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OCR: individual emplovees: A Yet treating the unions in the instant case like any FOIA requester from the public at Iarge, HL ugency employer's inaist doing 18} would necessarily jeopal ardize the ability unions to obtain this wide array of personal data sa vital ta their representational functions. Treating union requests Tor implicating per- 5onal privacy under Section 7114{b) (4] they were made under the FOIA would limit application the public interest to that identified in Reporers Comnittee for FOIA Exemption balancing. That the extent which documents reveal "what the government up to wouId be balanced against in dividual privacy interests determi inc the privacy invasion "clearly unwarranted. Reporters Corn mittee, 189 U.F at 773 Yct some court5 appeals have indicuted that personal data s ...