June 24, 2020

Public Disclosure Commission
P.O. Box 40908
Olympia, WA 98504-0908
Dear Chair Ammons and Commission Members:
We are writing to convey concerns expressed by our employees about the potential
posting of F-1 reports filed by professional legislative staff online. We respectfully
request that the Public Disclosure Commission affirm its previous decisions regarding
this issue and continue to disclose these reports upon request.
In 2014, the question of publishing F-1 information online arose as part of a strategic
planning effort. Before making a decision, the PDC engaged in a lengthy and intensive
process that lasted seven months. After work group meetings, stakeholder meetings, and
an online survey, the PDC determined that F-1 information would continue to be
disclosed upon request, and that it would not be published online.
However, just four years later (in 2018) the question of publishing F-1 information online
came up again. The PDC heard numerous concerns from F-1 filers, including
professional legislative staff, and acknowledged that there had been virtually no process
involving them in discussions about privacy concerns, identity theft, personal safety, and
other impacts. The PDC ultimately deferred making a decision to publish F-1
information online.
Now, the question of publishing F-1 information online is before the Commission once
more. Yet concerns about incidents of identity theft, data breaches, and unauthorized
access to credit reports are rising. Consumers are reminded by state and federal
governments, financial institutions, health care providers, employers, and others to take
steps to protect personally identifiable information. Yet criminals with online access to
such information can undermine those protections and continue to victimize those
consumers.
Just last month, dozens of professional legislative staff were victims of identity theft
when unemployment insurance claims were filed in their names. When placing credit
freezes and fraud alerts with the nationwide credit bureaus, these staff were required to
verify their identities. Many of the questions posed to them could be easily answered
with information from an F-1 report (e.g., “At which of the following five financial
institutions do you have an auto loan?”). Anyone with unfettered access to their F-1
information could do the same.

 Public Disclosure Commission
June 24, 2020
Page 2
It is therefore critical to prevent criminals from scraping personally identifiable
information from F-1 reports filed by professional legislative staff, and then using that
data to victimize those employees for years to come.
Please exercise your discretion to continue providing F-1 reports filed by professional
legislative staff in response to records requests and not publishing their F-1 information
online.
Sincerely,

Bernard Dean
Chief Clerk of the House

cc:

Brad Hendrickson
Secretary of the Senate

Peter Lavallee, Executive Director, Public Disclosure Commission
Sean Flynn, General Counsel, Public Disclosure Commission