Right-to-Know Law • Addresses of Direct-Care Workers • “Caregiver Exemption” • Ability of Information to Identify Individual

Dep’t of Human Serv. Pennsylvanians for Union Reform, Inc., PICS Case No. 17-0218 (Pa. Commw. Feb. 8, 2017) Brobson, J. (31 pages).

The addresses of direct-care workers was not facially exempt from disclosure under the Right-to-Know Law where the exemption relied upon by the agency was intended to protect disclosure of information personal to an applicant for or recipient of social services, including the identity of a protected individual’s caregiver, and where addresses direct-care workers would not automatically lead to the disclosure of a worker’s identity, but OOR was required to conduct a balancing test in light of the workers’ constitutional right to privacy of their home addresses. Order of the OOR affirmed in part, reversed in part, case remanded.