===== PDF PAGE 82 ===== RESOLUTION NO. 26-R-0078 A RESOLUTION APPROVING A FOIA POLICY FOR THE CITY OF WEST CHICAGO WHEREAS, the City of West Chicago (“City”) is a municipal corporation established and existing under the laws of the State of Illinois pursuant to the Illinois Municipal Code, 65ILCS 5/1-1-1 et seq.; and WHEREAS, further, the City is a home-rule municipality pursuant to Article VII, Section 6, of the Constitution of the State of Illinois of 1970, and, subject to the specific limitations of Illinois law, may exercise any power and perform any function pertaining to its government and affairs; and WHEREAS, Subsection (h) of Section 3 of the Freedom of Information Act, 5 ILCS 140/3(h), authorizes the City to promulgate rules and regulations in conformity with the provisions of Section 3 of the Freedom of Information Act pertaining to the availability of records and procedures to be followed; and WHEREAS, the City Council determined that it is in the best interest of the City and the public to approve and implement the Policy; NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of West Chicago, duly assembled in regular session, as follows: SECTION 1: Recitals. The recitals listed above are incorporated in this Resolution as if fully set forth in this Resolution. SECTION 2: Approval of Policy. The City Council hereby approves the Policy in the form attached to this Resolution as Exhibit A. SECTION 3: Effective Date. This Resolution shall be in full force and effect following its passage and approval in the manner provided by law. APPROVED this 8th day of September, 2026. AYES: ______ NAYS: ______ ABSENT: ______ ABSTAIN: ______ ________________________________________ Mayor Daniel Bovey ATTEST: __________________________________ Executive Office Manager, Valeria Biggerstaff Item # 7.I. ===== PDF PAGE 83 ===== Exhibit A FOIA POLICY ===== PDF PAGE 84 ===== FOIA POLICY 1 2026 CITY OF WEST CHICAGO FREEDOM OF INFORMATION ACT POLICY This Policy ("Policy"), adopted pursuant to Section 3(h) of the Illinois Freedom of Information Act ("FOIA" or "Act") outlines the City of West Chicago's ("City") procedures for compliance with FOIA, by the City and any person requesting public records from the City ("Requester"). The City will respond to written requests for inspection, copying, or certification of public records in accordance with the FOIA, this Policy, and other applicable law. I. REQUESTS FOR PUBLIC RECORDS A. Responsibilities of FOIA Officer The City's Freedom of Information Officer ("FOIA Officer") is the person administratively responsible for receiving and processing all requests to inspect, copy, or certify public records under the Act and this Policy. The FOIA Officer is the person with authority on behalf of the City to grant or deny requests, in whole or in part, to inspect, copy, to issue timely written responses to FOIA requests, to certify public records filed pursuant to the Act and this FOIA Policy, and to extend the time for response. The City may designate one or more FOIA officers. The FOIA Officer is also responsible for coordinating the City's reasonably diligent search for records responsive to FOIA requests, including conferring with all relevant departments and subdivisions of the City, and their officials, officers, and employees, in furtherance of timely searching for, identifying, and producing records responsive to a FOIA request to the FOIA Officer. B. FOIA Officer Training As a necessary prerequisite to serving as a FOIA Officer, all FOIA Officers appointed by the City must complete the electronic training curriculum developed and administered by the Illinois Attorney General's Public Access Counselor ("PAC") within 30 days of assuming the position. Additionally, FOIA Officers must successfully complete an annual training program pursuant to Section 3.5(b) of the Freedom of Information Act. C. Requests All requests to inspect, copy, or certify public records must be in writing and exclusively directed to: FOIA Officer, foia@westchicago.org 475 Main Street, West Chicago, Illinois 60185. ("Office"). Written requests may be submitted to the City's FOIA Officer via electronic mail ("e-mail"), personal delivery, mail, fax, or other means available to the City in accordance with Section 3(c) of the Act. The City will not honor oral requests to inspect or copy public records. FOIA requests will not be accepted through any of the City's social media sites, including but not limited to Facebook. Failure to submit written FOIA requests in accordance with the Act and this Policy, including submitting FOIA requests to City officials or employees who are not expressly designated as ===== PDF PAGE 85 ===== FOIA POLICY 2 2026 FOIA officers in this Policy or on the FOIA page of the City's website, will render your FOIA request invalid. D. Receipt of Requests The City has established an e-mail address dedicated to FOIA requests: foia@westchicago.org which is monitored during business hours by the FOIA Officer. A FOIA request sent during business hours on a business day will be deemed received on the following business day by the City. An e-mailed FOIA request submitted to the City's FOIA Officer (1) after the close of business on a weekday, (2) on an Illinois holiday, or (3) on a weekend, will be deemed received by the City on the next business day, regardless of date of transmittal. E. Format of Requests As a cybersecurity measure, FOIA does not require the City to open electronically attached files (e.g., PDF files) or hyperlinks to view or access details of a request. If the City receives a request that would require it to open hyperlinks or attached files, the City's FOIA Officer will, within 5 business days of receipt, notify the Requester of the requirement that the entirety of an electronic request must appear within the body of the electronic submission. If the Requester fails to resubmit a proper request, the City may deny the request pursuant to Section 3(c) of FOIA. F. Robot or Artificial Intelligence (AI) Requests Within 5 business days after its receipt of the request, if the City's FOIA Officer has a reasonable belief that a request was not submitted by a person, the City's FOIA Officer may require the requester to verify orally or in writing that the requester is a person. The deadline for the City to respond to the request will be tolled until the requester verifies that the requester is a person. If the requester fails to verify that they are a person within 30 days after the City's FOIA Officer requests such a verification, then the City may deny the FOIA request pursuant to Section 3(j) of FOIA. G. Processing FOIA Requests Upon discovery and receipt by the City, all FOIA requests for inspection or copying of public records must be immediately forwarded to the City's FOIA Officer or their designee(s) in accordance with Section 3(c) of the Act. Upon receiving a request for a public record, the FOIA Officer will note the request with the date and time of receipt by the City, compute the day on which the response is due and note the date on which the response is due on the request. The FOIA Officer will maintain an electronic or paper copy of the request, including all documents submitted with the request, until the request has been complied with or denied. The FOIA Officer will create a file for the retention of the original request, a copy of the response, a record of written communications with the Requester, and a copy of other communications related to the request. Upon receiving a request for public records that may be in the possession or custody of one or more City departments, the FOIA Officer will timely forward the request to personnel within the appropriate department, who must timely consult with relevant persons in their department, or relevant persons in other departments, to conduct a reasonably diligent search for any records potentially responsive to the parameters and scope of the particular FOIA request. Any records ===== PDF PAGE 86 ===== FOIA POLICY 3 2026 responsive to a FOIA request must be timely forwarded to the FOIA officer. If the department needs assistance or guidance in conducting a search for responsive records, please consult the City Attorney. If a department anticipates or suspects that the department will not be able to locate records responsive to a FOIA request within 5 business days after receipt, the department must timely notify the FOIA officer, who will draft and timely send a written notice extending the time to comply to the FOIA request by at least 5 additional business days, or for a longer period if agreed to in writing between the FOIA Officer and the Requester, for any of the applicable reasons specified in the Act. H. Supplemental Requests Supplemental, amended, narrowed, or additional requests to inspect, copy, or certify public records will not relate back to the time of receipt of the initial request. Supplemental, amended, narrowed, or additional requests will be considered new requests for purpose of determining all applicable time periods. I. FOIA Request Must Seek Identifiable Public Records All FOIA requests must seek identifiable public records in the possession or custody of the City, not general information, data, or statistics. J. Creation of New Records FOIA does not require the City to create, maintain, or otherwise prepare new records that do not currently exist in the City's possession or custody at the time of receiving the FOIA request. K. Interpretations or Advice; Answering Questions The FOIA Officer will not interpret or advise a Requester about the meaning or significance of any public records. The FOIA officer will also not answer any questions posed by a FOIA Requester. If a FOIA request is vague, ambiguous, categorical, or otherwise confusing, the FOIA Officer may contact the Requester, if necessary, to clarify the Request. The FOIA Officer may seek advice on appropriate responses from the City's Attorney, and seek advisory opinions from the PAC as specified below. L. Purpose of Request The City will not require a requester to specify the purpose for their request, except to determine whether the records are requested for a commercial purpose or whether to grant a request for a fee waiver as authorized by the Act or this Policy. II. RESPONSES TO REQUESTS A. Time for Response Except as otherwise provided in the Act, the City will respond to a FOIA request filed pursuant to Section I of this FOIA Policy within 5 business days after the request is received by the City, unless the City extends the time to respond to the request pursuant to the Act. The time periods for complying with or denying a FOIA request to inspect or copy public records, in whole or in part, shall not apply to requests for records made for a commercial purpose, requests made by a ===== PDF PAGE 87 ===== FOIA POLICY 4 2026 recurrent requester, or voluminous requests, as defined in the Act. All responses and decisions required to be issued by the City pursuant to the Act or this FOIA Policy will be conclusively deemed to have been given as of the date of emailing to the requester's email address, personal delivery to the requester or to the residence of the requester or, if mailed, as of the date of mailing, regardless of the date of actual receipt by the requester. B. Responding to Requests The FOIA Officer may consult with the City's Attorney before responding to any request to inspect, copy, or certify public records. The FOIA Officer may also consult with the City's Attorney if the FOIA Officer believes it would be beneficial to the City to seek an advisory opinion from the PAC regarding whether a request should be complied with, extended, or denied (in whole or in part). C. Requests for Records to be Used for a Commercial Purpose The time lines specified above in Section II.A do not apply to requests for records to be used for commercial purposes, as defined in Section 2(c-10) of the Act. The City will respond to a request for records to be used for a commercial purpose within 21 business days after receipt. In accordance with Section 3.l(a) of the Act, the response will (i) provide the requester an estimate of the time required by the City to provide the records requested and an estimate of the fees to be charged, which the City may require the requester to pay in full before copying the requested documents, (ii) deny the request, in whole or in part, pursuant to applicable exemptions; (iii) notify the requester that the request is unduly burdensome and extend an opportunity to confer with the requester in writing to attempt to reduce the request to manageable proportions, or (iv) provide the records requested. Unless the records are exempt from disclosure, the City will comply with a request within a reasonable period of time considering the size and complexity of the request, giving priority to records requested for non-commercial purposes. It is a violation of the Act for a person to knowingly obtain public records for a commercial purpose without disclosing the commercial purpose of the request. D. Form of Response 1. Disclosure of Public Records. (a) If the FOIA Officer determines that the Act requires disclosure of all or any part or portion of any public records in response to a FOIA request, the FOIA Officer will notify the Requester in writing of that determination. (b) Except as otherwise specifically authorized by the FOIA Officer, only City personnel will be permitted to search City files, records, or storage areas; to use City equipment; to make copies of City public records; or to disclose City public records. Original public records may not be removed from the City's Office at any time. (c) Public records requested under the Act may be inspected, or copies of public records obtained, during business hours at the City Office. Because space is limited, requesters must make arrangements in advance with the ===== PDF PAGE 88 ===== FOIA POLICY 5 2026 FOIA Officer for a specific appointment to inspect public records at the City Office. (d) Requests for the reproduction of any public records that are tape recordings will be honored in accordance with the provisions of the Act and this FOIA Policy. (e) The requester must pay all copying, certification, and postage fees m advance of receiving copies of any public records. (f) When requested in electronic format, records will be furnished in the electronic format specified by the Requester, if feasible. If it is not feasible to furnish the records in the requester's specified electronic format, then the City will furnish the record in the format in which it is maintained by the City, or in paper format at the option of the requester. 2. Extension of Time. If the FOIA Officer determines that additional time is needed to respond to a request for any one or more reasons authorized by Section 3(e) of the Act, the FOIA Officer will notify the Requester in writing of that determination, the reasons requiring the extension, and the length of the extension. The requester and the City may also agree in writing to extend the time for compliance for a period to be determined by the parties. 3. Repeated Requests. Repeated requests from the same person for the same records that are unchanged or identical to records previously provided or properly denied under the Act will be deemed unduly burdensome in accordance with Section 3(g) of the Act. 4. Recurrent Requests. Requests received from any person or persons that, in the 12 months immediately preceding the request, have submitted (i) 50 or more requests for records, (ii) 15 or more requests for records within a 30-day period, or (iii) 7 or more requests for records within a 7-day period, excluding requests made by news media and non-profit, scientific, or academic organizations for purposes outlined in Section 2(g) of the Act, will be reviewed as a recurrent request and treated in the following manner: Within 5 business days of receiving a recurrent request, the FOIA Officer will notify the requester: (i) that the City is treating the request as a request under section 2(g) of the Act, (ii) of the reasons why the City is treating the request as a request under section 2(g) of the Act, (iii) that the City will send an initial response within 21 business days after receipt of the request; and (iv) of the following categories of initial responses that may be asserted pursuant to section 3.2(a) of the Act. Within 21 business days after receipt of a recurrent request, the FOIA Officer will issue one of the following initial responses: (i) Provide to the requester an estimate of the time required by the City to provide the records requested and an estimate of the fees to ===== PDF PAGE 89 ===== FOIA POLICY 6 2026 be charged, which the City may require the requester to pay in full before copying the requested documents; (ii) Deny the request, in whole or in part, pursuant to applicable FOIA exemptions; (iii) Notify the requester that the request is unduly burdensome and extend an opportunity to the requester to confer with the FOIA Officer in writing to attempt to reduce the request to manageable proportions; and/or (iv) Provide the records requested. Unless the requested records are exempt from disclosure, the FOIA Officer will comply with the request within a reasonable period considering the size and complexity of the request. 5. Voluminous Requests. Requests received from any person or persons that (i) includes more than 5 individual requests for more than 5 different categories of records in a period of 20 business days or (ii) requires the compilation of more than 500 letter or legal-sized pages of public records unless a single record exceeds 500 pages, excluding requests made by news media and non-profit, scientific, or academic organizations for purposes outlined in Section 2(h) of the Act, will be reviewed as a voluminous request and treated in the following manner: Within 5 business days of receiving a voluminous request, the FOIA Officer will notify the requester: (i) that the City is treating the request as a request under section 2(h) of the Act, (ii) the reasons why the City is treating the request as a request under section 2(h) of the Act, and (iii) that the requester has 10 business days to amend their request in such a way that it is no longer a voluminous request. Within 5 business days after the receipt of the Voluminous Requester Notice or within 5 days from the last day for the requester to amend their request, the FOIA Officer will provide one of the following initial responses: (i) Provide to the requester an estimate of the fees to be charged, which the City may require the requester to pay in full before copying the requested documents; (ii) Extend the time for response by not more than 10 business days from the final day for the requester to respond to this notice. (iii) Deny the request, in whole or in part, pursuant to applicable FOIA exemptions; (iv) Notify the requester that the request is unduly burdensome and extend an opportunity to the requester to confer with the FOIA ===== PDF PAGE 90 ===== FOIA POLICY 7 2026 Officer in writing to attempt to reduce the request to manageable proportions; and/or (v) Provide the records requested. 6. Unduly Burdensome Requests. (a) If the FOIA Officer determines that (1) a request seeks all records falling within a category, that the request is vague or ambiguous, or responding to the request will otherwise unduly burden or interfere with City operations; (2) that there is no way to narrow the request to manageable proportions; and (3) the City's burden of complying with the request outweighs the public interest of complying with the request, the FOIA Officer will notify the requester in writing that their request is deemed unduly burdensome, the reasons supporting that determination, and the right of the requester to confer with the FOIA Officer in writing in an effort to narrow the request to manageable proportions. (b) If the requester agrees to confer with the FOIA Officer regarding narrowing the burdensome request to more manageable proportions, and the narrowed request is no longer deemed burdensome by the FOIA Officer, then the FOIA Officer will respond to the narrowed request within five business days following the date of receiving the narrowed request in writing, or within the extension period if the City's FOIA Officer extends the time to respond to the narrowed request. The response may take any form specified in this Section 11.D. (c) If the requester does not agree to confer with the FOIA Officer regarding narrowing the burdensome request to more manageable proportions, or the FOIA Officer determines that the narrowed request remains unduly burdensome, the FOIA Officer may deny the request as unduly burdensome. 7. Non-Responsive Information in Records. If the City's search in response to a FOIA request identifies records, or part thereof, that are not responsive to the parameters of the FOIA request, the City may elect to withhold those records, or part thereof from disclosure. Redacting or withholding non-responsive records, or parts thereof, is not a "redaction" under FOIA, and that information is not deemed improperly withheld under the Act. 8. Redacting Information. When a request is made to inspect or copy a public record that contains information that is exempt from disclosure, but also contains information that is not exempt from disclosure, the FOIA Officer may elect to redact the exempt information, and will make available the remaining nonexempt information available for inspection or copying. 9. Denial. If the FOIA Officer determines that all or part of any public records request filed pursuant to Section I of this FOIA Policy are exempt from disclosure under the Act or this FOIA Policy, the FOIA Officer will notify the Requester in ===== PDF PAGE 91 ===== FOIA POLICY wntmg of that determination, including: (i) a detailed factual basis for the application of any exemption claimed; (ii) the reason for the denial; (iii) the name and position of the person responsible for the denial; (iv) the requester's right to judicial review and review by the Public Access Counselor, including the Public Access Counselor's address and phone number; and (v) the requester's right to seek judicial review of the denial pursuant to Section 11 of the Act ("Notice of Deniaf'). In the event that a request is denied on the grounds that the records are exempt under Section 7 or Section 7.5 of the Act, the notice of denial will specify the exemption claimed to authorize the denial and the specific reasons for the denial, including a detailed factual basis and a citation to supporting legal authority. 10. Records of Denials. Copies of all notices of denial shall be retained by the FOIA Officer in a single central office file that is open to the public and indexed according to the type of exemption asserted and, to the extent feasible, according to the types of records requested. E. Records Available on the City's Website Pursuant to Section 8.5 of the Act, the City is not required to copy a public record that is published on the City's website, and in response to a request may notify a requester that the record is available online and direct the requester to the website location where the record can be reasonably accessed (e.g., through a link to the relevant portion of the website). However, if a requester is unable to reasonably access the record online after being directed to the website, the requester may re-submit their request for the record stating their inability to reasonably access the record online, and the record will be made available for inspection or copying. F. Failure to Respond If a FOIA officer does not respond to a request properly filed under Section 1 of this FOIA policy, the request is deemed denied. III. INTERACTION WITH PUBLIC ACCESS COUNSELOR A. The City's Request for an Advisory Opinion The Mayor or the City Attorney may request the PAC to issue an advisory opinion regarding complying with the Act. B. Receipt of Request for Review If the City receives a further inquiry letter from the Illinois Public Access Counselor ("PAC") regarding a request for review alleging violations of FOIA, the City may respond to the PAC within 7 business days after receipt of the further inquiry letter, and will otherwise fully cooperate with the PAC in accordance with Section 9.5 of the Freedom of Information Act. Records provided to t PAC under a claim of confidentiality for the purposes of facilitating their review and resolution of a request for review will not be disclosed to the public, including ===== PDF PAGE 92 ===== FOIA POLICY 9 2026 to a Requester, by the PAC. The City may furnish affidavits or other records concerning any matter germane to the review. C. Mediation In the event the PAC chooses to resolve a request for review by mediation, the City will cooperate with the PAC. D. Response to PAC Binding Opinions Upon the receipt of a binding opinion from the PAC concluding that the City has violated the Act, the City, at its discretion, may either take necessary action as soon as practical to comply with the directive of the opinion or may file an administrative review action pursuant to Sections 9.5(f) and 11.5 of the Act. IV. REVIEW OF DENIAL A. Review by Public Access Counselor If a non-commercial requester disagrees with a Notice of Denial, then the non-commercial requester may file a request for review with the PAC not later than 60 days after the date of the Notice of Denial. The request for review by the PAC must be in writing, signed by the non- commercial requester, and include a copy of the request and the Notice of Denial and any other response from the City. Commercial Requesters, or persons whose request for records was treated by the FOIA Officer as a request for a commercial purpose under this FOIA Policy, may not file a request for review with regard to the FOIA Officer's basis for denial. Commercial requesters may only file a request for review for the limited purpose of reviewing whether the FOIA Officer properly determined the request was made for a commercial purpose. A Requester treated as a voluminous requester may only file a request for review with the PAC for the limited purpose of reviewing whether the FOIA Officer properly determined that the request was a voluminous request. B. Judicial Review A requester whose FOIA request is denied may file suit for injunctive or declaratory relief in the Circuit Court of the Eighteenth Judicial Circuit. V. FEES A. Fees Established Unless fees are waived or reduced pursuant to Section V.D below, each requester must pay the following fees for copying, certification, and mailing of public records, which the City has determined to be reasonably calculated to reimburse its actual cost for reproducing and certifying public records and for the use, by any person, of the equipment of the City to copy records: 1. Copies - letter or legal $.15 per side. ===== PDF PAGE 93 ===== FOIA POLICY 10 2026 2. Copies - color or oversize 3. Certification 4. Mailing Actual cost of reproduction. $1.00 per document plus copy cost. Actual cost of postage. 5. Statutory Fees Fees otherwise fixed by statute will be imposed at the rates authorized by statute. 6. Recording Media (flash drive, CD, etc) -- Actual cost to the City However, there will be no charge for the first 50 pages of letter or legal size black and white copies for a requester, except for requests for commercial purposes. When the services of an outside vendor are required to copy a public record, the actual reasonable charges of the outside vendor will be the fees for copying such records, notwithstanding the fees stated above. If the City provides records in response to a request but fails to respond within the requisite periods, copies will be provided free of charge in accordance with Section 3(d) of the Act. B. Fees for Commercial Requests Commercial requesters may be subject to an additional fee of $10.00 for each hour spent by City personnel in searching for and retrieving a requested record. No fee will be charged for the first 8 hours spent by personnel in searching for or retrieving a requested record. Commercial requesters may also be charged the actual cost of retrieving and transporting public records from an off-site storage facility when the public records are maintained by a third-party storage company under contract with the City. If a fee is charged to a commercial requester under this section, the requester will be provided a receipt accounting for all fees, costs and personnel hours in connection with the request. C. Fees for Electronic Records (Voluminous Requests) The City will impose a fee for electronic records that fall under a voluminous request, as described in Section II.D.5 of this Policy. The fees are set forth below: 1. Records not in PDF format: • up to 2 MB of data - $20.00 • more than 2 MB but less than 4 MB of data - $40.00 • more than 4 MB - $100.00 2. Records in PDF format: • up to 80 MB of data - $20.00 • more than 80 MB but less than 160 MB of data - $40.00 • more than 160 MB - $100.00 ===== PDF PAGE 94 ===== FOIA POLICY 11 2026 D. Method and Time of Payment Payment of all required fees must be made in cash, by cashier's or certified check, or by money order prior to the inspection, copying, or certification of any public record. E. Waiver of Fees The fees provided in Section V.A above may be waived or reduced by the FOIA Officer or another appropriately authorized official if the requester states the specific purpose of the request on the request and establishes to the reasonable satisfaction of the FOIA Officer that a fee waiver or reduction would be in the public interest. Any request for fee waiver or reduction must be indicated on the request at the time the request is filed. A fee waiver or reduction will be considered to be in the public interest only if the principal purpose of the request is to disseminate information regarding the public health, safety, and welfare or the legal rights of the general public and is not for the principal purpose of personal or commercial benefit to the requester. The FOIA Officer may consider the number of requested public records and the cost and necessity of copying them in setting the fee waiver or reduction amount. VI. CITY OBLIGATIONS A. Records Subject to Immediate Disclosure Upon Request The FOIA Officer will develop a list of documents or categories of records that the City will immediately disclose upon request. B. List of Records Under the City's Control The City will maintain and make available for inspection and copying a reasonably current list of all types or categories of records under its control. The list will be reasonably detailed in order to aid people in obtaining access to public records pursuant to the Act. The City will furnish, upon request, a description of the manner in which its public records stored by means of electronic data processing may be obtained in a form comprehensible to persons lacking knowledge of computer language or printout format. C. Posting Requirements The City will prominently display on its website, make available for inspection or copying, and send through mail if requested, each of the following: • a brief description of the City, identifying and describing the membership of the City's Corporate Authorities and of all of its standing and special committees and other advisory bodies, • a short summary of the City's purpose, • a block diagram of its functional subdivisions, • the approximate number of its full and part-time employees, • identification and membership of advisory councils, commissions, or committees, • the total amount of its operating budget, • the number and location of each of its offices, • a brief description of the methods whereby the public may request public records, • a directory designating the Freedom of Information officer(s), ===== PDF PAGE 95 ===== FOIA POLICY 12 2026 • the address where requests for public records should be directed, and • any fees allowable under Section 6 of the Act, as set forth in Section V, above. D. Record Keeping The FOIA Officer will retain copies of all requests and documents relating to a request until the request is complied with or has been denied, or for a longer period if required by the Act, other applicable law, preservation request, or court order. In addition, copies of requests, any responses including Notices of Denial, and a copy of communications with the Requester and other communications shall be maintained by the FOIA Officer for the period provided by law, or for a longer period of time pursuant to a preservation request or court order. E. Summary of Procedures The FOIA Officer will create, maintain current, and make available for inspection, copying, and mailing a copy of this FOIA Policy containing at a minimum the following: a brief summary of the procedures established by this FOIA Policy, a directory designating the FOIA Officer, the address where requests for public records should be directed, and any fees allowed. VII. GENERAL A. Conflicts and Invalidity This FOIA Policy is promulgated in compliance with the Act, and does not supersede the Act. In the event that this Policy, or part thereof, conflicts with the Act, the Act will control over the FOIA Policy. If any provision of the FOIA Policy is deemed illegal or unenforceable, the remainder of the Policy will remain unaffected and applicable to all requesters to the extent permitted by law. B. Definitions In addition to the definitions provided in the Act, the following definitions are applicable to this FOIA Policy: 1. Business hours: 8:00 a.m. to 4:30 p.m. on a business day. 2. Business day: Any day on which the City Office is open and staffed for regular public business during business hours.