California Appellate Tracker

Hurley v. Department of Parks & Recreation

February 27, 2018

Agency records containing personal information are protected under the Information Privacy Act even if not maintained in the agency’s centralized personnel records.

This opinion affirms a $19,200 award of noneconomic damages to a government employee against the entity for which she worked and against her supervisor for violating the Information Practices Act (Civ. Code 1798 et seq,) which prohibits government agencies from disclosing personal information about an individual. Here, the defendant agency maintained personal information about the plaintiff in a supervisory file that it twice disclosed improperly, once to a non-supervisory co-worker, and the other time to a former supervisor who at the time was on leave. The personal information included the fact that plaintiff had not passed a probationary period at a prior employer and had a life partner for whom she had sought medical insurance through her employment. A record containing such personal information is protected under the Information Practices Act even if it is not maintained in the agency’s centralized personnel records.

California Court of Appeal, Fourth District, Division One (McConnell, J.); February 21, 2018; 2018 WL 989506.

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Hurley v. Department of Parks & Recreation

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