I concur with Justice Riley for the following reasons.
I agree that the Department of State Police may refuse to relinquish the security guards’ names and addresses to the union on the ground that such "[information [is] of a personal nature where the public disclosure of the information would constitute a clearly unwarranted invasion of an individual’s privacy.” MCL 15.243(l)(a); MSA 4.1801(13)(l)(a). However, I would employ a balancing test to reach this conclusion. The privacy interests at stake in this case, in my opinion, clearly outweigh any potential public interest, regardless of whether the definition of public interest is limited by the words of the preamble to the Michigan Freedom of Information Act, MCL 15.231(2); MSA 4.1801(1 )(2), as Justice Riley advocates, or given a more expansive reading, as exemplified by Justice Ryan’s opinion in Kestenbaum v Michigan State University, 414 Mich 510, 552-555; 327 NW2d 783 (1982).
A balancing test is an appropriate means of implementing the words of the statutory exemption. Determining whether "public disclosure of the information would constitute a clearly unwarranted invasion of an individual’s privacy” neces*466sarily involves an evaluation of the privacy interests and a weighing of those interests against the public interest to be served in the disclosure.
As Justice Levin observes, both opinions in Kestenbaum employed a balancing test. The Fitzgerald opinion in Kestenbaum noted:
It generally has been accepted, however, that where the requested information might fall under the federal privacy exemption, a balancing test must be employed, i.e., the public interest in disclosure must be weighed against the potential invasion of privacy. [Kestenbaum, supra, p 526, emphasis added (citing federal cases).]
That opinion further stated that it "also is necessary under the state act to balance interests.” Id., p 527. The Ryan opinion in Kestenbaum also indicated that "[t]he Court must balance the public interest against the privacy interests with a 'tilt’ in favor of disclosure.” Id., p 561.
On the federal level, the balancing test first articulated in Dep’t of the Air Force v Rose, 425 US 352; 96 S Ct 1592; 48 L Ed 2d 11 (1976), has gained wide acceptance. See Minnis v Dep’t of Agriculture, 737 F2d 784, 786 (CA 9, 1984); Heights Community Congress v Veterans Administration, 732 F2d 526, 528 (CA 6, 1984); American Federation of Government Employees v Dep’t of Health & Human Services, 712 F2d 931, 932 (CA 4, 1983); Washington Post Co v Dep’t of Health & Human Services, 223 US App DC 139, 147; 690 F2d 252 (1982); Wine Hobby USA, Inc v Internal Revenue Service, 502 F2d 133, 136 (CA 3, 1974); Getman v NLRB, 146 US App DC 209; 450 F2d 670 (1971). For example, the Circuit Court of Appeals for the District of Columbia, in Washington Post Co, supra, stated that in "determining whether disclosure is clearly unwarranted — we *467must balance the public interest in disclosure against the privacy interests of [the persons who are the subjects of the information].” Id., p 147 (emphasis added). Likewise, the Court of Appeals for the Sixth Circuit recently stated that in Rose, supra,
the Supreme Court mandated that the court balance the individual’s right to privacy against disclosure’s benefit to the public interest in determining if the disclosure would result in a "clearly unwarranted invasion of personal privacy.” [Heights Community Congress, supra, p 528.]
Application of the balancing test under either the state or federal exemption is a two-part process. Under the federal act, a court must first determine whether the information contained may be identified as applying to a particular individual.1 If so, it must determine whether disclosure would constitute "a clearly unwarranted invasion of personal privacy.” The balancing test comes into play in the second stage of the analysis.
Likewise, under the state act, a court must first determine whether the requested information is "of a personal nature.” If it is found to be personal, then the question is whether disclosure would constitute a clearly unwarranted invasion of an individual’s privacy. Again, this is where the *468Rose balancing test comes into play. See Kesten-baum, supra, pp 550-551 (opinion of Ryan, J.).
I
I find the information sought in this case to be of such a sufficiently personal nature as to give rise to a cognizable privacy interest under the act. In Kestenbaum, Justice Ryan concluded that the names and addresses of Michigan State University students were not sufficiently personal to allow nondisclosure under the exemption. Kestenbaum, supra, p 546. However, Justice Ryan’s analysis does not seem to preclude the possibility that names and addresses of different persons, in a different situation, might be sufficiently personal in nature.
In reaching his conclusion in Kestenbaum, Justice Ryan noted "that names, addresses, telephone numbers, and other standard identifying information simply are not embarrassing information 'of a personal nature’ for the overwhelming majority of students at Michigan State University.” Id., p 546 (emphasis added). It may be said that linking names and addresses with the fact of employment by a security guard agency is not "standard information.” Also, Justice Ryan seems to have considered the characteristics and situation of the persons subject to the disclosure in coming to his conclusion. That opinion noted explicitly:
We leave for another day the question whether, in certain unusual circumstances, ordinarily impersonal information might take on an intensely personal character. [Id., p 547.]
There are several aspects of this case that heighten the privacy interest at stake. First, the information here would reveal more than the *469name and address of the individual, it would indicate the type and place of employment. A strong case for distinguishing security guards from other types of addressees may be made on the basis of the law enforcement nature of their work. It is certainly relevant to note that the Michigan foia provides specific exemptions relating to police and sheriffs departments.
A public body may exempt from disclosure as a public record under this act[,]
[u]nless the public interest in disclosure outweighs the public interest in nondisclosure in the particular instance, public records of a police or sheriff’s agency or department, the release of which would do any of the following:
Disclose the personal address or telephone number of law enforcement officers or agents .... [MCL 15.243(l)(t)(iii); MSA 4.1801(13)(l)(t)(iii). Emphasis added.]
Although obviously not directly applicable to this case, these provisions indicate that when names and addresses are linked with the fact of law enforcement employment, the privacy interest is augmented.
Second, the State Police Department’s promise of confidentiality regarding this information also weighs on the side of a heightened privacy interest. As Justice Riley points out, the department’s rule provides:
A complete employee personnel list shall be filed with the department of each licensee on a quarterly basis. This list shall be kept conffdential except for office use. [1979 AC, R 28.4003. Emphasis added.]
*470In Washington Post Co, supra, the court discussed how a pledge of confidentiality may affect the privacy interests at stake in a federal foia case:
Other things being equal, release of information provided under a pledge of confidentiality involves a greater invasion of privacy than release of information provided without such a pledge. On the other hand, to allow the government to make documents exempt by the simple means of promising confidentiality would subvert foia’s disclosure mandate. On balance, we believe that a government pledge of conñdentiality, made in good faith and consistently honored, should generally be given weight on the privacy side of the scale in accord with its effect on expectations of privacy. Cf. Ditlow v Shultz, [170 US App DC 352, 358] 517 F2d 166, 172 (1975) (footnote omitted) ("the absence of a governmental assurance of confidentiality . . . would seem to undercut the privacy expectations protected by exemption 6”). However, such a pledge should not be given determinative weight where the public interest in disclosure is high and the privacy interest in the information would otherwise be low. See Ackerly v Ley, [137 US App DC 133, 137, n 3] 420 F2d 1336, 1340, n 3 (1969) ("pledge of confidentiality . . . can not, in and of [itself], override the Act”); Robles v EPA, 484 F2d 843, 846 (CA 4, 1973) (similar). [Id., p 150. Emphasis added.]
Clearly, the Department of State Police had good public policy and safety reasons for promulgating the confidentiality rule. Those reasons presumably do not include the subversion of foia requests. This conclusion is supported also by the existence of the specific law enforcement exemptions. There have been no allegations of bad faith or a lack of consistency in applying the confidentiality rule. Thus, the pledge should "be given weight on the privacy side of the scale in accord with its effect on expectations of privacy.”
*471In Justice Levin’s abbreviated discussion of the confidentiality pledge, it merely observes that
because privacy is so subjective a concept — virtually anything can be embarrassing in the appropriate circumstance — we regard as significant the absence of evidence establishing or even tending to show that the requested information is personal in nature. We are not willing to "deem” addresses personal in nature as a matter of law.
On the contrary, factoring the confidentiality pledge into the privacy interest side of the balancing test would not amount to a declaration that all addresses are highly personal.
II
The public interest in disclosure in this case is minimal. In this respect, I agree with Justice Levin. The union’s interest in this information is primarily a proprietary one. Moreover, a general interest in the encouragement of collective bargaining is not a compelling public interest.
A federal case from the Court of Appeals for the Fourth Circuit supports this conclusion. In American Federation of Government Employees v Dep’t of Health & Human Services, 712 F2d 931 (CA 4, 1983), the union sought disclosure of the addresses of 20,000 bargaining unit employees of the Social Security Administration headquarters for purposes of communicating with them about the union. Employing the Rose balancing test, the court noted the employees’ privacy interest in their home addresses. Turning to the public interest, the court concluded that
even granting that collective bargaining is a matter of grave public concern, any benefits flowing *472from disclosure of the information sought would inure primarily to the union, in a proprietary sense, rather than to the public at large. [Id., p 932.]
Thus, the court struck the balance in favor of the employees’ privacy interest and against the union’s interest when the only identifiable public interest was the furtherance of collective bargaining.
Thus, I find it unnecessary to reach the question whether the body of public interests cognizable under the Michigan foia should be circumscribed by the act’s preamble or be interpreted more broadly. However public interest is defined, it is clear that the interests served by disclosure in this case do not rise to that level.
Even assuming an initial " 'tilt’ in favor of disclosure,” Kestenbaum, supra, p 561, when the privacy interests in this case are balanced against this minimal, possibly nonexistent, public interest, the privacy interests clearly tip the scale in favor of nondisclosure. I believe that the department’s exemption of these records from disclosure was entirely within the dictates of our state foia. Therefore, I would reverse the judgment of the Court of Appeals. I concur in part V of my brother Levin’s opinion concerning attorney fees.
Cavanagh, J., took no part in the decision of this case.The federal foia privacy exemption applies to information contained in "personnel and medical files and similar files . 5 USC 552(bX6). The United States Supreme Court has interpreted that language broadly, however, holding that the exemption applies to any
"'. . . Government records on an individual which can be identified as applying to that individual.’ [Citation to House Report omitted.] When disclosure of information which applies to a particular individual is sought from Government records, courts must determine whether release of the information would constitute a clearly unwarranted invasion of that person’s privacy.” Dep’t of State v Washington Post Co, 456 US 595, 603; 102 S Ct 1957; 72 L Ed 2d 358 (1982).