To view graphic version of this page, refresh this page (F5)

Skip to page body

Neglect Of Reporting Requirements

Neglect Of Reporting Requirements

Report of the
1999-2000 San Francisco Civil Grand Jury

PREFACE

This Report, "Neglect of Reporting Requirements," was previously issued as an Interim Report the week of April 20, 2000. This Preface briefly discusses changes to the Interim Report following its issuance. This Report now is final and is included with the other final reports by the 1999-2000 Civil Grand Jury.

The conclusions and recommendations remain as originally presented in the Interim Report. Those agencies that have not yet responded to the Interim Report are requested to respond to this Final Report.

The Civil Grand Jury has received responses from several agencies and is appreciative of these timely responses. To date, 18 of approximately 230 agencies have responded. Tables 1 and 2 have been updated as applicable to reflect information in the responses. Since this Civil Grand Jury term ends in June 2000, information from responses received the last week of June or later cannot be reflected in this Final Report. The Civil Grand Jury has received responses from the following agencies:

Clerk of the Board of Supervisors (includes Assessment Appeals, Youth Commission)

Mental Health Board

City Attorney's Office

Metropolitan Transportation Commission

Civil Service Commission

Police Department

Mayor's Office of Emergency Services

Public Transportation Department

Family Violence Advisory Council

Public Utilities Commission

First Source Hiring Administration

Department of Public Works

Annual Joint Fundraising Drive (a.k.a. Combined Charities Campaign)

San Francisco Redevelopment Agency

Public Library (includes Library Comm. and Bay Area Library Information System Adv. Board)

Office of the Treasurer and Tax Collector



Other changes to the Tables include indicating which other agencies are defunct (information received either verbally or by update of the Administrative Code), adding new agencies (e.g., Business Tax Board of Review, Child Support Services), updating report requirements, and indicating which agencies have established a webpage following issuance of the Interim Report.

Lastly, we are also aware that the proposed 2000-2001 budget notes possible rearrangement of some executive branch departments into the Adult and Aging Services. In that these proposals are not finalized, this Report does not reflect any of the proposed reorganization.

SUMMARY

Many San Francisco departments, boards, commissions and other agencies are failing to send copies of required reports to the Documents Department of the San Francisco Public Library, despite the requirements of Administrative Code, Section 8.16. The types of required reports required include annual, financial, statistics, and recommendation reports. It also appears that many reports required by the Municipal Codes may not even be prepared.

Failure to prepare required reports reduces the potential for policy makers to make fully informed decisions. Failure to send copies of reports to the Public Library diminishes the public's ability to easily review these public documents in a central location and decreases their ability to stay aware of local government successes, activities or plans; this failure also reduces the amount of historical material available for research.

BACKGROUND

This year's Civil Grand Jury attempted to use Public Library resources for research at the beginning of its term. It became apparent that documents required to be on file at the Public Library were in fact not available. Specifically, several Annual Reports were not available or were not current. Further investigation showed that other reports required by the Municipal Codes also were not available at the Public Library.

Several other investigations have also indicated lack of compliance with Municipal Code reporting requirements, including:

  • Controller Department Audit 98020, dated September 15, 1999, in part documenting the failure of City departments to submit required reports to the Commission on the Status of Women. The Audit notes that the Commission had on file only 21 percent of the reports from City agencies required by Section 33.4 of the Administrative Code (129 out of the 632 required reports). The Audit also noted that the Commission had not met the Section 33.6 semiannual report requirement to the Board of Supervisors, as well as several other report problems;
  • a 1997-1998 Civil Grand Jury report noting failure of departments to report overtime as required by Administrative Code, Section 18.13;
  • a Board of Supervisors Budget Analyst report, dated March 13, 1998, also regarding failure to report overtime as required by Section 18.13;
  • Controller Department Audits 98046, 98058, and 98064, in part documenting failure to prepare and submit required reports to the San Francisco Arts Commission.

In that requirements of the Municipal Codes appeared to not be complied with, the Civil Grand Jury determined that a review to determine the extent of noncompliance was warranted.

MUNICIPAL CODE REQUIREMENTS

The San Francisco Charter and Municipal Codes (hereafter referred to as Municipal Codes) contain requirements for preparation and submittal of a wide variety of reports. The San Francisco Board of Supervisors also occasionally includes report requirements in its Ordinances and Resolutions; California and Federal laws may also impose some report requirements. The requirements typically state when and to whom the reports are to be submitted. The Board of Supervisors is the most usual required recipient of reports, followed by the Mayor of San Francisco.

Examples of required reports include the Ethics Commission report regarding whistleblower complaints, various Controller Department reports regarding the financial status of the City and County, Human Resources Department reports regarding sexual harassment claims, the Lead Hazard Reduction and Lead Poisoning Prevention Committees activity reports, the Recreation and Park Department Open Space report, the Public Health Department review of jail conditions, and the Children, Youth and Families Children's Services Plan.

In addition to requirements specific to each report, there also is a global requirement applicable to all official published documents. Administrative Code, Section 8.16, states in part:

It shall be the duty of every official, board, commission, or department, who or which publishes an annual report or other official published documents, relative to the affairs under his or her or its control or related to his or her or its functions, to file at least two copies thereof with the Documents Department of the San Francisco Public Library within 10 days after publication of each such report or document.

The reports of documents required to be filed pursuant to the provisions of this Section shall be made available by the Documents Department for reference thereto by the People of the City and County.

Any violation of the provisions of this Section on the part of any elective officer or any member of any board or commission shall be deemed to be official misconduct and any violation of the provisions of this Section on the part of any employee shall be deemed to be inattention to duties and considered cause for suspension or dismissal from service.

The requirement to file annual reports with the Public Library has been in the Administrative Code since before World War II (see Ordinance 1542 from Series of 1939, Journal of Proceedings dated March 16, 1942). Reports required by the Municipal Code, ordinances or resolutions are official published documents and, therefore, two copies of such reports should be filed with the Public Library. For the purposes of this report, agencies such as advisory committees are considered to be a unit of the agency they advise and, therefore, subject to the requirements of Section 8.16 as well.

It is interesting to note the Section 8.16 statement regarding official misconduct. None of the Municipal Code requirements we reviewed had any penalties or sanctions for failure to make or prepare any of the required reports, yet once the reports are issued there then is a sanction for failure to send copies to the Public Library. The Municipal Code contains a large number of report requirements and, no doubt, some of these requirements have outlived their usefulness. A good example of a report requirement that may have outlived its usefulness is Administrative Code, Section 18.13. Section 18.13 requires overtime reports if certain conditions are met. Our interviews indicate that the data intended to be derived from this report are now more easily obtained from a monthly overtime report published by the Controller's Office. However, until the requirements are changed the required reports should continue to be submitted.

In addition to required reports, departments, boards, commissions, and other government agencies (hereafter referred to collectively as agencies) also issue many other reports relative to their affairs, which also should be sent to the Public Library. The Public Library does have a variety of these types of reports on file; however, as noted in the next Section, no agency has a complete listing of all of the types of reports that should be sent to the Public Library. Actions taken in response to the recently voter-approved changes to Section 67 of the Administrative Code, the "Sunshine Law," may eventually provide such a list. Therefore, we limited our review only to those reports that were required by the Municipal Codes.

Failure to send copies of reports to the Public Library is a technical violation of Municipal Code requirements and diminishes the public's ability to easily review public documents in a central location. While the reading files of various departments and the Board of Supervisors Clerk's files are also available for public review, we note that during these investigations we have found it easier and more convenient to use the Public Library files. In addition, Section 8 of the Administrative Code allows agency documents either to be sent to storage after a departmentally-determined number of years or discarded. Therefore, if older or previous versions of reports need to be reviewed, this would be more easily done at the Public Library.

METHODOLOGY

To identify City agencies and their reporting requirements, we reviewed the San Francisco Municipal Codes, applicable Board of Supervisors resolutions and ordinances, and lists of active commissions, boards, etc., from the Mayor's Office and Board of Supervisors Clerk's Office (see Table 1). Our review centered primarily on agencies created by San Francisco, California or federal law which have recurring reports with regular submittal requirements (e.g., annual, quarterly, etc.) since there should be a reasonable certainty of finding them. Recurring reports are easier to use to verify compliance than are reports required only when certain conditions are met. One-time-only reports have also occasionally been included, usually where an agency's only requirement is to produce a final report. We have not included other types of report requirements (e.g., those for lobbyists to the Ethics Commission or non-profit organizations to the Board of Supervisors) since these reports would not be subject to the requirements of Section 8.16.

The Municipal Code recurring report requirements typically do not specify that a report need not be submitted if there is nothing to report. As noted in the Controller's Audit 98020, even if there is nothing to report a report nevertheless should be issued to document that fact. Issuance of such a report would eliminate ambiguity and would be of value to policy makers.

The files of the Public Library and Clerk of the Board of Supervisors were reviewed for reports (as noted above, the Board of Supervisors is the most usual required report recipient). Also, we reviewed SFGov (.www.sfgov.org), the website for San Francisco City and County (however, reports provided on the Internet do not satisfy Administrative Code, Section 8.16 requirements).

We also interviewed Public Library and Board of Supervisors personnel, as well as heads of various other City agencies.

RESULTS

Results are presented in Table 1. A typical entry in the Table would look like this:

Department/

Board/

Commission, etc.

Charter/

Code Citation

Report(s)

Current Report?

Clerk, Brd of Supervisors Files

Doc. Desk Library Files

Web/

Other

typical agency name

XY, Z.123 (citation that requires the report or lists agency duties)

report frequency

<to whom report is required to be sent>

is there a current report available

(the date of the report found in the files)

(in bold/italic if out of date or not found)

notes regarding reports on web, or other notes



A more detailed discussion of Table 1 parameters is presented in the introduction to the Table. The Table 1 shaded boxes, which denote either that a report was out-of-date or not found, indicate that approximately half of the agencies have a potential problem with respect to issuing recurring reports and/or sending copies of recurring reports to the Public Library.

CONCLUSIONS

Our interviews and review of data included in Table 1 lead to the following conclusions:

(1) Many City agencies do not appear to be following the requirements of Administrative Code, Section 8.16 to file copies of official published documents with the Public Library.

Table 1 indicates that copies of many reports have not been sent to the Document Desk of the Public Library. Library staff are aware of the requirements of Section 8.16 and have several times in the past sent out a reminder to various City agencies regarding this requirement (see Appendix B; library staff note that the City Attorney's office has reviewed and concurred with this reminder). However, library staff have had neither a full listing of all agencies that might be required to send copies of reports to the library, nor a list of what reports should be expected from each agency (no one else we interviewed knew of such a list either). Therefore, it is uncertain whether or not all applicable agencies received this reminder. Further, there is no requirement that Public Library staff send such a reminder, and library staff do not feel they have any recourse by which to encourage or enforce compliance with Section 8.16.

The issue of agency non-compliance with respect to Section 8.16 was brought to the attention of the Sunshine Task Force in April 1995 by Documents Department library staff. The library staff noted that there was no formal process to notify staff of the creation or demise of new agencies (this is also important with respect to posting of agendas and minutes) and that compliance with the requirements of Section 8.16 was not complete. Among the suggestions given by the Task Force to library staff was to write a letter to the Mayor, requesting compliance with Section 8.16 by all city departments (Charter Section 3.100 states that the Mayor shall have the responsibility to enforce all laws relating to the City and County). The letter was never drafted, and relative to this matter the Sunshine Task Force took no further action.

Interviews with various department heads indicate that many are not familiar with the requirements of Section 8.16. For those who were aware of Section 8.16, there was some confusion between this requirement and the requirements of Administrative Code, Section 8.7, which involves sending reports or other material of historical significance to the San Francisco History Room of the Public Library. The History Room is a different department and on a different floor than the Document Desk. There also was some confusion regarding exactly how the wording of Section 8.16 ("official published documents") related to the reports required by the Municipal Code.

The San Francisco City Attorney's Office publishes "An Overview of the Laws Governing the Conduct of Public Officials," to provide City officials with an overview of laws regulating their conduct as public officials. This document contains a wealth of information regarding public records and public meetings laws. Part 2 of the document is intended to familiarize elected officials, department heads, etc. "with State and local laws governing the public's right of access to City records and meetings conducted by City boards and commissions." However, the City Attorney's guide does not contain a discussion of the requirements of Section 8.16. This appears to be a missed opportunity to provide officials with information regarding requirements for public access to information at the Public Library.

Library staff report that the Documents Desk is patronized often by members of the public looking for a variety of documents from San Francisco City and County government. Having copies of reports in the Public Library provides for a central location. The public then does not need to find out which departments and personnel to ask for what information. The Public Library is also open at more convenient times than are government offices. Lastly, review of documents at the Public Library is easier if one is reviewing a great number of documents or trying to review reports from different agencies to the same Administrative Code requirement (this reduces undue imposition on Board of Supervisors Clerk staff, and avoids having to go to each agency's reading file during their hours of operation).

(2) Some City agencies are not aware of all the Municipal Code Sections that require them to submit reports.

Failure of agencies to prepare required reports reduces the potential for policy makers to make fully informed decisions. Interviews with various department personnel indicate a varying degree of knowledge of reports required of their department by the Municipal Code. For instance, several departments were unaware of the requirements of Administrative Code, Section 18.13 regarding reporting of overtime. Other departments were unaware of the Annual Report requirements of the Charter, Section 4.103, and Administrative Code, Sections 1.56 and 2A.30. Still others, when other report requirements were brought to their attention, noted they should not be required to submit the information since that information was under the jurisdiction of another department, or that the report requirement should have been changed several years ago following a department reorganization.

Our interviews with various City personnel also revealed a lack of clarity regarding whose responsibility it was to:

  • inform departments of their Municipal Code reporting requirements;
  • follow up if these requirements were not met; and
  • take enforcement action.

Some interviewees believed that the Clerk of the Board of Supervisors should be responsible for ensuring that reminders are sent to agencies that are not submitting required reports. Others believed that it was the responsibility of the Mayor, the City Attorney, or library staff.

The 1997-1998 Civil Grand Jury report on overtime and Administrative Code 18.13 reporting requirement requested a response from the Board of Supervisors. The Civil Grand Jury asked essentially that the Board take actions to enforce the Section 18.13 reporting requirements. The Board responded that they had no jurisdiction over the subject departments and, therefore, would not be taking any action. In this light, then it must be the chief executive officer (i.e., the Mayor) who has reminder and enforcement jurisdiction. The Charter, Section 3.100, which notes that the Mayor is responsible for enforcing all laws relating to the City and County, bolsters this position.

Our interviews indicate that the following factors are involved:

  • there is no clear authority responsible for reminding agencies of their reporting responsibilities and ensuring compliance;
  • there is no process by which agencies might on an annual basis be made aware of their specific report requirements and the requirements of Section 8.16;
  • there is a lack of accountability if Municipal Code requirements are not met;
  • the Municipal Code is voluminous, and there is no easy method by which a given agency can identify all its reporting requirements;
  • there may no longer be any need for some of the reports marked no report found, but no action was taken to delete the requirement;
  • some agencies may be under the incorrect assumption that a report need not be submitted if there is nothing to report during a given report interval.

(3) Some agencies send reports directly to the individual Supervisors, rather than through the Board of Supervisors Clerk.

Several agencies had up-to-date Annual Reports on file at the Public Library, but had out-of-date Reports on file at the Board of Supervisors. When asked about the discrepancy, these departments noted that they had sent their recent Annual Report directly to each of the Supervisors, not to the Clerk. Unlike for Boards and Commissions, regulations for departments do not specifically state that Annual Reports should be sent to the Clerk of the Board of Supervisors. While such a transmittal directly to the Supervisors may fulfill the Municipal Code requirement to submit a report, it is less than satisfactory. Such material then is neither logged into the Clerk's files nor available for public review at the Clerk's Office.

(4) The requirements for Annual Reports are not clear.

The requirements for Annual Reports for departments, boards, and commissions are unclear and, for such a relatively simple requirement, somewhat complex. A fuller discussion of this issue is presented in Appendix A. The applicable Municipal Code requirements are quoted in Attachments 1, 2 and 3 to Appendix A.

In brief, the requirements for Annual Reports from departments are different than for Annual Reports from boards or commissions. For example, departments are required to submit an Annual Report. Boards and commissions may submit either an Annual Report or an Annual Statement of Purpose; however, the Charter allows either option whereas the Administrative Code only discusses the Statement of Purpose. In addition, neither the Charter nor the Administrative Code defines what is a Statement of Purpose or what are its parameters. Nor does the Municipal Code make any qualification to these requirements for advisory boards or commissions.

In summary (and for ease of discussion in the Recommendations section), the findings from the above conclusions are:

  1. Many agencies do not appear to be following the requirements of Administrative Code 8.16.
  2. Many people are unaware of the many report requirements in the Municipal Codes.
  3. Many people are unaware of the requirements of Administrative Code 8.16 requirements to send copies to the Public Library.
  4. There is no list of all reports and documents that should be available at the Public Library and that also could be used by the library staff to send out reminders or otherwise contact departments to get copies.
  5. City Attorney overview material does not provide any information regarding Section 8.16.
  6. There is a lack of clarity as to who within San Francisco City government should be responsible for ensuring that all government agencies are informed of all their requirements. There also is a lack of clarity as to who should monitor compliance with Municipal Code requirements, and enforce the requirements as necessary.
  7. Municipal Code requirements sometimes are not easy to find. Report requirements are sometimes not well labeled, the indexes for the Municipal Codes are sometimes deficient, and sometimes responsibilities for reports are called out in a part of the Municipal Codes that a given agency would not expect (e.g., Police Department report requirements called out in the Traffic Code).
  8. Some agencies send their reports directly to each of the Supervisors, rather than sending the reports to the Supervisors through the Clerk's Office.
  9. Municipal Code Annual Report requirements are not well-defined (see Appendix A for details).

Recommendations

Finding (1) Many agencies do not appear to be following the requirements of Administrative Code Section 8.16 that two copies of all public documents be filed with the Public Library.

Recommendation

Each agency is requested to respond in writing to the Civil Grand Jury as to whether or not that agency:

  • agrees whether or not listed report requirements are correct;
  • agrees whether or not report status is correct;
  • believes there are any requirements we have omitted;
  • intends to send material to the library.

Also, please tell us how you have incorporated, or will incorporate, knowledge of these requirements into any department procedure or other internal process such that staff turnover, etc., will not negatively impact sending required material to the Document Desk of the Public Library. Also, please let us know how you have disseminated this information to your staff.

Required Response

All agencies

Finding (2) Many people are unaware of the many report requirements in the Municipal Codes.

Recommendation

As noted in Charter Section 3.100, the Mayor is responsible for enforcing all laws relating to the City and County. The Mayor or his designee should send a letter to all agencies reminding them of their duty to be aware of code requirements, as well as his expectations regarding their compliance with Code requirements.

Required Response

The Mayor

Finding (3) Many people are unaware of the requirements of Administrative Code 8.16 requirements to send copies to the Public Library.

Recommendation

The Mayor or his designee should send a letter to all agencies reminding them of their duty to be aware of code requirements, as well as his expectations regarding their compliance with Code requirements.

Required Response

The Mayor

Finding (4) There is no list of all reports and documents that should be available at the Public Library, and that also could be used by the library staff to send out reminders or otherwise contact departments to get copies.

Recommendation

In response to the recent voter-approved modifications to Administrative Code, Section 67, Administrative Services is in the process of preparing a list of all documents prepared by various agencies. This list will include all agency reports and documents; the reports required to be sent to the Public Library are only a subset of this larger list. The information in Table 1 may be of some use to the Administrative Services Department in their task. Once prepared, the Administrative Services list would be a resource for any Library staff action.

Required Response

Administrative Services

Recommendation

The "Posting and Depository Factsheet" currently sent out by Public Library staff as a reminder regarding the requirements of Section 8.16 should be revised. Specifically, the Factsheet notes that copies "should be sent". Our review of Section 8.16 indicates that the requirement supports stronger wording, and we recommend that Library staff change "should" to "shall", possibly using a bold font. We also recommend that the list of official publications be modified to add "reports issued in response to Municipal Code requirements."

Required Response

Public Library, Documents Department

Finding (5) City Attorney overview/training material does not provide any information regarding the requirements of Section 8.16.

Recommendation

The City Attorney publication, "An Overview of the Laws Governing the Conduct of Public Officials," should be revised to include appropriate guidance to all agencies regarding the requirements of Administrative Code, Section 8.16

Required Response

The City Attorney's Office

Finding (6) There is a lack of clarity as to who within San Francisco City government should be responsible for ensuring that all government agencies are informed of all their requirements. There also is a lack of clarity as to who should monitor compliance with Municipal Code requirements, and enforce the requirements as necessary.

Recommendation

The Mayor or his designee should establish a process to send out an annual reminder letter to all agencies informing them of their duties to be aware of code requirements, as well as his expectations regarding their compliance with Code requirements. This should include an annual review and update of the list of publications that that agency prepared in cooperation with the Administrative Services Department. The Mayor or his designee should also establish a process by which input could be received regarding potential noncompliance.

The Mayor should also formulate a policy regarding actions that would be taken by his office should an agency not follow the requirements of Section 8.16.

Required Response

The Mayor

Recommendation

The Board of Supervisors should tell new agencies about the requirements of Administrative Code 8.16, perhaps by inclusion of specific reference in the resolution or ordinance used to create the agency. City departments and long-standing boards and commissions may retain a "corporate memory" of requirements. Newly-formed agencies that may only be in existence for a year, then produce a final report may not otherwise be notified of any Municipal Code requirements that apply.

Required Response

The Board of Supervisors

Finding (7) Municipal Code requirements sometimes are not easy to find. Report requirements are sometimes not well labeled, the indexes for the Municipal Codes are sometimes deficient, and sometimes responsibilities for reports are called out in a part of the Municipal Codes that a given agency would not expect (e.g., Police Department report requirements called out in the Traffic Code).

Recommendation

The Board of Supervisors should study the Municipal Code structure, especially with respect to (a) labeling of report requirements, and (b) how the indexes are established. Report requirements should be better identified.

Required Response

The Board of Supervisors

Recommendation

As the Board is currently doing with its revisions to the Administrative Code, consideration should be given to revising other parts of the Municipal Codes. The Board should review current report requirements for relevance, and consider elimination of those requirements no longer useful.

Required Response

The Board of Supervisors

Recommendation

In its role to prepare and make available a codification of the ordinances of the City and County (Charter Section 6.102), the City Attorney's Office should consider preparing a master index for all Sections of the Charter and Municipal Codes. A master index would make it easier for agencies to identify all requirements that apply to them. The Charter and Municipal Codes are available on the Internet for full-text search, but some searches can result in many "hits" to review. A master index could shorten this process. Also, not all members of the public have Internet access.

Required Response

The City Attorney's Office

Finding (8) Some agencies send their reports directly to each of the Supervisors, rather than sending the reports to the Supervisors through the Clerk's Office.

Recommendation

On a regular basis (perhaps yearly), the Clerk of the Board of Supervisors should send out a reminder letter to all agencies regarding the need to send, through the Office of the Clerk, any documents required to be reported to the Board of Supervisors.

Required Response

Clerk of the Board of Supervisors

Finding (9) Municipal Code Annual Report and Annual Statement of Purpose requirements are not well defined (see Appendix A for details).

Recommendation

The Board of Supervisors should initiate action to make the following changes to the Administrative Code:

  1. Administrative Code, Section 1.56, should be revised to allow either the Annual Report or Annual Statement of Purpose option.
  2. Section 1.56 should be revised to note that the Annual Statement of Purpose and the Mission and Goals statements are equivalent.
  3. Section 1.56 should be revised to clarify which boards and commissions (all, just those in charter, none that are advisory, etc.) to which it applies.
  4. Sections 1.56 and 2A.30 should be revised to indicate to whom the Annual Report should be sent.
  5. Sections 1.56 and 2A.30 should be revised to indicate Annual Report expectations for those cases where there is both a department and a board or commission (two separate Annual Reports would not be required)
  6. Consideration should be given to some form of combination of the Annual Report and Customer Service Plan report requirements. Some examples of Annual Reports with specific content requirements include Park and Recreation and the Lead Hazard Reduction Program.

Required Response

Board of Supervisors

Ancillary Recommendations

Finding (10) Some of the findings in this report may be of interest to the Sunshine Task Force.

Recommendation

We recommend that the Task Force review this report for concurrence and followup. For those recommendations with which the Task Force agrees, we request that the Task Force consider sending letters of concurrence to those from whom we have required a response, notifying them of your concurrence.

Required Response

Sunshine Task Force

Finding (11) Several agencies are placing some of their documents (includes both required and non-required reports) on their Internet web pages. This does put the reports into an easily accessible public space; however, Section 8.16 currently does not specify this as a method for compliance with its provisions. Surprisingly, some of the information was available only on the Internet, not in the Board of Supervisors Clerk's or Public Library files. Also, some of the information on the Internet was out of date with respect to material available in the Library. Therefore, we make the following observations:

  • Putting a document on the Internet does not meet Administrative Code requirements to send two copies to the Public Library.
  • Attention must be paid to keep information on a web page current, unless the agency is also maintaining an archive.
  • There are people that do not have ready access to the Internet yet. The Public Library does maintain availability of Internet access for the public, but sometimes it can be difficult to get all the research done in the time usually allotted (1 hour).
  • There must be strong document control procedures to ensure that the version placed on the Internet is the same as that issued in paper form. The issue here is that sometimes several earlier drafts or versions of a report exist, and care should be taken to ensure that the correct version is uploaded to the website. Also, following upload there should be restrictions on access so that uploaded files are not inadvertently accessed and modified.

  • Sometimes a report has graphs or tables that are not easily presented on the website. Also, if graphs and tables are presented, there remains the issue of access to this information by the blind since software translators may not be able to adequately translate such information.

  • Information should easy to find on the website. Even though the document is on the Internet, it may not be in the most easily found area. Reliance on use of the website search engine is not necessarily the best way, since this essentially presupposes that the public should know that such information is there, or should be there, to be found. If one doesn't know that the information should be available, then one very well may not use a search engine to find it.

Recommendation

A reminder regarding City policy on posting information on the Internet should be developed and communicated to all affected agencies.

Required Response

The Mayor

Finding (12) During our review of the City and County web pages for documents, we observed that several of the agencies did not have a web page. The recent changes to Administrative Code, Section 67, include direction regarding placement of information on the Internet, specifically Sections 67.9, 67.21-1, 67.29, and 67.29-2. While this is not within the scope of our review, we thought we would compile the statistics and forward them for information to the Sunshine Task Force since we had the data at hand. The statistics are presented in Table 2. These data only indicate that an agency is in some way mentioned on a web page; we intend no endorsement or criticism of the adequacy of information presented.

Recommendation

We recommend that the Task Force discuss Table 2 and the issue of web pages at one of their public meetings.

Required Response

None.

Last updated: 4/3/2012 11:29:16 AM