Election Investigations Guidebook available to interested parties will vary depending upon the circumstances.”282 In other words: An organization that is subject to open records laws may need to make all records available to any person upon request. Other organizations may have a legitimate need to protect confidential or proprietary information, and they may therefore reasonably put in place procedures designed to control access to information.283 The Principles of Access to Archives, while advocating for the “widest possible access to archives,” similarly acknowledge the potential need for restrictions on “investigatory or law enforcement information.”284 In the Philippines, for example, where citizens have a constitutional right to information,285 limitations to public access nevertheless include restrictions on records related to any ongoing investigation.286 As outlined in the Principles of Access to Archives, if an election investigation body finds it necessary to limit public access to certain investigative documents and records, it should “limit the scope of restrictions to those imposed by law or to identify instances where a specific harm to a legitimate private or public interest temporarily outweighs the benefit of disclosure at the time.”287 Furthermore, consistent with the general principle of transparency, it must ensure that any “restrictions and the reasons for them are clear to the members of the public.”288 Finally, restrictions must be “administered on equitable terms” and not arbitrarily.289 282 Id. at 10. 283 Id. 284 Int’l Council on Archives, Principles of Access to Archives § 4 (2012), http://www.ica.org/13619/toolkits-guides-manuals-and-guidelines/principles-of-access-to-archives.html. 285 Const. (1987), art. III, sec. 7 (Phil.). 286 Nat’l Archives of the Philippines (NAP) General Circular No. 1, §§ 13–13.5.4, 105:12 O.G. 1715 (Jan. 20, 2009) (“The National Archives of the Philippines shall provide official information, records or documents to any requesting public . . . , except if: . . . It would disclose investigatory records . . . ; Interfere with enforcement proceedings; Deprive a person of a right to a fair trial or an impartial adjudication; Disclose the identity of a confidential source; Unjustifiably disclose investigative techniques and procedures . . . .”). 287 Int’l Council on Archives, Principles of Access to Archives § 4 (2012), http://www.ica.org/13619/toolkits-guides-manuals-and-guidelines/principles-of-access-to-archives.html. 288 Id. 289 Id. 90

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