 533-34).
^ Id
^ See generally 65 PA. CONS. STAT. § 702(b) (2006).
' Id.; Penn State, 935 A.2d at 533 (citing Sapp Rooftng Co., 713
A.2d at
629) (explaining the purpose of the Right-to-Know Law).
2010] PENNSYLVANIA ADMINISTRATIVE LAW 579
government and the public's effectiveness in fulfilling its role
in a democratic society.̂
The Right-to-Know Law provides access to state public
records^ for "examination and inspection,"'*' allowing private
citizens to serve as a watchdog over state government.
However,
there are concems about the risk to individuals whose personal
identification information is contained within the disclosed
public
records."
5. In Pennsylvania State University v. State Employees'
Retirement Board {Penn State), the Supreme Court of
Pennsylvania dismissed the appellants' argument that a person's
right to privacy should bar the disclosure of certain
information.'^
The court stated that the Right-to-Know Act protects "the
' 65 P A . C O N S . S T A T . § 702(a). The Sunshine Act goes
on to "declare[] it to
be the public policy of this Commonwealth to insure the right of
its citizens to
have notice of and the right to attend all meetings of agencies at
which any
agency business is discussed or acted upon." Id. § 702(b).
' A public record is defined as:
Any account, voucher or contract dealing with the receipt or
disbursement of
funds by an agency or its acquisition, use or disposal of services
or of
supplies, materials, equipment or other property and any
minute, order or
decision by an agency fixing the personal or property rights,
privileges,
immunities, duties or obligations of any person or group of
persons:
Provided, That the term "public records" shall not mean any
report,
communication or other paper, the publication of which would
disclose the
institution, progress or result of an investigation undertaken by
an agency in
the performance of its official duties, except those reports filed
by agencies
pertaining to safety and health in industrial plants; it shall not
6. include any
record, document, material, exhibit, pleading, report,
memorandum or other
paper, access to or the publication of which is prohibited,
restricted or
forbidden by statute law or order or decree of court, or which
would operate
to the prejudice or impairment of a person's reputation or
personal security, or
which would result in the loss by the Commonwealth or any of
its political
subdivisions or commissions or State or municipal authorities of
Federal
funds, excepting therefrom however the record of any
conviction for any
criminal act.
65 PA. STAT. ANN. § 66.1(2) (West 2000), repealed by Right-
to-Know Law, 65
PA. STAT. ANN. § 67.102 (West Supp. 2009).
'° Id. § 66.2, repealed by Right-to-Know Law, 65 PA. STAT.
ANN. § 67.102
(West Supp. 2009).
" Times Publ'g Co. v. Michel, 633 A.2d 1233, 1237-38 (Pa.
Commw. Ct.
1993).
'' Penn State, 935 A.2d at 538.
580 WiDENER LAW JOURNAL [Vol. 19
individual's right to privacy by excluding from the defmition of
7. 'public record' 'any record . . . which would operate to the
prejudice
or impairment of a person's reputation or personal security.' "'^
Courts have historically interpreted this exclusion from the
definition as the creation of an exception to the disclosure rule
of
the Right-to-Know Act.''* Pennsylvania courts have now
embarked
on the path to determine just what qualifies under this exception
and what it means to the overall disclosure of public records.
In Sapp Rooflng Co. v. Sheet Metal Workers' International
Ass'n, Local Union No. 12, the Supreme Court of Pennsylvania
examined whether payroll records of a private contractor, which
were turned over to a school board while performing work for
the
district, would be considered public records and, if they were,
whether the information contained within those records would
qualify under the security exception.'^ "The records . . .
contain[ed] the names . . . addresses . . . social security
numbers,
job positions, rates of pay and hours worked" of the Sapp
employees working for the school board.'^ The court held that
the
payroll records qualified as public records "because they . . .
evidence [d] a disbursement [of public funds] by the school
district."'^ The court reasoned that even though the records
would
not be public records if held solely by Sapp Roofing Co., the
records became part of the public record when they were turned
over to the school board, because the records were instrumental
in
the relationship between Sapp Roofing and the school board.'^
The court found that the asserted public interest in the
requested information, the enforcement of the Prevailing Wage
8. Act, was unpersuasive.'^ The court believed that the public
interest
'̂ Penn State, 935 A.2d at 538 (quoting 65 PA. STAT. ANN. §
66.1(2)).
'" Id. (citing Goppelt v. City of Phila. Revenue Dep't, 841 A.2d
599, 603-
04 (Pa. Commw. Ct. 2004)).
'̂ Sapp Roofing Co. v. Sheet Metal Workers' Int'l Ass'n, Local
Union No.
12, 713 A.2d 627, 628 (Pa. 1998). The payroll records had to be
turned over to
the school board so that the board could comply with the
Prevailing Wage Act.
Id. (citing Prevailing Wage Act, 43 PA. STAT. ANN. §§ 165-1
to -17 (West
2009)).
"Id
''^ Id ai 629.
"Id
'^ Id at 630.
2010] PENNSYLVANIA ADMINISTRATIVE LAW 5 81
in the information would do little to help enforce the Prevailing
Wage Act.'̂ *' The court used a balancing test between "the
public
interest in disclosure of the information . . . [and] the
individual's
right to privacy and personal security."^' In this particular case,
there was little evidence to show that the public had much of an
9. interest in the disclosure of the information; therefore, the only
information that the court allowed to be disclosed was the
payroll
information, not the personal identification and security
information.^^
In Penn State, the Supreme Court of Pennsylvania dealt with a
request for the release of information about various
Pennsylvania
State University employees, including the famed football coach
and professor Joe Patemo.^^ The information was held by the
State
Employees' Retirement System (SERS), the state agency that
manages the retirement benefits of state employees.̂ "* While
the
University itself was not subject to full public record disclosure
requirements under the Right-to-Know Law,̂ ^ when its
employees
choose to take advantage of the state retirement system their
information becomes part of SERS records, which are subject to
disclosure under the Right-to-Know Law.̂ ^ The court held that
the
public had an interest in the information, which includes
"names,
service history and salaries," so far as the information was
"necessary to justify all guaranteed disbursements from the
fund."^^ Salary information was allowed because it "is not so
personal and inextricably linked to a person's identity as to
threaten
one's personal security."^^ The court went on to specify that its
Sapp Roofing Co., 713 A.2d at 630.
" Pa. State Univ. v. State Employees' Ret. Bd. {Penn State), 935
A.2d 530,
532 (Pa. 2007).
10. "^ Id at 532-33 (citing 71 PA. CONS. STAT. § 5102 (2006)).
" Id. at 533 (citations omitted). But see 65 PA. STAT. ANN. §§
67.1501 -
.1503 (West Supp. 2009). "State related" schools, such as
Pennsylvania State
University, are now subject to limited disclosure requirements
under the Right-
to-Know Law. Id §§ 67.1501-.1503.
'^ Penn State, 935 A.2d at 533.
" Id at 534.
'' Id. (quoting Pa. State Univ. v. State Employees' Ret. Bd., 880
A.2d 757,
767 (Pa. Commw. Ct. 2005)).
582 WiDENER LAW JOURNAL [Vol. 19
holding did not include "information pertinent to an individual's
personal security such as addresses, telephone numbers, or
social
security numbers."^^
The Supreme Court of Pennsylvania emphasized that the
definition of a public record should be "broadly construed" and
that the meaning of "account" in the public record definition
extends to anything that bears a close connection to any
statutory
category included in the defmition of public record.^° The court
also emphasized the fact that University employees avail
themselves of the services offered by SERS, and therefore it is
necessary for SERS to maintain proper records of the
11. relationship
between itself and University employees.'" The University tried
to
claim that the records were not considered public records
because
they were not "created by a public agency," but the court
deemed
this argument immaterial.^^
In order for information to be disclosed it must be considered
relevant to the public interest asserted, which may vary based
on
the type of information requested.''^ While names, service
records,
and salaries might be considered relevant to the public's interest
in
ensuring that SERS performs properly, "one's social security
number, telephone number or . . . address" is hardly relevant. '̂*
The
court again applied " 'a balancing test, weighing privacy
interests
and the extent to which they may be invaded, against the public
benefit which would result from disclosure.' "̂ ^ An "
'intrinsically
harmful' analysis" would offer an alternative for determining
whether the information should be disclosed or withheld.
However, the court stated that, while the intrinsically harmful
''^ Penn State, 935 A.2d at 534.
^̂ Id. (citing La Valle v. Office of Gen. Counsel, 737 A.2d 330,
332 (Pa.
Commw. Ct. 1999)).
'' Id at 535.
^' Id. (citing Tribune-Review Publ'g Co. v. Dep't of Cmty. &
Econ. Dev.,
12. 859 A.2d 1261 (Pa. 2004)).
" Id at 539.
'Ud
'^ Penn State, 935 A.2d at 541 (quoting Times Publ'g Co. v.
Michel, 633
A.2d 1233, 1239 (Pa. Commw. Ct. 1993)).
^̂ Id. (quoting Moak v. Phila. Newspapers, Inc., 336 A.2d 920
(Pa.
Commw. Ct. 1975), abrogated by Penn State, 935 A.2d 530).
2010] PENNSYLVANIA ADMINISTRATIVE LAW 583
nature of the disclosure may be considered in the balancing test,
it
"may not be regarded as the sole determining factor."''^
III. ANALYSIS
In Tribune-Review Publishing Co., the Supreme Court of
Pennsylvania held, after applying a balancing test, "that . . .
telephone numbers must be redacted from the telephone bills
prior
to public disclosure of those bills under the Right-to-Know
Act."^^
This case stemmed from a request made by "[t]he Tribune-
Review
Publishing Company and Andrew Conte, a journalist [for the
publication]," to acquire "itemized billing records for cellular
telephones" purchased with taxpayer funds.''̂ The phones were
"purchased by the City of Pittsburgh . . . and issued to City
Council
13. members Leonard Bodack and Barbara Bums."''^ The
information
sought by the appellants included "the telephone numbers of
both
incoming calls to and outgoing calls from each phone, the time
of
each call, and the duration and cost of each call" between
January
1, 2002, and August 1, 2003, as well as a record of "which calls
were personal calls for which the council members had
reimbursed
the City.""'
The city denied the request, claiming that:
(1) the records were excludable under the Right-to-Know Act
because they contained private telephone numbers, which, if
revealed, could potentially result in danger to the owners of the
telephone numbers and/or danger that persons would be
reluctant to contact the City regarding local problems; and (2)
such bills were not, in general, public records subject to the
Right-to-Know Act because the council members had
reimbursed the City for their cellular telephone '̂
After the city issued its denial, the appellants appealed to the
Court of Common Pleas of Allegheny County, which ordered
the
" Penn State, 935 A.2d at 541.
^' Tribune-Review Publ'g Co. v. Bodack, 961 A.2d 110, 118
(Pa. 2008).
^ ' M at 111-12.
""W. at 112.
"Id
14. 584 WiDENER LAW JOURNAL [Vol.19
information to be released.'*^ The appellees, in turn, appealed
the
order to release the information to the Commonwealth Court of
Pennsylvania.'*'* The commonwealth court reversed, holding
"that
the telephone bills did not fall within the defmition of 'public
record.' "'^
The Commonwealth Court of Pennsylvania found that the
telephone bills fell under the defmition of public record because
the bills were considered " 'account[s or] voucher[s] . . . dealing
with the receipt or disbursement of funds by an agency.' . . .
However, [the court found that] the disclosure of [the bills] . . .
could compromise the privacy" of those individuals whose
telephone numbers appeared on the bills."*^ The court really
prohibited the disclosure of the bills with the telephone numbers
on
them, not necessarily the disclosure of the cellular telephone
bills
in some alternative form."*̂
When reviewing the commonwealth court's decision on
appeal, the Supreme Court of Pennsylvania focused on two main
issues."*^ First, do "itemized cellular telephone bills" fall under
the
defmition of a public record? and second, "[d]o the personal
security and privacy exceptions in the Right-to-Know Act create
legal defenses to access that need not be supported with
substantial
evidence?"'*^ The court emphasized that the defmition of public
record is broadly construed, putting heavy meaning on the word
"̂ Tribune-Review Publ'g Co., 961 A.2d at 112 (citing 65 PA.
15. STAT. ANN.
§ 66.4(b) (West 2000), repealed by Right-to-Know Law, 65 PA.
STAT. ANN.
§§ 67.301-.304 (West Supp. 2009) (containing the former
appeals procedure)).
""Id
"*' Id. (citing 65 PA. STAT. ANN. § 66.1, repealed by Right-to-
Know Law,
65 PA. STAT. ANN. § 67.102 (West Supp. 2009)).
"̂ Id. at 112-13 (quoting 65 PA. STAT. ANN. § 66.1, repealed
by Right-to-
Know Law, 65 PA. STAT. ANN. §67.102 (West Supp. 2009))
(discussing
Tribune-Review Publ'g Co. v. Bodack, 875 A.2d 402, 407-08
(Pa. Commw. Ct.
2005)).
"' Id at 113 (discussing Bodack, 875 A.2d at 407-08).
"^/i/. at 114.
•*' Tribune-Review Publ'g Co., 961 A.2d at 114. The court was
very
specific when it stated "cellular telephone" because the
commonwealth court
drew a distinction between traditional telephones and cellular
phone in its
rationale. Id. at 113 (quoting Bodack, 875 A.2d at 407). This
aspect of the
opinion is discussed later in part III. See infra pt. IIL
2010] PENNSYLVANIA ADMINISTRATIVE LAW 585
16. "any."^° Additionally, the word "account," within the definition
of
public record, " 'is to be broadly construed for the benefit of the
public, encompassing, at minimum, the [agency's] financial
records of debit and credit entries, as well as monetary receipts
and
disbursements.' " '̂ When looking at the definition of a public
record broadly, the supreme court found that the commonwealth
court correctly determined that, "in general terms," the cellular
telephone bills are considered a public record.^^
The court also held that the lower court correctly recognized
that the public record definition contains some exceptions for
records which, if disclosed, " 'would operate to prejudice or
impair[] . . . a person's reputation.' "̂ ^ Traditionally,
" 'Pennsylvania courts have interpreted this reputation and
personal
security exception as creating a privacy exception to the [Right-
to-
Know Act's] general disclosure rule.' "^"^ The court found that,
in
order "to determine whether the privacy exception should"
apply to
records, the questions to be examined were " 'whether the
records
requested would potentially impair the reputation or personal
security of another, and whether that potential impairment
outweighs the public interest in the dissemination of the records
at
issue.' " ^ These two questions essentially create a balancing
test
between the personal security interest in preventing the
disclosure
of information and the public interest in knowing the
information.
17. The party asserting that the information falls under the
definition of a public record has the burden of proof ^̂
However, if
^' Tribune-Review Publ'g Co., 961 A.2d at 114 (emphasis
omitted) (citing
Pa. State Univ. v. State Employees' Ret. Bd. {Penn State), 935
A.2d 530, 533
(Pa. 2007)).
' ' Id. at 114 (quoting Penn State, 935 A.2d at 534).
'^ Id. The city tried to claim that, since the agency was
reimbursed for the
private phone calls, the records were no longer part of the
public record. Id.
However, the court determined that this "does not change the
fact that" at some
point public funds were disbursed to pay the bills, which makes
them part of the
public record. Id. at 114-15.
" Id. at 115 (quoting 65 PA. STAT. ANN. § 66.1 (West 2000),
repealed by
Right-to-Know Law, 65 PA. STAT. ANN. § 67.102 (West Supp.
2009)).
^̂ Id. (quoting Penn State, 935 A.2d at 538).
" Id. (emphasis omitted) (quoting Penn State, 935 A.2d at 538).
'* Tribune-Review Publ'g Co., 961 A.2d at 115 (citing
Uniontown
Newspapers, Inc. v. Roberts, 839 A.2d 185, 189 n.l (Pa. 2003);
Tribune-Review
18. 586 WiDENER LAW JOURNAL [Vol. 19
the burden is met, the party attempting to withhold the
information
has the burden of proving it meets an exception.^^ In this
particular
case, the appellants claimed they met their burden of proving
that
the information was a public record but that the appellees failed
to
meet their burden.^^ The court disagreed with the appellants'
argument that evidence of specific security and privacy concems
had to be presented in order for an exception to apply, stating
that
"we have never held that the requisite balancing test is utilized
only after the agency has established, through particular and
item-
specific evidence, that the challenged information in an
otherwise
public record defmitively meets one of the exceptions set forth"
in
section 66.1 of the Pennsylvania Public Officers Code.^^
The court went on to explain former precedent:
[I]f anything, our case law has recognized that there are certain
types of infonnation whose disclosure, by their very nature,
would operate to the prejudice or impairment of a person's
privacy, reputation, or personal security, and thus intrinsically
possess a palpable weight that can be balanced by a court
against those competing factors that favor disclosure.*"
The court looked to previous rulings involving similar
information and found that, historically, the court has stated
19. that
the very nature of such information may result "in a threat to [a
person's] privacy, reputation, or personal security" if
disclosed.^'
The lower court emphasized the fact that the bills were for
cellular telephones rather than traditional telephones.^^ While
at
Publ'g Co. V. Westmoreland County Hous. Auth., 833 A.2d 112,
115 (Pa.
2003)).
" Id. (citing Uniontown Newspapers, Inc., 839 A.2d at 189 n . l
;
Westmoreland County Hous. Auth., 833 A.2d at 115).
^' Id. The appellants claimed that the appellees did not show
that any
person whose number appeared on the bills would suffer harm
by the disclosure
of the bills except for one person who called Bodack to
complain about potential
drug trafficking. Id.
^' Id. (citing 65 PA. STAT. ANN. § 66.1 (West 2000), repealed
by Right-to-
Know Law, 65 PA. STAT. ANN. § 67.102 (West Supp. 2009)).
''" Id. at 115-16 (emphasis omitted).
^'W. at 117.
^' Tribune-Review Publ'g Co., 961 A.2d at 113 (quoting
Tribune-Review
Publ'g Co. V. Bodack, 875 A.2d 402, 407 (Pa. Commw. Ct.
20. 2005)).
2010] PENNSYLVANIA ADMINISTRATIVE LAW 587
first this distinction might seem minimal, the lower court noted
that on traditional telephone bills only the telephone numbers of
the people called appear on the caller's bill because the person
being called is not charged for receiving the phone call.̂ ^
However, because of the nature of cellular telephones, people
pay
for airtime when they call someone and when someone calls
them;
therefore, both incoming and outgoing telephone numbers
appear
on the bill.̂ '* An unknowing public citizen may not realize that
he
or she has placed a call to a cellular phone and, therefore,
unwittingly disclosed his or her private telephone number in a
public record.^^
The court also examined the lower court's reasoning that a
person's reputation could be harmed by disclosure of these
records.^^ A public official could easily misdial, reaching a
person
whose reputation would be harmed by any connection to that
official.^^ The lower court reasoned that it was not enough to
just
weigh the benefit of the information being disclosed, but that
the
rights of innocent private citizens needed to be considered as
well.^^ Additionally, there are security interests to be
considered
for those vigilant private citizens who call public officials to
report
21. various concerns, including concerns about possible drug
trafficking (as was the case for one of the phone numbers on the
bills in question).^^
" Tribune-Review Publ'g Co., 961 A.2d at 113 (quoting Bodack,
875 A.2d
at 407).
*" Id. (quoting Bodack, 875 A.2d at 407).
" Id. (quoting Bodack, 875 A.2d at 407). The court stated that
the
reasoning of Times Publishing Co. v. Michel applied in this
case as well, and
explained that " 'private citizens have a legitimate and
reasonable expectation
that their phone numbers will remain private and that disclosure
of these
numbers would constitute an unwarranted invasion of personal
privacy
outweighing any public benefit.' " Id. (quoting Bodack, 875
A.2d at 407) (citing
Times Publ'g Co. v. Michel, 633 A.2d 1233 (Pa. Commw. Ct.
1993)).
^̂ Id (citing Bodack, 875 A.2d at 407).
^̂ Id. The court reasoned, "[s]uch damage can be measured only
by the
interpretation placed on the release of that information and its
perceived
connection to the political, business, marital, competitive or
other interests of the
person receiving the call." Id. (quoting Bodack, 875 A.2d at
407).
22. ^' Id at 113-14 (quoting Bodack, 875 A.2d at 407-08).
*' See Tribune-Review Publ'g Co., 961 A.2d at 114-15 (citing
Bodack, 875
A.2d at 408).
588 WiDENER LAW JOURNAL [Vol. 19
Following previous rulings, the court found that the lower
court properly balanced the test of personal security interests
and
the public's right to the information.^^ The court found that, in
order to satisfy both interests, the cellular telephone bills
should be
released, but only after the telephone numbers have been
redacted.^' The court stated that "the telephone numbers must
be
redacted" prior to being released to the public under the Right-
to-
Know Act because there is a "patently strong . . . interest" in
not
disclosing the phone numbers on the cellular telephone bills and
a
"weak, perhaps non-existent public interest."
IV. EVALUATION
The Tribune-Review Publishing Co. case falls in line with
Pennsylvania law. It properly follows precedent while further
refining what information actually falls within the exception.^''
Additionally, the case appropriately deals with how to handle
disclosure of records containing information that falls within
the
public records exception. '̂* Penn State and Sapp Roofing Co.
23. established the test: there must be a balancing of the public
interest
in the disclosure of information and the individual right to
privacy
in one's personal identification and security information.^^ This
test
is applied in order to establish whether the information sought
falls
within the public records exception.^ The court in Tribune-
Review
Publishing Co. followed that test exactly by weighing the strong
™ Tribune-Review Publ'g Co., 961 A.2d at 114-15. See
generally Pa. State
Univ. V. State Employees' Ret. Bd. {Penn State), 935 A.2d 530
(Pa. 2007)
(holding that while the public had a right to know the salaries of
state
employees, that right did not extend to personal information
such as addresses,
telephone numbers, and social security numbers); Sapp Roofing
Co. v. Sheet
Metal Workers' Int'l Ass'n, Local Union No. 12, 713 A.2d 627
(Pa. 1998)
(dealing with the disclosure of payroll information, including
telephone
numbers).
'" Tribune-Review Publ'g Co., 961 A.2d at 117.
^Vi/. at 117-18.
" See generally Penn State, 935 A.2d at 541; Sapp Rooftng Co.,
713 A.2d
at 630.
'•* See Tribune-Review Publ'g Co., 961 A.2d at 113-18.
" Penn State, 935 A.2d at 541 ; Sapp Rooftng Co., 713 A.2d at
24. 630.
'^ Penn State, 935 A.2d at 541 ; Sapp Rooftng Co., 713 A.2d at
630.
2010] PENNSYLVANIA ADMINISTRATIVE LAW 589
public interest in the disclosure of information related to how a
public agency spends its funds and the strong private interest in
maintaining the privacy of telephone numbers. ^ The court also
refined the scope of the test by applying it specifically to the
public
interest in the disclosure of telephone numbers on cellular
telephone bills and by acknowledging the possible prejudice or
harm to the private interest in protecting the information.^
The court reached the proper conclusion by basically applying
the test to the records as a whole and then again to the personal
identification and security information.^^ The cellular
telephone
bills are public records and, as such, should be released;
however,
since the public interest in the actual numbers is weaker than
the
privacy interest in the numbers, the numbers must first be
redacted.̂ *' The court's decision strikes the proper balance
between
transparency and privacy.
The court in Tribune-Review Publishing Co. did seem to put
more weight in the idea that some information can be
"intrinsically
harmful" than it seems the court did in Penn State}^ In Penn
State,
the court concluded that an intrinsically harmfiil analysis alone
25. can
not determine if the information meets the public records
exception. However, in Tribune-Review Publishing Co., the
court
determined that there are certain types of infonnation which—if
disclosed—could lead to potential prejudice and harm to
personal
identification and security information because of its very
nature.^^
While not overruling the holding in Penn State, the court in
Tribune-Review Publishing Co. seemed to definitely give more
credence to the idea that some information, no matter what,
possesses the potential to be harmful to the private citizen if
released. '̂*
" Tribune-Review Publ'g Co., 961 A.2d at 117-18.
''Id
"See id
*Vi/. at 118.
^'See/i^. at 117-18.
" Penn State, 935 A.2d at 541 ("Intrinsic harmfulness . . . may
not be
regarded as the sole determining factor in the privacy
analysis.") (citing Moak v.
Phila. Newspapers, Inc., 336 A.2d 920, abrogated by Penn State,
935 A.2d 530).
^̂ Tribune-Review Publ'g Co., 961 A.2d at 117.
''See id
590 WiDENER LAW JOURNAL [Vol.19
In Penn State, the court made a point of the fact that
26. University employees' information became property of that
agency
because they received a benefit from SERS and, therefore, their
information became part of the public record. The argument
could be made, in the case of Tribune-Review Publishing Co.,
that
those who called their city council member received a benefit as
well and therefore their information should become part of the
public record. However, this is not a strong claim. The benefit
received by the University employees is far greater and longer-
lasting than the benefit of being able to contact a city council
member. Additionally, in Penn State, the information released
did
• ÍÍÍÍ
not contain personal identification or security information. The
University employees also chose to avail themselves of SERS
services,^^ whereas some of the numbers appearing on the
cellular
telephone records could belong to people who dialed a wrong
number or could be a wrong number dialed by a city council
member.^^ This means that citizens who had made no
purposeful
availment of their city council members' assistance would have
be
at risk of having personal identification and security
information
released.
The Pennsylvania General Assembly passed a major overhaul
of the Right-to-Know Act, which took full effect on January 1,
^̂ However, the Act is only applicable to informationapp
requests made after December 31, 2008.^ Therefore, the
precedent
27. established by Tribune-Review Publishing Co., and other cases
relating to the former version of the Right-to-Know Act, are
applicable to all cases pending based on requests made prior to
December 31, 2008. The General Assembly recognized the fact
that some information should not be released to the public
despite
being contained in public records and has established twenty-
nine
different categories of information that are exceptions to the
*' Penn State, 935 A.2d at 535.
*̂ M at 539.
^ ' M a t 533.
^̂ See Tribune-Review Publ'g Co., 961 A.2d at 113 (quoting
Tribune-
Review Publ'g Co. V. Bodack, 875 A.2d 402, 407 (Pa. Commw.
Ct. 2005)).
^' 65 PA. STAT. ANN. § 67.3104 (West Supp. 2009).
^'id §67.3101.
2010] PENNSYLVANIA ADMINISTRATIVE LAW 591
disclosure requirement.^' Included in those categories are things
like social security numbers, telephone numbers, addresses,
driver's license numbers, and e-mail addresses.^^
V. CONCLUSION
Overall, Pennsylvania courts have shown an interest in
preserving a proper balance between the public interest in a
transparent govemment and the private interest in the right to
individual privacy of one's personal identification and security
28. infonnation. The Tribune-Review Publishing Co. holding shows
that it is possible to serve both interests equally without forcing
one to compromise. In the next few years, this will continue to
be
an issue until all requests for information prior to December 31,
2008, are satisfied. It will be important that the courts continue
to
strive for the proper balance between public and private
interests.
The Pennsylvania General Assembly clearly recognized the need
for that balance by establishing a more detailed list of what
infonnation is excludable from disclosure. That list, Tribune-
Review Publishing Co., and prior case law will prove to be key
guidance to courts in the near ñiture.
Lindsay M. Schoeneberger
§ 67.708(b).
Id § 67.708(b)(6)(i)(A).
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However, users may print, download, or email articles for
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Title
ABC/123 Version X
29. 1
Week One Information Security Key Terms
SEC/440 Version 5
1
University of Phoenix Material
Week One Information Security Key Terms
This document is a comprehensive collection of important terms
that will be discussed throughout the class. You can refer to it
as you read the textbooks or complete any of the weekly
assignments.
Access controls – Controls that restrict unauthorized individuals
from using information resources and are concerned with user
identification
Accountability – A term that means a determination of who is
responsible for actions that were taken
Authentication – A process that determines the identity of the
person requiring access
Authorization – A process that determines which actions, rights,
or privileges the person has based on verified identity
Availability – The property of an information system being
accessible and usable on demand by an authorized user
Client – Host computer that receives network services from a
network server
Confidentiality – The condition when designated information is
collected for approved purposes and is not disseminated beyond
a community of authorized users
Configuration management – The management of changes made
to an information system’s hardware, software, firmware, and
documentation throughout the IS lifecycle
Contingency plan – The documented organized process for
30. implementing emergency response, back-up operations, and
post-disaster recovery of an information system
Data – An elementary description of things, events, activities,
and transactions that are recorded, classified, and stored but are
not organized to convey any specific meaning
Database – A group of logically related files that stores data and
the associations among them
E-commerce – The buying and selling of goods and services
over the Internet
E-business – A broader definition of electronic commerce,
including buying and selling of goods and services, as well as
servicing customers, collaborating with business partners,
conducting e-learning, and conducting electronic transactions
within an organization
E-government – The use of electronic commerce to deliver
information and public services to citizens, business partners,
suppliers of government entities, and those working in the
public sector
Information – Data that has been processed that is meaningful
and useful to human beings
Knowledge – Data or information that has been organized and
processed to convey understanding, experience, accumulated
learning, and expertise as applied to a current problem or
activity
Extranet – Private network that extends to authorized users
outside of the organization
Encryption – The conversion of plaintext information or data
into an unintelligible form by means of a reversible translation
based on a table or algorithm
Firewall – Allows or blocks traffic into and out of a private
network or a user's computer
Hacker – Common nickname for an unauthorized person who
breaks into or attempts to break into an information system by
circumventing software security safeguards
31. Internet – The global network that uses universal standards to
connect millions of different networks
Intranet – Internal network not accessible to the public and
protected by a firewall
Information system – Set of interrelated components that
collect, process, store, and distribute information to support
decision making and control within an organization
Information technology architecture – A high-level map or plan
of the information assets in an organization
Information technology infrastructure – The physical facilities,
IT components, IT services, and IT personnel that support an
entire organization
Identification – The process that enables recognition of an
entity by a system, generally by the use of unique machine
readable usernames
Integrity – A subgoal of computer security which ensures that
data is a proper representation of information and has not been
exposed to accidental or malicious alteration or destruction
Malicious code or virus – Programs that carry malicious
executable, virus, or worm code that intentionally cause harm
by modifying or destroying computer systems often without the
user’s knowledge
Network – A connecting system (wireline or wireless) that
permits different computers to share information or resources
Protocol – A formal set of rules governing the communication
between two network devices
Risk formula – Risk = Impact x (Threat x Vulnerability)
Risk – The probability that a particular threat will exploit a
particular vulnerability of a system
33. 2. The security concept that states every user should be
responsible for his or her own actions is called
_______.
3. The individual who is responsible for deciding on the access
rights to the information for various personnel is called an
_______.
4. Physical, technical, and administrative controls used to
protect information systems are called
_______.
5. The probability that a particular threat will exploit a
particular vulnerability of an information system is called
_______.
6. An event, process, activity, or substance that has an adverse
effect on organizational assets is called a _______.
Federal Information Security Management Act (FISMA) of 2002
Terminology Matching
Match the terminology with the correct definition by inserting
the corresponding letter in the answer column.
Terminology
Answer
Definitions
7.
Authorize
A. Information systems and internal information are grouped
based on impact.
8.
Supplement
34. B. The step where an initial set of security controls for the
information system are chosen and tailored to obtain a starting
point for required controls
9.
Monitor
C. Assess the risk and local conditions, including the security
requirements, specific threat information, and cost–benefit
analysis to increase or decrease security controls.
10.
Categorize
D. Step where the original and supplement controls are put in
writing
11.
Document
E. Original and supplement controls are applied to the system.
12.
Select
F. Security controls are evaluated to see if they are implemented
correctly and are operating as intended.
13.
Assess
G. Evaluation of risk to organizational operations,
organizational assets, or individuals that leads to this action
14.
Implement
H. Requires checking and assessing the selected security
controls in the information system on a continuous basis
15.
In 300- to 400-words, explain why security professionals must