NBP maintained that service record of the bank employee could not be shared under State Bank of Pakistan Prudential Regulation M-3 regarding record retention and that such records were kept only for five years. The commission maintained that service records of an employee are public records under Section 6 (c) of the Right of Access to Information Act 2017 and Section 2 (2) (e) of the National Archives Act, 1993 and not financial transactions carried out by a bank in its normal course of functions.