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-74- Except from Minutes of the Board of Regents' Meeting of January 25, 1977 -87- [[underlined]] Policy on Public Disclosure of Internal Audits [[/underlined]] Since 1970, the Smithsonian's Office of Audits has been performing internal audits of virtually all Institution programs. Each audit consists of an independent investigation; a draft report of facts, criticisms, and recommendations; written responses and, often, a lively debate between auditors and auditees; and a revised final report, advisory in nature, but it consistently succeeds in improving operations because of a willingness to admit error on both sides and, more importantly, because it is an entirely internal procedure whose confidentiality is respected by all parties. Recently, and for the first time, there has been a request from a member of the public for copies of fifteen Smithsonian internal audit reports, citing the Freedom of Information laws. The initial response to this request stated: "A substantial number of those concerned with the integrity and independence of internal audits believe that the public interest in the effectiveness of internal self-criticism outweighs the interest in public disclosure, and that the fifth exemption to the Freedom of Information Act, relating to inter-agency memoranda, should apply since the purpose of this exemption is to encourage candid communications in order to arrive at better decision-making than would occur if personnel were inhibited in expressing their honest opinions and recommendations for fear of outside criticism or pressures. A recent court decision supports this view, but further study and consultation is necessary, not only with regard to this primary and comprehensive question but also to consider the application of the other FOI exemptions in detail to the numerous documents requested."
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