Public housing algorithms audit
| Submitted | March 13, 2023 |
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Communications
From: Todd Feathers
To Whom It May Concern:
Pursuant to the California Public Records Act, I hereby request the following records regarding algorithmic tools used by your agency to guide decision making:
For the purposes of this request, the term algorithmic tools refers to computer software or code that employs machine learning techniques. It does not apply to other types of algorithms, such as Excel formulas.
My request applies to all algorithmic tools developed in-house by your agency, purchased for use by your agency, or otherwise used by your agency since Jan. 1, 2018. Such algorithmic tools include, but are not limited to, models for:
- Tenant screening
- Fraud detection
- Risk scoring
- Rate setting (e.g. for rent, utilities, or other fees)
- Maintenance/repair/budget allocation
- Investigations (e.g., crime hotspot prediction, facial recognition, complaint prioritization)
- Unit/voucher prioritization (e.g. models used to rank potential tenants or match them with available units)
- Advertising/outreach prioritization (e.g. models used to decide where or to which groups to advertise)
For each algorithmic tool your agency has used since Jan. 1, 2018, I request the following records:
1) Executive summaries, project overviews, or comparable records that describe the scope and purpose of the algorithmic tool.
2) Contracts, statements of work, successful RFP submissions and bid packets, or comparable records that describe the purchase and/or construction of the algorithmic tool.
3) User handbooks, guides, training manuals, agency policies, or comparable records that describe the tool’s functions and its appropriate uses.
4) The data dictionary, data library, or comparable document that defines the data fields used by the algorithmic tool.
I ask that all fees be waived as I am a journalist and intend to use the requested records to publish articles in the public interest. In the event you choose to impose fees, I request a detailed breakdown of the fees, including the hourly wage of the lowest-paid employee capable of processing the request and an explanation justifying the employee hours required to complete the request.
Should you choose to reject this request or redact portions of it, I ask that you provide a detailed breakdown of the statutory exemptions and associated case law underlying your decision to withhold each/any portion from public review.
The requested documents will be made available to the general public, and this request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.
Sincerely,
Todd Feathers
From:
Hello,
The Los Angeles County Development Authority is in receipt of your request for public records for "records regarding algorithmic tools used by your agency to guide decision making."
In response, we are in the process of compiling the responsive documents and require additional time to comply with your request as authorized by California Government Code Section 6253. We estimate that we will be able to provide the requested records by April 7, 2023.
Thank you.
PLEASE NOTE: Unfortunately, this email is an automated notification, which is unable to receive replies.
We're happy to help you with any questions or concerns you may have.
Please submit an inquiry through our Public Inquiry Portal at https://publicinquiry.lacda.org. Thank you.
From: Los Angeles County Development Authority
Hello Todd,
As a follow up to the response from the Los Angeles County Development Authority below, on your request for public records “regarding algorithmic tools used by your agency to guide decision making," the responsive records have been identified.
In order to proceed with loading the records onto your website as requested, please provide an eight (8) letter security code as none was included with your request letter.
Thank you.
Elisa E. Vásquez, Director
Pronouns: she, her, hers
Communications and Public Affairs Unit
Los Angeles County Development Authority
700 W. Main Street
Alhambra, CA 91801
phone: 626.586.1762
fax: 626.943.3801
www.lacda.org<http://www.lacda.org/>
[FB-f-Logo__blue_1024]<http://www.facebook.com/lacdevauthority>[Twitter_Logo_Blue]<http://www.twitter.com/lacdevauthority>[In-2C-128px-R]<https://www.linkedin.com/company/58455/>
From: Todd Feathers
Hi Elisa,
I'm happy to provide a code, but could you just clarify what you need it for. Are you getting a prompt from MuckRock to enter a code, or is this required for processing on LACDA's end?
Appreciate the help!
Todd
From: Todd Feathers
Hello,
I'm following up on your request for a security code. Could you please explain what the security code is for and why it's needed to upload the responsive records?
Thank you!
Todd
From: Muckrock Staff
To Whom It May Concern:
I'm following up on the following California Public Records Act request, copied below, and originally submitted on March 14, 2023. You had previously indicated that it would be completed on April 7, 2023. I wanted to check on the status of my request, and to see if there was a new estimated completion date.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I'm following up on the following California Public Records Act request, copied below, and originally submitted on March 14, 2023. You had previously indicated that it would be completed on April 7, 2023. I wanted to check on the status of my request, and to see if there was a new estimated completion date.
Thanks for your help, and let me know if further clarification is needed.
From: Los Angeles County Development Authority
Hello - on behalf of Elisa Vasquez, Communications and Public Affairs Director, Los Angeles County Development Authority, please see the attached files you requested.
Thank you,
Rosa Barreto, Executive Assistant
Pronouns: she, her, hers
Communications and Public Affairs Unit
Los Angeles County Development Authority
700 West Main Street
Alhambra, CA 91801
Phone: (626) 586-1770
Fax: (626) 943-3801
www.lacda.org
There are too many files to display on this communication. See all files
From:
Hello Todd,
As a follow up, today I received the attached fax with correspondence from you which includes the passcode for your website to allow the Los Angeles County Development Authority to upload responsive records in response to your request for “algorithmic tools used by your agency to guide decision making." As such, the records have now been uploaded.
Please note that the attached fax includes three emails from you dated April 6, 2023, April 7, 2023 and April 11, 2023, which I did not receive via email. Additionally, I only received one fax dated May 11, 2023. Finally, your initial email per the thread below, did not include the passcode for your website.
For any follow up questions, please respond to this email thread. Thank you.
Elisa E. Vásquez, Director
Pronouns: she, her, hers
Communications and Public Affairs Unit
Los Angeles County Development Authority
700 W. Main Street
Alhambra, CA 91801
phone: 626.586.1762
fax: 626.943.3801
www.lacda.org<http://www.lacda.org/>
[FB-f-Logo__blue_1024]<http://www.facebook.com/lacdevauthority>[Twitter_Logo_Blue]<http://www.twitter.com/lacdevauthority>[In-2C-128px-R]<https://www.linkedin.com/company/58455/>
From: Todd Feathers
Hi Elisa,
Thank you very much for your help with this request and my apologies about the lost emails. That's likely a problem on my end.
The documents you provided are heavily and I believe inappropriately redacted. I don't see the explanation for the redactions given anywhere, but I would be happy to set up a phone call to discuss this.
The RFP you provided states in section 1.14 "Notice to Proposer Regarding the Public Records Act" that:
"At such time as the Housing Authority recommends a Proposer to the
Executive Director, all such proposals submitted in response to this RFP become
a matter of public record, with the exception of those parts of each proposal which
are defined by the Proposer as business or trade secrets, and are plainly marked
as 'Trade Secret,' 'Confidential,' or 'Proprietary' ...
"A blanket statement of confidentiality or the marking of each page of the proposal as
confidential shall not be deemed sufficient notice of exception. The
Proposer(s) must specifically label only those provisions of the proposal
which are 'Trade Secrets,' 'Confidential,' or 'Proprietary' in nature."
However, many of the documents your provided are either 1) redacted without any designation as confidential or 2) the entire documents are improperly labeled confidential on each page, which as the RFP states, "shall not be deemed sufficient notice of exception."
Successful bid packages and contracts are clearly public records and I ask that these documents should be released in full.
Todd
From: Los Angeles County Development Authority
Hello Todd,
I am in receipt of your email below, dated May 12, 2023, where you indicate that the documents provided by the Los Angeles County Development Authority in response to your California Public Records Act request for algorithmic tools used by the agency “are heavily and I believe inappropriately redacted.” In response, please note the following explanations and Government Code citations used for the redactions.
Government Code section 7927.705 exempts from disclosure records which are exempt or prohibited from disclosure under Federal or State law, including those protectable as trade secrets or proprietary information under Evidence 1060 or other applicable law.
Government Code section 7922 allows an agency to withhold a record by demonstrating that, on the facts of the particular case, "the public interest served by not making the record public clearly outweighs the public interest served by disclosure of the record." (CBS Broadcasting, Inc. v. Superior Court (2001) 91 Cal.App.4th 892; Times Mirror Co. v. Superior Court (1991) 53 Cal.3d 1325.) The redacted parts of the records are the vendors’ trade secret and proprietary information. The public interest in not making the redacted portions public outweighs disclosure of trade secret and proprietary information.
Please let me know if you have any questions.
Elisa E. Vásquez, Director
Pronouns: she, her, hers
Communications and Public Affairs Unit
Los Angeles County Development Authority
700 W. Main Street
Alhambra, CA 91801
phone: 626.586.1762
fax: 626.943.3801
www.lacda.org<http://www.lacda.org/>
[FB-f-Logo__blue_1024]<http://www.facebook.com/lacdevauthority>[Twitter_Logo_Blue]<http://www.twitter.com/lacdevauthority>[In-2C-128px-R]<https://www.linkedin.com/company/58455/>
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