1 April 15, 2024
To: City of Stockton – Public Records Request
From: Moss Adams, LLP
Subject: Public Records Request Benchmarking
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Background
The California Public Records Act (PRA) was originally enacted in 1968 to: 1) safeguard the accountability of government to the public; 2) promote maximum disclosure of the conduct of governmental operations; and 3) explicitly acknowledge the principal that secrecy is antithetical to a democratic system of government. The PRA states that “access to information concerning the conduct of the people’s business is a fundamental and necessary right of every person in this state.”
1 The City of Stockton (the City) requested its internal auditor, Moss Adams, conduct a Public Records Request procedure review including a compilation of how other cities organize and operationalize their public records requests. The review is intended to assist the City in improving its structure and procedures surrounding their public records request. The purpose of this memo is to provide a summary of the analysis of the City’s alignment with peers related to public records requests.
Peer Comparison
The City’s approach to public records requests was compared to five peer cities that were identified by Moss Adams and reviewed for relevance by City management: Sacramento, Tracy, Bakersfield, Manteca and Modesto. The analysis compared the City with peers in the areas listed in the following table.
TOPIC STOCKTON PEER ANALYSIS SUMMARY
What department leads public
records request responses?
The Community Relations Officer within the City
Manager’s Office coordinates public records
requests.
In all five benchmarked cities, the City Clerk
manages PRA requests. In three peer cities, the City
Clerk is an appointed official that reports into the
City Manager’s Office.
How many employees are
dedicated to responding to
public records requests?
One employee, the Community Relations Office,
coordinates responses to requests and individual
departments are responsible for searching and
providing responsive records
In three peer cities, a Deputy City Clerk oversees
triaging requests. In two peer cities, the City Clerk’s Office is sometimes able to fulfill requests
1 Gov. Code, § 7921.000 (formerly Gov. Code, § 6250)
2 TOPIC STOCKTON PEER ANALYSIS SUMMARY
independent of departments and has between 2 to 6
FTE dedicated to this function.
How many PRA requests are
received per year?
480 requests in calendar year 2023. The number of requests varied between 450 and 5,000 requests in calendar year 2023. In interviews,
peers noted an increase in the number of requests
when a system was implemented due to customer
ease.
Do public safety departments
have their own public records
request process?
Yes Four peer cities separate police and fire department requests and those departments own their requests
using their own instance of the electronic request
system.
The police department in one peer city does not
have its own instance of the electronic request
system and must forward requests to the City
Clerk’s office for upload.
How are requests received? Requests can be received in any format including Ask Stockton, email, in-person, and phone call.
All five of the peer cities use some form of request
system to organize and triage requests. Next
Request or justFOIA. If requests are received
outside of those systems, the city clerk’s office is
entering those into the system and using the system
to track.
Does the City use a system to
track and respond to requests?
No, requests and responses are tracked manually. All five peer cities use an electronic system to manage requests; four peer cities use NextRequest
and one peer uses justFOIA.
How are requests fulfilled? The Community Relations Officer sends requests to the appropriate departmental personnel. Some
larger departments, such as Public Works, have a
dedicated records requests liaison.
In four peer cities, requests are sent to designated
person(s) in the department(s) to which the request
pertains. The designated person tis responsible for
retrieving any responsive records within the
appropriate timeframe. Only one city is able to fulfill requests within the City Clerk’s Office.
Are responsive records
reviewed by the City Attorney’s
Office?
Responsive records are reviewed by the City
Attorney’s Office on a case-by-case basis for
sensitive matters.
In four peer cities, responses to requests are
reviewed by the City Attorney’s office on a case-by-
case basis and only if needed. One peer city has the
City Attorney’s office review the response to every
request.
Are fulfilled requests made
public?
No, responses to PRA requests are not made
public.
Four of the five peer cities publish responses to PRA
requests on their website.
3 TOPIC STOCKTON PEER ANALYSIS SUMMARY
Does the city have a Public
Records Request manual or
written policy?
Stockton has a process flow chart that describes the
public records process.
Only one peer city had a manual for public records
request that included the process for requests and
any FAQs. Peer cities had templates and workflows
built into their electronic request system.
4 Appendix: Peer City Results
Sacramento Tracy Bakersfield Modesto Manteca
What department
leads public records
request responses?
City Clerk; appointed City Clerk; appointed
but reports into the City
Manager’s Office
City Clerk; appointed
but reports into the City
Manager’s Office
City Clerk; appointed City Clerk; appointed
but reports into the City
Manager’s Office
How many
employees are
dedicated to
responding to
public records
requests?
Sacramento employs
four deputy city clerks
and one analyst to
handle the public
records requests in
addition to the City
Clerk. All of these
employees (6 FTE) are
dedicated to fulfilling
records requests.
The City Clerk and a
Deputy City Clerk
manage the intake,
triage, and completion
of records requests.
Every department has a
designated liaison that
responds to requests.
The Deputy City Clerk
oversees triaging
requests to each
specific department.
Every department has a
designated liaison that
responds to requests.
The Deputy City Clerk
oversees triaging
requests to each
specific department.
Every department has a
designated team (4-5
people) to research and
respond to requests.
The Deputy City Clerk
oversees triaging
requests to each
specific department.
Every department has
at least 1 designated
liaison that responds to
requests.
How many PRA
requests are
received per year?
About 5,000 requests 875 requests in
calendar year 2023
2,355 requests in
calendar year 2023
823 requests in
calendar year 2023
450 requests in
calendar year 2023
Do public safety
departments have
their own public
records request
process?
Yes Yes Yes Yes No
How are requests
received?
Online portal, call,
email, in-person
Online portal, call,
email, mail, in-person
Online portal, call,
email, in-person
Online portal, call,
email, in-person
Online portal, call,
email, in-person
Does the City use a
system to track and
respond to
requests?
Yes, NextRequest Yes, NextRequest and
Laserfische
Yes, justFOIA NextRequest NextRequest
How are requests
fulfilled?
The City Clerk’s Office
has access to many
records and can often
fulfill requests
independently. In some
cases, the request is
sent to a department to
retrieve responsive
records.
The City’s Clerk’s office
has access to many
records in Laserfische.
Each department has a
designated liaison that
is responsible for
retrieving responsive
records.
Each department has a
designated liaison that
is responsible for
retrieving responsive
records.
Each department has a
designated team that is
responsible for
retrieving responsive
records.
Each department has at
least 1 designated
liaison that is
responsible for
retrieving responsive
records.
Are responsive
records received by
Some requests go to
the City Attorney for
The City Clerk’s office is
in frequent
Deputy City Clerk works
with City Attorney for
City Attorney reviews all
requests. If it’s sensitive
The City Attorney will
review requests in
5 the City Attorney’s
Office?
review on a case-by-
case basis. If it involves
employee records,
emails, or anything
confidential, the City
Attorney will review after
redactions are made by
the City Clerk’s office.
communication with the
City Attorney’s office but
each request does not
necessarily go to the
City Attorney for review.
City Attorney reviews all
confidential requests or
employee
investigations.
sensitive requests and
sends legal a hard copy
for review and advice.
information (employee
records/emails) it goes
directly to risk
management and HR to
fulfill and manage.
City Attorney’s office
also reviews templates
within the automated
system annually to
ensure compliance with
PRA.
regards to
communication, police
department, and other
sensitive matters on a
case-by-case basis.
Are fulfilled
requests made
public?
Yes Yes No Generally yes, although
there may be some
exceptions
Generally yes, although
there may be some
exceptions
Does the City have
PRA policies and
procedures?
No, workflows and
templates are built into
the system
No, workflows and
templates are built into
the system
Yes, the City has a
manual
No, workflows and
templates are built into
the system
No, workflows and
templates are built into
the system