Personal Privacy vs Public Records Laws (Prevailing Wage Version)

Contractors on prevailing wage projects must submit certified payroll reports to the public authority.  To what extent is that information subject to a public records request?  A New York appellate court recently confronted that issue and ruled in favor of privacy.^[1] 

The case arose on the following facts:  "Petitioner is a union employee and, as part of his job, purportedly seeks to ensure that nonunion contractors comply with the prevailing wage law."  When he made a public records request to the New York State Thruway, he was given copies of payroll reports that included titles and wages, but with names and addresses of the individual workers redacted.  The position of the state agency was that disclosure of names and addresses "would constitute an unwarranted invasion of personal privacy."  The lower court agreed, and the union appealed.