Question juridique clé
Whether access to archived personnel files requires the requester to show a protected interest
Solution extraite
Yes. The requester had to make a protected interest plausible, and this was not done.
Motifs extraits
The cantonal access regulation was incomplete for archived files, so the court applied the constitutional access-to-files rule. Under that rule, access to completed or non-procedural files also depends on a plausible protected interest, especially for personnel files containing internal documents and third-party information.