HQL Public Information Act Request

BradyWarrior · Dec 30, 2014

After going over that HQL update thread I was wondering if anyone has ever submitted a Public Information Act request for the following or other records of public interest with respect to the HQL program? A) any documented internal MSP policies and or procedures pertaining to the processing of HQL applications B) any and all email communications pertaining to the handling of the specific PIA requestor's HQL application and C) internal policies and procedures related to cybersecurity governance of the systems in use by MSP in the storage, processing, or transmission of HQL applications and supporting records.

I'm sure we could think of other areas of relevance but that's just what I came up with on the fly.

http://www.oag.state.md.us/Opengov/pia.htm

I bring this up because if it hasn't been done, it *might* be a good idea.

Jack McCauley · Dec 31, 2014

Ultimately, after review by the Legal Counsel Section and the Public Information Office, you will receive a response from the Commander of the Licensing Division. If you can afford to pay for the time it takes to provide your response and if this information is not legally protected, you may then receive a very vague response. What are you trying to learn? I don't understand the purpose of such a request.

Mark75H · Dec 31, 2014

With the ongoing lawsuit, MSI can probably subpoena anything relevant and have it in depth/complete and free of charge

Rack&Roll · Dec 31, 2014

Whaaaaaaaaaaaaaaaaaaaaaaaaaaaat ?

Norton · Dec 31, 2014

Don't count on getting anything of use. I can tell you with 100% certainty that they will use the slightest vagueness in your wording to use it as an opportunity to omit any records that they don't want you to have.

I know for a fact that they did not give me an full response to a PIA that I did a few years ago.

Perhaps if you have the time and resources to pursue it, you might finally find what you are looking for, but my advice is that unless you know that something is out there, what its called and who was involved, you'll never find any smoking guns.

That PIA game is nearly a full time job.

Gryphon · Dec 31, 2014

What Norton said. I have sued the State under the PIA and prevailed at the Court of Appeals when the State violated the act and the Circuit Court let them get away with it. Wanna guess how much it cost and how long it took? The PIAs usefulness is limited in scope.

BradyWarrior · Jan 1, 2015

Jack McCauley said:
I don't understand the purpose of such a request.

Curiosity. After following the HQL update thread for a few months, there is quite a bit of analysis, speculation, and information sharing about process specifics like, "MSP only mails cards on Tuesday", "Some applications go through a secondary review", etc. I'm not really concerned about finding a "smoking gun", but rather looking for improved transparency in accordance with the law.

Public oversight by concerned stakeholders can be of great value, but I don't expect the media to take much interest in the HQL issuance process or in protecting the privacy of law abiding gun owners. With respect to cybersecurity, I wouldn't expect or want MSP to divulge specifics. But it would be nice to know what their "report card" looks like in terms of complying with all applicable policies, laws, and regulations governing the handling of our personal records.

Thanks all for the responses. Jack, I look forward to your talk at MSI next week.

BeoBill · Jan 2, 2015

BradyWarrior said:
... With respect to cybersecurity, I wouldn't expect or want MSP to divulge specifics. But it would be nice to know what their "report card" looks like in terms of complying with all applicable policies, laws, and regulations governing the handling of our personal records.

At the Federal level the safeguarding specifics of any automation system are protected at one level above the data the system processes; we can safely assume that this goes for MSP systems as well [something equivalent to or greater than U//FOUO/LE SENSITIVE]. So for systems that process PII (like that found in HQL applications), you have a snowball's chance of getting anything beyond "We comply with all applicable state and Federal information protection guidelines."

swinokur · Jan 2, 2015

I believe the only portions of the MSI suit are the banned long guns and the high capacity magazines. The HQL is not part f the suit and therefore no request for any info would be made by either side.

Someone can correct me if I'm wrong.

BradyWarrior · Jan 2, 2015

BeoBill said:
At the Federal level the safeguarding specifics of any automation system are protected at one level above the data the system processes; we can safely assume that this goes for MSP systems as well [something equivalent to or greater than U//FOUO/LE SENSITIVE]. So for systems that process PII (like that found in HQL applications), you have a snowball's chance of getting anything beyond "We comply with all applicable state and Federal information protection guidelines."

Here are some example reports I found via Google, lots of them are out there. But you're right, it's probably foolish to expect transparency from Maryland.

http://oig.hhs.gov/oas/reports/region7/71400433.pdf
http://www.oig.doc.gov/OIGPublications/OIG-14-025-A.pdf

HQL Public Information Act Request

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