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An element essential to the vitality of a democracy is its citizens' ability to obtain information on the workings of their government. Georgia citizens are guaranteed access to all state, county, and municipal public records by the "Open Records Act."' In recent years, many individuals and groups, especially the news media, have resorted to this statute in order to gain access to government records. The records sought have been outside the categories of traditional courthouse records such as land titles and mortgages, and have consisted of documents such as ambulance records of a hospital authority, records of a public housing authority, or a departmental evaluation report commissioned by a state university.' As a result, Georgia courts have had to reexamine and expand their traditional definition of "public records."

These cases also brought another complex issue before the courts. The same statute that grants Georgia citizens access to public records also places restrictions on that right. For example, one category of public records which cannot be disclosed is within that group "the disclosure of which would be an invasion of personal privacy." In light of the burgeoning amount of personal data collected by the government on individuals, this statutory exception gives the individual a resource to prevent indiscriminate release of personal information to the public.