January 2017 Email Metadata (Information Technology, Rhode Island)

Matt Chapman - Free Our Info, NFP filed this request with the Information Technology, Rhode Island of Providence, RI.
Due Aug. 3, 2018
Est. Completion None
Status
Awaiting Response

Communications

From: Matt Chapman - Free Our Info, NFP

To Whom It May Concern:

Pursuant to the Rhode Island Access to Public Records Act, I hereby request the following records:

For all accounts managed by your department, please provide me the following information for all emails sent during January, 2017:

1. From address
2. To address
3. bcc addresses
4. cc addresses
5. Time
6. Date

Please note that I am not requesting the contents of each email.

I am more than happy to provide documentation or tips for extracting this information from your mail server if needed. Documentation that I have available include methods using excel, powershell, msaccess, Office 365 eDiscovery tools, and the direct extraction from an exchange database using forensic analysis tools.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.

Sincerely,

Matt Chapman

From: Information Technology, Rhode Island

The Access to Public Records Act ("APRA"), R.I.G.L. § 38-2-1 et seq., pertains to requests for documents. Your request seeks information relative to a non-document inquiry. Specifically, your request seeks "the following information for all emails sent during January, 2017..."

Assuming your request seeks documents that reflect the information requested, the City of Providence does not maintain documents responsive to this request.

Please be advised that pursuant to R.I. Gen. Laws § 38-2-3(h), the City is not required to "reorganize, consolidate, or compile data" if the data is not maintained in an electronic format, or if doing so would unduly burden the City. In this instance, the City does not possess any documents responsive to your request, and creating a document by reorganizing, consolidating, or compiling data, would be an undue burden.

In accordance with R.I. Gen. Laws § 38-2-8, you may wish to appeal this decision to the Chief Administrative Officer. In this instance, Jim Silveria, Director of Information Technology, fulfills that role. You may also wish to file a complaint with the Department of the Attorney General or the Rhode Island Superior Court.

From: Information Technology, Rhode Island

Your first record request 18-573 has been opened.

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City of Providence Public Records (https://click.pstmrk.it/2sm/providenceri.nextrequest.com/g2ZtyQE/DbEk/4RDdyQtNlV/cmVxdWVzdGVyX3JlcXVlc3Rfb3BlbmVk)


Your first City of Providence record request (request number 18-573) has been submitted. It is currently unpublished and is not available for the general public to view.
You will receive a response within ten (10) business days.  Your request will be available for the public to view thirty (30) days after you receive a final response.


As the requester, you can always see the status of your request by signing into the City of Providence Public Records portal here. If you haven't already activated your account, (https://click.pstmrk.it/2m/providenceri.nextrequest.com%2Fusers%2Fsign_in/hGZtyQE/DbEk/hS2SMwKmrh/cmVxdWVzdGVyX3JlcXVlc3Rfb3BlbmVk) click here to get started. Once your account is activated, your request will be visible at the following link: (https://click.pstmrk.it/2m/providenceri.nextrequest.com%2Fsign_in_help/hWZtyQE/DbEk/QAUWjn38JR/cmVxdWVzdGVyX3JlcXVlc3Rfb3BlbmVk) Request 18-573. (https://click.pstmrk.it/2m/providenceri.nextrequest.com%2Frequests%2F18-573/hmZtyQE/DbEk/WV8ayTgbxA/cmVxdWVzdGVyX3JlcXVlc3Rfb3BlbmVk)



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From: Information Technology, Rhode Island

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From: Information Technology, Rhode Island

Your City of Providence public records request 18-573 has been closed.

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Record request #18-573 has been closed. The closure reason supplied was:



View Request #18-573 (https://click.pstmrk.it/2m/providenceri.nextrequest.com%2Frequests%2F18-573/bkB0yQE/DbEk/tkU1JE8wXA/cmVxdWVzdGVyX3JlcXVlc3RfY2xvc2Vk)

Too many emails? (https://click.pstmrk.it/2sm/providenceri.nextrequest.com%2Fsettings/b0B0yQE/DbEk/kpqb5YdzV6/cmVxdWVzdGVyX3JlcXVlc3RfY2xvc2Vk) Change your email settings here Trouble with the request button? Copy the URL below into your web browser:
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From: Information Technology, Rhode Island

Dear Mr. Chapman,

It was shared with me that you submitted the attached "public records request" via fax to "Information Technology" at 444 Westminster Street.

As you may or may not know, the Access to Public Records Act (the "APRA") requires each public body to develop written procedures regarding access to public records. See R.I. Gen. Laws § 38-2-3(d). The City of Providence has published these procedures on its website: http://www.providenceri.gov/law-department/public-records-request/. The Attorney General for the City of Providence has opined that requests not made through the processes established by a public body do not constitute a request for public records under the APRA. See DeWolf v. Town of Coventry, 2017 WL 2342547 (R.I.A.G.).

As such, by faxing your request to "Information Technology" your request was not submitted pursuant to the APRA - and the City is therefore not obligated by statute to provide a response.

However, as a courtesy, your request was input into our NextRequest portal and all responses, will be facilitated through that portal, directed to the email provided. This request is #18-573. Your organization, MuckRock News, has made use of our portal in the past, and I would encourage you to do the same moving forward.

Please feel free to contact me if you have any questions about the City's Procedure for Public Records.

Thank you.

[Signature]

From: Information Technology, Rhode Island

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Public
The Access to Public Records Act ("APRA"), R.I.G.L. § 38-2-1 et seq., pertains to requests for documents. Your request seeks information relative to a non-document inquiry. Specifically, your request seeks "the following information for all emails sent during January, 2017..."

Assuming your request seeks documents that reflect the information requested, the City of Providence does not maintain documents responsive to this request.

Please be advised that pursuant to R.I. Gen. Laws § 38-2-3(h), the City is not required to "reorganize, consolidate, or compile data" if the data is not maintained in an electronic format, or if doing so would unduly burden the City. In this instance, the City does not possess any documents responsive to your request, and creating a document by reorganizing, consolidating, or compiling data, would be an undue burden.

In accordance with R.I. Gen. Laws § 38-2-8, you may wish to appeal this decision to the Chief Administrative Officer. In this instance, Jim Silveria, Director of Information Technology, fulfills that role. You may also wish to file a complaint with the Department of the Attorney General or the Rhode Island Superior Court.

July 5, 2018, 1:35pm

From: Matt Chapman - Free Our Info, NFP

"In accordance with R.I. Gen. Laws § 38-2-8, you may wish to appeal this decision to the Chief Administrative Officer. In this instance, Jim Silveria, Director of Information Technology, fulfills that role. You may also wish to file a complaint with the Department of the Attorney General or the Rhode Island Superior Court."

In your response, you claim that the city does not possess any documents responsive to my request, though the compilation of the data would be an undue burden. I do not believe that this would be the case for a department with sufficient technical skills, ie the the the IT department. There are many ways to extract this information from mail servers whose efforts would not require undue burden. Please also bear in mind that at a systems level (eg, the exchange database), the information respondent to my request is stored identically to the contents of an email. In other words, an exchange database stores an email body as a discrete field in the same way that it stores an email's metadata in a series of discrete fields.

As I stated in my original request, I am more than happy to provide technical documentation to extract the information respondent to my request. Please let me know if you would like to view this documentation.

Thank you and regards,
Matt Chapman
Free Our Info, NFP

From: Information Technology, Rhode Island

Hello Matt Chapman!

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From: Information Technology, Rhode Island

RE: Appeal of Request 18-573

Dear Mr. Chapman:

I am in receipt of your petition, pursuant to Rhode Island General Laws § 38-2-8, in which you seek review of the Providence Public Records Unit’s response to your July 5, 2018 request for records. Upon review of your request and the Public Records Unit’s response, I affirm the decision of the Public Records Unit (“PRU”).

Your request sought the following:

“For all accounts managed by your department, please provide me the following information for all emails sent during January, 2017:

1. From address

2. To address

3. Bcc addresses

4. Cc addresses

5. Time

6. Date”

You also note in your request that you did not request the content of each email. Further, you explain that if help is ‘needed’ in extracting the information from our server, you would be happy to help.

In response, the PRU correctly identified that the City does not maintain documents responsive to your request. Further, the PRU explained that the City of Providence is under no obligation under the Access to Public Records Act (the “APRA”) to “reorganize, consolidate, or compile data not maintained by the public body in the form requested at the time the request…was made except to the extent that such records are in an electronic format and the public body would not be unduly burdened in providing such data.” See R.I. Gen. Laws § 38-2-(3)(h).

In your appeal, you indicate that you feel that any IT department with “sufficient technical skills” would be able to accomplish the compilation of the data you seek without incurring an “undue burden.” However, as the Director of Information Technology for the City of Providence, I disagree.

Any computer code that you provide or find on the internet somewhere would need to be vetted and screened by my department before I would allow it to be used to obtain the information you seek. This is necessary to ensure both the reliability, and more importantly, the security, of running a program, developed by an outside entity, on our secure network. That analysis would, at the very least, require a line-by-line analysis of each line of the computer code. The time necessary to vet the program, in order to determine the reliability and security of the code would be comparable to the amount of time it would take for our department to draft such code from scratch. Additionally, any such code would need to be run in a development environment prior to querying our live, production, mission critical system. That effort would constitute an undue burden. See Katz v. Employees Retirement System, PR 16-32 (Where the Attorney General found that asking a public body do more than “reorganize, consolidate, or compile data” by performing “never-before executed calculation” constituted an “undue burden.”), see also Katz v. Employees Retirement System, PR 16-32B, see also Ryan v. Town of Burrillville, PR 16-22 (“No evidence has been presented to suggest that the [information] could be ‘reorganized, consolidated, or compiled,’ in a way that would not unduly burden the town.”).

In accordance with Rhode Island General Laws § 38-2-8, you may wish to file a complaint with the Department of the Attorney General or the Rhode Island Superior Court.

[http://www.providenceri.com/signatures/444%20Westminster/IT/Jim%20Silveria.gif]

From: Matt Chapman - Free Our Info, NFP

Thank you for your response, however I do not understand why you think that you do not maintain the records responsive to my request. RIGL § 38-2-2 (4) states that "electronic data processing records" are public record. As such, I believe that your department is the maintainer of the transaction records of emails through Exchange's message tracking logs, which are enabled by default.

Please find the following Microsoft documentation useful for the purpose of this request, which describes the straightforward retrieval of the electronic data processing records of emails respondent to my request:
https://docs.microsoft.com/en-us/powershell/module/exchange/mail-flow/get-messagetrackinglog?view=exchange-ps

The above documentation, for the purpose of this request, can be distilled down to the below powershell. Please note that this is fairly standard code for an IT department with sufficient technical skills; the work required to review this code would unlikely be considered to cause significant burden by experts within the field. As a test, please run the below powershell for a short timeframe (1hr) as a test.
`get-messagetrackinglog -Start "1/1/2017 00:00:00 AM" -End "2/1/2017 00:00:00 AM" | select timestamp, sender, {$_.recipients} | export-csv c:\results.csv`

If I am wrong that any of the above is helpful, or that you do not maintain these records (eg, through a retention policies), please let me know.

I have zero intention of causing any undue burden to your department, and again, am more than happy to research straightforward methodologies if it means a reduction of burden.

Warmest Regards,
Matt Chapman
Free Our Info, NFP

From: Information Technology, Rhode Island

Your City of Providence public records request 18-573 has been published.

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Record request #18-573 has been published and is now available for public view.


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