Yes, they in fact do.

See Fraternal Order of Police, Lodge No. 5 v. City of Philadelphia, 812 F.2d 105 (3d Cir. 1987) (finding inadequate safeguards on questionnaire responses by police candidates and stating that “[s]afeguards against disclosure of private material have been held to be adequate where there exists a statutory penalty for unauthorized disclosures,; when there exist security provisions to prevent mishandling of files coupled with an express regulatory policy prohibiting disclosure. . . .”); US v. Westinghouse, 638 F.2d 570 (3d Cir. 1980) (setting forth balancing test to determine when disclosures are unwarranted).

There are many more cases. In my casebook, I excerpt quite a few, plus list cases from many different circuits that recognize the right.

Dan, do the lower court cases agree with this interpretation of what the right does, or is this more of a brooding omnipresence in the Solovian sky?