Name and Title of the Chief FOIA Officer:
Peggy R. Mastroianni, Legal Counsel
1. Did your agency conduct FOIA training during the reporting period for FOIA professionals?
Yes. EEOC did conduct training for its FOIA Professionals during the 2014 fiscal year.
2. If yes, please provide a brief description of the type of training conducted.
EEOC provides substantive FOIA training to all FOIA Professionals on a quarterly basis by video-teleconference. Substantive training was presented to FOIA professionals in the St. Louis, Miami, Philadelphia, Phoenix and Houston District Offices by video teleconference and teleconference. Training was also presented onsite to FOIA staff in our Miami and Philadelphia District Offices.
3. Did your FOIA Professionals attend any FOIA training or conference during the reporting period such as that provided by the Department of Justice?
In addition to the training referenced above, five FOIA Professionals attended training provided by DOJ, four attended events sponsored by the American Society of Access Professionals (ASAP), two attended training provided by the Office of Government Information Services, and one attended ASAP's Annual FOIA Conference in Virginia.
4. Provide an estimate of the percentage of your FOIA professionals and staff with FOIA responsibilities who attended substantive FOIA training during this reporting period.
EEOC would estimate that 94% of EEOC FOIA professionals and staff with FOIA responsibilities attended substantive FOIA training during this reporting period.
5. In the 2014 Chief FOIA Officer Report Guidelines, OIP asked agencies to provide a plan for ensuring that core, substantive FOIA training is offered to all agency FOIA professionals at least once each year. Please provide the status of your agency's implementation of this plan.
As described in the EEOC 2014 Chief FOIA Officer report, EEOC FOIA training will be provided in the format of an interactive on line module that our FOIA professionals will take on line. EEOC online FOIA training will be adapted from the FOIA storybook OIP develops. We have had several discussions with our IT office concerning the development of interactive online training for FOIA professionals. Further steps toward implementing our planned FOIA training can begin in earnest after the OIP storybook is shared. In the interim, EEOC will provide training, patterned from the training OIP presented on February 25 and 26, 2015, to FOIA professionals via video-teleconference. EEOC anticipates providing its FOIA professionals FOIAXpress training in April and substantive FOIA training in the fourth quarter of this fiscal year.
6. Did your FOIA professionals engage in any outreach or dialogue with the requester community or open government groups regarding your administration of the FOIA.
Yes, EEOC initiated outreach dialogues with the Center for Effective Government.
7. If you did not conduct any outreach during the reporting period, please describe why.
See response immediately above.
8. Does your agency have a distinct process or system in place to review records for discretionary release?
EEOC's process to review record for discretionary release is not yet formalized. The current process is frequent reiteration to FOIA professionals of the requirements of the presumption of disclosure and discussions of the principles embodied in the President's Executive Memorandum on the FOIA and the Attorney General's FOIA Guidelines. We are moving towards establishing processes for making greater discretionary disclosures, where possible.
9. During the reporting period, did your agency make any discretionary releases of information?
10. What exemptions(s) would have covered the material released as a matter of discretion?
11. Provide a narrative description, as well as some specific examples of the types of information that your agency released as a matter of discretion during the reporting year.
12. If your agency was not able to make any discretionary releases of information, please explain why.
Almost 99% of the approximately 18,000 FOIA requests and 7,000 Section 83 of the EEOC Compliance Manual requests EEOC receives annually are for investigative charge files. Three of statutes EEOC enforces, Title VII, the ADA and GINA, contain confidentiality provisions that prohibit the EEOC, its officers, and employees from making charge information public under penalty of arrest, fine, and jail. Consequently, EEOC cannot make discretionary releases of this information to the public. However, EEOC does make aggregated annual statistical data concerning employment discrimination charges available on its website, and discloses non-confidential statistical data arrays requested by the public. EEOC also made its first quarterly FOIA log available on its FOIA page. With regard to the remaining 1% of FOIAs, EEOC is proactively disclosing as much of the requested material as is permitted, Examples of some of the proactive disclosures on our website include informal discussion letters, Fair Employment Practice contracts, and aggregated EEO-1 data predating November 1, 1996, when agency's were required to make records available in electronic as well as paper format
13. Describe any efforts your agency has undertaken to inform non-FOIA professionals of their obligations under the FOIA.
Efforts can include training for non-FOIA professionals, distributing memoranda on the FOIA, announcements on FOIA matters, etc.
The FOIA Public Liaison participated in a webinar presented to all EEOC employees to discuss the new FOIA paradigm and what it means for records generated in the course of investigating and litigating employment discrimination. The Chair and her staff and a Commissioner were briefed on their responsibilities under the FOIA.
14. If there are any other initiatives undertaken by your agency to ensure that the presumption of openness is being applied, please describe them here.
At every opportunity, EEOC FOIA professionals are reminded of their responsibility to review each document with an eye toward disclosure. EEOC is emphatic that records are redacted, not withheld in full. EEOC has also provided substantive training to FOIA professionals on exemption (b)(5) to help instill the requirement to review each record with an eye toward making discretionary releases and to only withhold records when there is a "real" harm to an EEOC interest.
If any of these initiatives are online, please provide links in your description.
These initiatives are not on line yet.
As the Attorney General emphasized in his "[a]pplication of the proper disclosure standard is only one part of ensuring transparency. Open government requires not just a presumption of disclosure, but also an effective system for responding to FOIA requests." It is essential that agencies effectively manage their FOIA program.
Please answer the following questions to describe the steps your agency has taken to ensure that your management of your FOIA program is effective and efficient. You should also include any additional information that describes your agency's efforts in this area.
1. In the 2014 Chief FOIA Officer Report Guidelines, OIP asked agencies about the status of converting all eligible FOIA professionals to the new Government Information Series. If your agency reported that its staff was eligible for conversion but had not yet converted all professionals to the new series, what is the current proportion of personnel that have been converted?
Thirteen of the 17 of the eligible FOIA professionals have been converted to the new series.
2. If your agency has not converted all of its eligible employees yet, what is your plan to ensure that all FOIA professionals' position descriptions are converted?
Position Descriptions for the new Government Information Specialist series are now in place. We anticipate converting the remaining four FOIA professionals to the new series by the end of March.
3. For Fiscal Year 2014, what was the average number of days your agency reported for adjudicating requests for expedited processing. Please see Section VIII.A of your agency's Fiscal Year 2014 Annual FOIA Report.
On average, all requests for expedited processing were adjudicated in 2.34 days.
Please note here if your agency did not adjudicate any requests for expedited processing during Fiscal Year 2014.
4. If your agency's average number of days to adjudicate requests for expedited processing was above ten calendar days, please describe the steps your agency will take to ensure that requests for expedited processing are adjudicated within ten calendar days or less.
5. If your agency has a decentralized FOIA process, has your agency taken steps to make the routing of misdirected requests within your agency more efficient? If so, please describe those steps.
EEOC revised FOIA regulations at 29 C.F.R. 1610.7(a) identify the scope of FOIA authority for each field FOIA component. The Office of Legal Counsel (OLC) at Headquarters processes all other FOIA requests. 29 C.F.R. 1610.7(b). Additionally, each FOIA component, including OLC, is identified by a unique three number accountability code. Authorized staff may search the agency Integrated Management System (IMS) or the FOIA Tracking System (FTS) by this three digit code to ascertain the FOIA component with responsibility for the misdirected request. The FOIA component that received the misdirected FOIA will forward it to the correct FOIA component in the FTS, or by fax or email, and notify the requester that the misdirected request has been routed to the correct office and the name of a contact person.
6. If your agency is already handling the routing of misdirected requests in an efficient manner, please note that here and describe your process for these requests.
Yes, EEOC is handling the routing of misdirected requests in an efficient manner. See 5. above.
7. Does your agency notify requesters of the mediation services offered by the Office of Government Information Services (OGIS) at the National Archives and Records Administration?
Yes. EEOC notifies requesters of the mediation services offered by the OGIS in its determination in response to an appeal, and at 29 C.F.R. 1610.11(g) of its FOIA regulations.
8. When assessing fees, does your agency provide a breakdown of how FOIA fees were calculated and assessed to the FOIA requester? For example, does your agency explain the amount of fees attributable to search, review, and duplication?
Yes EEOC does.
9. If estimated fees estimates are particularly high, does your agency provide an explanation for the estimate to the requester?
EEOC provides the requester with an explanation of how the fee estimate was calculated.
10. If there are any other steps your agency has under-taken to ensure that your FOIA system operates efficiently and effectively such as conducting self-assessments to find greater efficiencies, improving search processes, eliminating redundancy, etc. please describe them here.
EEOC is in the process of configuring off the shelf FOIA software to meet its requirements, and to enable it to process Annual and Quarterly FOIA reports more efficiently. This system will also enable EEOC to run reports to conduct self-assessments. EEOC has created a new search request form for use when requesting responsive records from the various headquarter offices. Additionally, EEOC expects to launch the recently revised more customer-friendly FOIA webpage by March 16, 2015.
Both the President and Attorney General focused on the need for agencies to work proactively to post information online without waiting for individual requests to be received.
Please answer the following questions to describe the steps your agency has taken to increase the amount of material that is available on your agency websites. In addition to the questions below, you should also describe any additional steps taken by your agency to make and improve proactive disclosures of information.
1. Does your agency have a distinct process or system in place to identify records for proactive disclosure? If so, please describe your agency's process or system.
EEOC does not have a formalized distinct process or system in place to identify records for proactive disclosure.
2. Does your process or system involve any collaboration with agency staff outside the FOIA office? If so, describe this interaction.
Yes, the process used involves collaboration with agency staff in all headquarters offices, especially the Offices of Review and Information Policy, Information Technology, and Congressional and Legislative Affairs. OLC is dependent on these offices to upload information such as informal discussion letters, non-confidential aggregated data, brochures, or other records to the public web site. We also depend on all headquarters offices, including Commissioners, to timely respond to our requests for records responsive to FOIA requests.
EEOC is in the final stages of revamping its FOIA website to make a greater range of material proactively available to the public in a more customer-friendly manner. Most headquarters offices are receptive to requests that they consider making more information about the work of their offices publicly available.
3. Describe your agency's process or system for identifying "frequently requested" records that should be posted online.
Frequently requested records are identified either when the records are actually requested three or more times, or when EEOC anticipates that certain records will be requested by more than three requesters.
Additionally, FOIA staff monitors items such as quarterly reports of agency activity, agency newsletters, office announcements, press releases, matters appearing on the agency home page, as well as the responses to FOIA requests for non-confidential statistical data arrays and other records to proactively disclose. We proactively upload ADA informal discussion letters, brochures on each statute enforced by EEOC, aggregated EEO data in electronic format, and a quarterly FOIA log of requests received and processed. The FOIA Log provides non-confidential information about each request, including requests for charge files.
4. Provide examples of materials that your agency has proactively disclosed during the past reporting year, including links to the posted material.
Some examples of materials that EEOC has proactively disclosed during the past reporting year include guidance at www.eeoc.gov/eeoc/laws/guidance/subject.cfm; informal discussion letters at www.eeoc.gov/eeoc/foia/letters/index.cfm; memoranda of understanding at www.eeoc.gov/laws/mous/index.cfm; and the Digest of EEO Law at www.eeoc.gov/federal/digest/index.cfm and www.eeoc.gov/eeoc/newsroom/index.cfm.
5. If there are any other steps your agency has taken to increase proactive disclosures, please describe them here.
EEOC is in the final stages of revamping its FOIA website to make a greater range of material available to the public in a more customer friendly manner. Most headquarters offices have been receptive to requests that they consider making more information about the work of their office publicly available.
A key component of the President's FOIA Memorandum was the direction to "use modern technology to inform citizens about what is known and done by their Government." In addition to using the internet to make proactive disclosures, agencies should also be exploring ways to utilize technology in responding to requests.
Please answer the following questions to describe how your agency is utilizing technology to improve its FOIA administration and the public's access to information. You should include any additional information that describes your agency's efforts in this area.
1. Can a member of the public track the status of his or her request or appeal electronically?
Yes, the public can track a request or appeal that is submitted online.
2. If yes, how is this tracking feature provided to the public? For example, is it being done through the regular posting of status logs, an online portal, or through another medium?
EEOC provides this feature to the public through an online portal.
3. If your agency does provide online tracking, please describe the information that is provided to the requester through this feature. For example, some online tracking features may tell the requester whether the request is "open" or "closed," while others will provide further details throughout the course of processing, such as "search commenced" or "documents currently in review."
The following items are provided in the tracking system: date request was received, tracking number assigned, FOIA contact, misdirected to (office name), acknowledgement letter issued and date, date determination is due, extension taken and date, date tolled, date given to supervisor for review, date determination letter issued, and date request/appeal is closed.
4. If your agency does provide online tracking for requesters, does this feature also provide and estimated date of completion.
Yes, the EEOC FOIA Tracking System provides the estimated date of completion.
5. If your agency does not provide online tracking of requests or appeals is your agency taking steps to establish this capability? If not, please explain why.
See EEOC response to 4 above.
6. Beyond posting new material, is your agency taking steps to make the posted information more useful to the public, especially to the community of individuals who regularly access your website?
Steps can include soliciting feedback on the content and presentation of posted material, improving search capabilities on your agency website, posting material in open formats, making information available through mobile applications, providing explanatory material, etc.
Yes, EEOC is taking steps to make the posted information more useful to the public.
7. If yes, please provide examples of such improvements.
EEOC solicits feedback on the content and presentation of its Open Government webpage, and has posted 92 data sets in open format.
If your agency is already posting material in its most useful format, please describe these efforts.
EEOC has posted 92 data sets in open format at http://catalog.data.gov/organization/eeoc-gov.
8. Have your FOIA professionals interacted with other agency staff (such as technology specialists or public affairs or communications professionals) in order to identify if there are any new ways to post agency information online?
Yes, FOIA professionals do interact with technology specialists and public affairs staff to identify and discuss ways to post agency information online.
9. Did your agency use any means to publicize or highlight important proactive disclosures for public awareness? If yes, describe those efforts.
For example, this can be done through social media or with the offering of e-mail subscription services.
No, EEOC has not.
10. Has your agency encountered challenges that make it difficult to post records you otherwise would?
11. If so, please briefly explain what those challenges are.
There are challenges such as limited web staff.
12. Beyond using technology to redact documents, is your agency taking steps to utilize more advanced technology to facilitate overall FOIA efficiency, such as improving record search capabilities, utilizing document sharing platforms for consultations and referrals, or employing software that can sort and de-duplicate documents? If yes, describes the technological improvements being made.
After FOIAXpress is implemented, other technology will receive consideration, subject to available Commission resources.
13. Are there additional tools that could be utilized by your agency to create further efficiencies?
Yes, there are additional tools that could be utilized to further efficiency. They include: improving the networks and developing or expanding online sharing platforms to move responsive records between offices and to collaborate with offices on the FOIA process; obtaining software that can sort and de-duplicate; and on a less technical level, dedicated high power, large volume scanners and copiers. Adequate staffing of the intake and logging function in each FOIA component would also increase efficiency.
14. Did your agency successfully post all four quarterly reports for Fiscal Year 2014?
Yes, it did.
Please see OIP's guidance for posting of quarterly reports to ensure that your agency is following all required steps (including using the correct file type and URL structure) so that your quarterly reports are properly appearing on FOIA.gov. (If your reports are posted to your website, but do not appear on FOIA.gov, please contact OIP in order to resolve the issue.)
15. If your agency did not successfully post all quarterly reports with information appearing on FOIA.gov, please explain why and provide your agency's plan for ensuring that such reporting is successful in Fiscal Year 2015.
16. Do your agency's FOIA professionals use e-mail or other electronic means to communicate with requesters whenever feasible? See OIP Guidance, The Importance of Good Communication with FOIA Requesters 2.0: Improving Both the Means and the Content of Requester Communications." (Nov. 22, 2013). If yes, what are the different types of electronic means are utilized by your agency to communicate with requesters?
EEOC communicates with requesters electronically by email, fax and Internet. Each FOIA component has its own FOIA email address that is published on the EEOC website.
17. If your agency does not communicate electronically with requesters as a default, are there any limitations or restrictions for the use of such means? If yes, does your agency inform requesters about such limitations? See id.
The President and the Attorney General have emphasized the importance of improving timeliness in responding to requests. This section of your Chief FOIA Officer Report addresses both time limits and backlog reduction. Backlog reduction is measured both in terms of numbers of backlogged requests or appeals and by looking at whether agencies closed their ten oldest requests, appeals, and consultations. For the figures required in this Section, please use the numbers contained in the specified sections of your agency's 2014 Annual FOIA Report and, when applicable, your agency's 2013 Annual FOIA Report.
Simple Track: Section VII.A of your agency's Annual FOIA Report, entitled "FOIA Requests - Response Time for All Processed Requests," includes figures that show your agency's average response times for processed requests. For agencies utilizing a multi-track system to process requests, there is a category for "simple" requests, which are those requests that are placed in the agency's fastest (non-expedited) track, based on the low volume and/or simplicity of the record requested.
1. Does your agency utilize a separate track for simple requests?
No. EEOC's current FOIA Tracking System is not capable of capturing simple and complex requests. All requests, except expedited, are tracked in the "simple" track.
2. If so, for your agency overall in Fiscal Year 2014, was the average number of days to process simple requests twenty working days or fewer.
3. Please provide the percentage of requests processed by your agency in Fiscal Year 2014 that were placed in your simple track.
4. If your agency does not track simple requests separately, was the average number of days to processes all non-expedited requests twenty working days or fewer?
Yes. The average number of days to process all non-expedited requests was 16.87 days.
Backlogs: Section XII.A of your agency's Annual FOIA Report, entitled "Backlogs of FOIA Requests and Administrative Appeals" shows the numbers of any backlogged requests or appeals from the fiscal year. You should refer to these numbers from your Annual FOIA Reports for both Fiscal Year 2013 and Fiscal Year 2014 when completing this section of your Chief FOIA Officer Report.
5. If your agency had a backlog of requests at the close of Fiscal Year 2014, did that backlog decrease as compared with the backlog reported at the end of Fiscal Year 2013?
If not, explain why and describe the causes that contributed to your agency not being able to reduce its backlog. When doing so, please also indicate if any of the following were contributing factors:
The EEOC backlog at the end of Fiscal Year 2014 increased by five backlogged requests as compared with the backlog reported at the end of Fiscal Year 2013. This slight increase in the request backlog can be attributed to loss of staff.
6. If you had a request backlog, please report the percentage of requests that make up the backlog out of the total number of requests received by your agency in Fiscal Year 2014.
To calculate your agency's percentage, you must divide the number of backlogged requests reported in Section XII.A. of your Fiscal Year 2014 Annual FOIA Report by number of requests received in Fiscal Year 2014, which can be found in Section V.A. of your Annual FOIA Report. Once divided, you can multiply that number by 100 to get the percentage.
The percentage of requests that make up the backlog out of the total number of requests received by EEOC in Fiscal Year 2014 is 1.13%.
7. If your agency had a backlog of appeals at the close of Fiscal Year 2014, did that backlog decrease as compared with the backlog reported at the end of Fiscal Year 2013?
If not, explain why and describe the causes that contributed to your being able to reduce its backlog. When doing so, please also indicate if any of the following were contributing factors:
The EEOC backlog of appeals at the end of Fiscal Year 2014 backlog increased to three as compared with the zero backlog reported at the end of Fiscal Year 2013 due to the complexity of requests.
8. If you had an appeal backlog, please report the percentage of appeals that makeup the backlog out of the total number of appeals received by your agency in Fiscal Year 2014. If your agency did not receive any appeals in Fiscal Year 2014 and/or has no appeal backlog, please answer with "N/A."
To calculate your agency's percentage, you must divide the number of backlogged appeals reported in Section XII.A. of your Fiscal Year 2014 Annual FOIA Report by number of appeals received in Fiscal Year 2014, which can be found in Section V.A. of your Annual FOIA Report. Once divided, you can multiply that number by 100 to get the percentage.
The percentage of appeals that make up the backlog out of the total number of appeals received by EEOC in Fiscal Year 2014 is 1.02%.
9. In the 2014 guidelines for Chief FOIA Officer Reports, any agency with a backlog of over 1,000 requests in Fiscal Year 2013 was asked to provide a plan for achieving backlog reduction in the year ahead. Did you agency implement a backlog reduction plan last year? If so, describe your agency's efforts in implementing this plan and note if your agency was able to achieve backlog reduction in Fiscal Year 2014?
EEOC did not have a backlog of over 1,000 requests in Fiscal Year 2013.
10. If your agency had a backlog of more than 1,000 requests in Fiscal Year 2014, what is your agency's plan to reduce this backlog during Fiscal Year 2013?
EEOC did not have a backlog of more than 1,000 requests in Fiscal Year 2014.
Status of Ten Oldest Request, Appeals and Consultations: Section VII.E, entitled "Pending Requests- Ten Oldest Pending Requests," Section VI.C.(5), entitled "Ten Oldest Pending Administrative Appeals," and Section XII.C. , entitled "Consultations on FOIA Requests - Ten Oldest Consultations Received from Other Agencies and Pending at Your Agency, "show the ten oldest pending request, appeals, and consultations. You should refer to these numbers from your Annual FOIA Reports for both Fiscal Year 2013 and Fiscal Year 2014 when completing this section of your Chief FOIA Officer Report.
11. In Fiscal Year 2014, did your agency close the ten oldest requests that were reported pending in your Fiscal Year 2013 Annual FOIA Report?
EEOC closed the ten oldest requests that were reported pending in our Fiscal Year 2013 Annual FOIA Report.
12. If no, please provide the number of these requests your agency was able to close by the end of the fiscal year, as listed in Section VII.E of your Fiscal Year 2013 Annual FOIA Report. If you had less than ten total oldest requests to closed, please indicate that.
For example, if you only had seven requests listed as part of your "ten oldest" in Section VII.E and you closed six of them, you should note that you closed six out of seven "oldest" request.
13. Of the requests your agency was able to close from your ten oldest, please indicate how many of these were closed because the request was withdrawn by the requester. If any were closed because the request was withdrawn, did you provide any interim responses prior to the withdrawal?
None of the ten oldest requests was closed because the requester withdrew the request.
14. Fiscal Year 2014, did your agency close the ten oldest appeals that were reported in your Fiscal Year 2013 Annual FOIA Report?
EEOC closed the 10 oldest appeals that were reported in our Fiscal Year 2013 Annual FOIA Report.
15. If no, please provide the number of these appeals your agency was able to close by the end by the end of the fiscal appeals to close, please indicate that.
TEN OLDEST CONSULTATIONS For example, if you only had seven appeals listed as part of your "ten oldest" in Section VII.C.(5) and closed six of them, you should note that you closed six out of seven "oldest" appeals.
16. In Fiscal Year 2014, did your agency close the ten oldest consultations that were reported pending in your Fiscal Year 2013 Annual FOIA Report?
EEOC had no consultations in Fiscal Year 2013.
17. If no, please provide the number of these consultations your agency was able to close by the end of the fiscal year, as listed in Section XII.C of your Fiscal Year 2013 Annual FOIA Report. If you had less than ten oldest consultations to close, please indicate that.
For example, if you only had seven consultations listed as part of your "ten oldest" in Section XII.C. and you closed six of them, you should note that you closed six out of seven "oldest" consultations.
18. Briefly explain any obstacles your agency faced in closing its ten oldest requests, appeals, and consultations from Fiscal Year 2013.
19. If your agency was unable to close any of its oldest requests because you were waiting to hear back from other agencies on consultations you sent, please provide the date the request was initially received by your agency, the date when your agency sent the consultation, and the date when you last contacted the agency where the consultation was pending.
20. If your agency did not close its ten oldest pending requests, appeals, or consultations, please provide a plan describing how your agency intends to close those "ten oldest" requests, appeals, and consultations during Fiscal Year 2015.
21. Does your agency have a system in place to provide interim responses to requesters when appropriate? See OIP Guidance, "The Importance of Good Communication with FOIA Requesters." (Mar. 1, 2010)
EEOC has a system in place to provide interim response to requesters when appropriate.
22. If your agency had a backlog in Fiscal Year 2014, please provide an estimate of the number or percentages of cases in the backlog where a substantive, interim response was provided during the fiscal year, even though the request was not finally closed.
A rough estimate of the number of cases in the backlog where a substantive interim response was provided would be 50% or 97.5 requests.
Use of the FOIA's Law Enforcement Exclusions
Did your agency invoke a statutory exclusion, 5 U.S.C. § 552(c)(1), 2, 3, during Fiscal Year 2014?
No. EEOC did not invoke law enforcement exclusion during Fiscal Year 2014.
If so, please provide the total number of times exclusions were invoked.
Out of all the activities undertaken by your agency since March 2014 to increase transparency and improve FOIA administration, please briefly describe here at least one success story that you would like to highlight as emblematic of your agency's efforts. The success story can come from any one of the five key areas. As noted above, these agency success stories will be highlighted during Sunshine Week by OIP. To facilitate this process, all agencies should use bullets to describe their success story and limit their text to a half page. The success story is designed to be a quick summary of key achievements. A complete description of all your efforts will be contained in the body of your Chie FOIA Officer Report.