OPRA requires disclosure of the resumes of government employees and appointees, so that the public can see the qualifications of those serving in government. But as noted in this recent GRC opinion, Rodriguez v. Kean University, before releasing a resume, a records custodian may need to redact some portions of it.

When OPRA was enacted, there was some question as to whether employee resumes should be treated as confidential documents because they are personnel records. In 2002 Governor McGreevey issued Executive Order 26, to deal with the status of various records under OPRA. One section of this Executive Order requires disclosure of the resumes of successful job applicants.

In Rodriguez, the GRC determined, as it has in other cases, that an OPRA request for certain employees’ resumes should be granted based on Executive Order 26. However, the GRC did not require release of the entire resumes; it specifically ordered disclosure of the resumes “with redactions where necessary,” noting as an example that it has previously upheld the redaction of a home address from a resume on privacy grounds.

Resumes usually contain other information that may be protected by a privacy interest, such as a personal email address and home telephone number. In fact, as discussed in this New Jersey OPRA Law Reporter post, the GRC has held that personal email addresses are confidential under the statute’s privacy provision..

In addition, although not mentioned by the GRC, the Supreme Court has ruled that OPRA’s personnel records section permits disclosure of only a narrow category of information concerning an employee’s education and experience:  the records showing that a public employee meets the specific education and experience qualifications that are prerequisites for his job. This suggests that redactions may be necessary where a resume contains information unrelated to the qualifications specifically required for the employee’s position.