BLACKWELL, Justice.

When Kia Motors Manufacturing Georgia, Inc. opened a manufacturing facility in West Point, the Technical College System of Georgia undertook to provide technical and vocational training — as a part of its Quick Start program1 — to the workers whom Kia hired for the new facility. Years later, Krystal Coleman, Sabrina Robinson Bolston, Tim Durden, and Darrell Strawbridge each submitted a request to the Technical College System pursuant to the Open Records Act,2 seeking to inspect certain records concerning the hiring practices of Kia.3 The Technical College System refused on several grounds to make the requested records available for inspection, and Coleman, Bolston, Durden, and Strawbridge then filed a lawsuit to compel their production.4 In 2012, while the lawsuit was pending, the General Assembly amended the Open Records Act, and among other revisions, it added OCGA § 50-18-72(a)(47), which excepts certain records concerning the Quick Start program from public inspection. The Technical College System and Kia then moved to dismiss the lawsuit,5 asserting that paragraph 72(a)(47) excepts every record that Coleman, Bolston, Durden, and Strawbridge requested. Without deciding the extent to which paragraph 72(a)(47) applies to the requested records, the trial court denied the motions to dismiss, concluding that it would be unconstitutional in any event to apply paragraph 72(a)(47) in a pending lawsuit. The Technical College System and Kia appeal,6 and we conclude that paragraph 72(a)(47) applies by its terms in this case, and we conclude as well that its application in this case is constitutional. For these reasons, we reverse the decision of the trial court. But we cannot say from the pleadings alone that every record requested is excepted from public inspection under paragraph 72(a)(47), and so, we also remand for the trial court to determine the extent to which the requested records are so excepted.

1. We first consider whether OCGA § 50-18-72(a)(47) — on its face, and assuming its constitutionality — applies at all in this case.7 Paragraph 72(a)(47) excepts the following records from public inspection under the Open Records Act:

OCGA § 50-18-72(a)(47).8 No one disputes that the technical and vocational training provided to Kia workers by the Technical College System as a part of its Quick Start program is a "training program operated under the authority of Article 3 of Chapter 4 of Title 20." See OCGA § 20-4-40 et seq. But the appellees contend that the statutory exception in paragraph 72(a)(47) is limited in time and applies only for so long as "[no] binding commitment ha[s] been secured." Because the binding commitment of Kia to open its facility in West Point was secured years ago, before they asked to inspect any records, paragraph 72(a)(47) does not apply at all, they say, in this case. About this, the appellees are mistaken.

(a) We consider first whether OCGA § 50-18-72(a)(47) applies by its terms only for so long as "[no] binding commitment ha[s] been secured." When we consider the meaning of a statute, "we must presume that the General Assembly meant what it said and said what it meant." Arby's Restaurant Group, Inc. v. McRae, 292 Ga. 243, 245(1), 734 S.E.2d 55 (2012) (citation omitted). To that end, we must afford the statutory text its "plain and ordinary meaning," City of Atlanta v. City of College Park, 292 Ga. 741, 744, 741 S.E.2d 147 (2013) (citation and punctuation omitted), we must view the statutory text in the context in which it appears, Hendry v. Hendry, 292 Ga. 1, 3(1), 734 S.E.2d 46 (2012), and we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would. See Luangkhot v. State, 292 Ga. 423, 424(1), 736 S.E.2d 397 (2013). Consequently, courts sometimes refer to the rules of English grammar, see, e.g., Barnhart v. Thomas, 540 U.S. 20, 26(II), 124 S.Ct. 376, 157 L.Ed.2d 333 (2003), inasmuch as those rules are the guideposts by which ordinary speakers of the English language commonly structure their words, and the legislature "is presumed to know ... the rules of grammar."9 United States v. Goldenberg, 168 U.S. 95, 103, 18 S.Ct. 3, 42 L.Ed. 394 (1897). Applying these principles, if the statutory text is "clear and unambiguous," we attribute to the statute its plain meaning, and our search for statutory meaning is at an end. See Opensided MRI of Atlanta v. Chandler, 287 Ga. 406, 407, 696 S.E.2d 640 (2010).

Here, OCGA § 50-18-72(a)(47) naturally and reasonably admits of only one meaning, and it is not the one that the appellees urge. Paragraph 72(a)(47) applies, of course, only to certain records "related to a [Quick Start] training program." The particular Quick Start records to which it applies are identified by three participial phrases: "disclosing an economic development project"; "relating to job applicants"; and "identifying proprietary hiring practices, training, skills, or other business methods and practices of a private entity." That each of these participial phrases identifies a separate and distinct class of records to which the exception applies is signaled quite clearly by the commas that separate each participial phrase, see Garner, A DICTIONARY OF MODERN AMERICAN USAGE p. 537 (1998), especially the serial comma — followed immediately by the disjunctive "or" — that separates the second and third participial phrases. See id. at 253 ("whether to use the serial comma ... is more vehemently argued than any other punctuation issue ..., but [use of the serial comma is the only method that] is ironclad in avoiding unnecessary ambiguities"). See also Strunk, White, & Kalman, THE ELEMENTS OF STYLE § I(2), p. 3 (2000). The adverbial phrase on which the appellees rely — "prior to a binding commitment having been secured" — follows immediately after the first participial phrase, "disclosing an economic development project," and it can only be reasonably understood to modify that participial phrase and no others. See 2A Singer, STATUTES AND STATUTORY CONSTRUCTION § 47:33, p. 369 (6th ed. 2000) ("Referential and qualifying words and phrases, where no contrary intention appears, refer solely to the last antecedent."). Accordingly, Quick Start records "disclosing an economic development project" are excepted only to the extent that no "binding commitment ha[s] been secured," but the exception for Quick Start records "relating to job applicants" or "identifying proprietary hiring practices, training, skills, or other business methods and practices of a private entity" is not so limited.10 See OCGA § 50-18-72(a)(47). The Technical College System and Kia rely in this case upon the latter parts of the exception, and their reliance upon those parts is not foreclosed by the fact that Kia committed long ago to open its facility in West Point.11

(b) With this understanding of OCGA § 50-18-72(a)(47), we next consider the extent to which this statutory exception — on its face, and again assuming its constitutionality — applies in a lawsuit pending at the time of its enactment and arising from a request made before its enactment. Generally speaking, the retroactive application of statutes has long been disfavored in the law, even if it is not always forbidden. See Landgraf v. USI Film Products, 511 U.S. 244, 265(IV)(A), 114 S.Ct. 1483, 128 L.Ed.2d 229 (1994) ("[T]he presumption against retroactive legislation is deeply rooted in our jurisprudence, and embodies a legal doctrine older than our Republic."). For that reason, courts usually insist upon some clear indication in the statutory text that a statute is to be applied retroactively before so applying it.12 See Polito v. Holland, 258 Ga. 54, 55(2), 365 S.E.2d 273 (1988) ("Generally statutes prescribe for the future and that is the construction to be given unless there is a clear contrary indication shown." (Citations omitted)). Such a clear indication appears in the amendment that enacted paragraph 72(a)(47), which provides explicitly that "[OCGA § 50-18-72(a)(47) ] shall apply to any request for public records made prior to the effective date of this Act." Ga. L. 2012, p. 218, § 18. Accordingly, paragraph 72(a)(47) applies in this case, unless our Constitution forbids it, a question to which we now turn.

2. Even when the General Assembly clearly provides that a law is to be applied retroactively, our Constitution forbids statutes that apply retroactively so as to "injuriously affect the vested rights of citizens."13 Bullard v. Holman, 184 Ga. 788, 792(2), 193 S.E. 586 (1937). The appellees argue that, applied retroactively, OCGA § 50-18-72(a)(47) impairs their "vested right" to inspect the records that they requested. They have such a "vested right," they say, because the version of the Open Records Act in effect at the time they made their requests conferred a "right" of access to the records they seek. That "right" vested, they continue, when they made their requests, or at least when they filed their lawsuit. The Technical College System and Kia dispute that the former Open Records Act conferred any "rights," characterizing the access to public records afforded under the former Act instead as a mere "privilege." The trial court considered whether the former Act conferred "rights" or "privileges," and it decided that the former Act is better characterized as having conferred a "right" of access. Accordingly, the trial court concluded, the appellees have a "vested right" to inspect the requested records, and it would be unconstitutional to apply paragraph 72(a)(47) in this case. With these conclusions, we disagree.

(a) Our constitutional analysis begins with an inquiry into the nature of "vested rights," a legal concept with which this Court has dealt from time to time, but one that has not been defined consistently and with precision.14 In the search for "vested rights," some Georgia precedents — mostly decisions of our Court of Appeals, but at least one of our decisions as well — distinguish between "rights" and mere "privileges," as the parties and the trial court in this case have done. See, e.g., Fulton Bag & Cotton Mills v. Williams, 212 Ga. 783, 785(1), 95 S.E.2d 848 (1956) ("A person has no vested right in statutory privileges or exemptions." (Citation omitted)); Evans v. Belth, 193 Ga.App. 757, 758(2), 388 S.E.2d 914 (1989) (same); Atha v. Jackson Atlanta, Inc., 159 Ga.App. 433, 436, 283 S.E.2d 654 (1981) (same); Goolsby v. Regents of Univ. System of Ga., 141 Ga.App. 605, 607(1), 234 S.E.2d 165 (1977) (same), overruled on other grounds in Donaldson v. Dept. of Transp., 262 Ga. 49, 414 S.E.2d 638 (1992). Other precedents of this Court, however, seem to pay the distinction no mind. See, e.g., Jackson County Bd. of Health v. Fugett Constr., Inc., 270 Ga. 667, 670(2), 514 S.E.2d 28 (1999) ("[I]t is obvious that many rights, privileges, and exemptions which usually pertain to ownership under a particular state of the law, and many reasonable expectations, cannot be regarded as vested rights in any legal sense." (Emphasis supplied and citation omitted)); Goldrush II v. City of Marietta, 267 Ga. 683, 697(9), 482 S.E.2d 347 (1997) (same). More important, the distinction is one without real meaning in this context. Used in a legal sense, a "right" is most commonly understood to mean "[a] power, privilege, or immunity secured to a person by law," BLACK'S LAW DICTIONARY (9th ed.2009) (emphasis supplied), and a "privilege" is most commonly understood to mean "[a] special legal right, exemption, or immunity granted to a person or class of persons." Id. (emphasis supplied). Inasmuch as a "right" is understood to be a sort of "privilege," and insofar as a "privilege" is understood to be a kind of "right," any distinction between "rights" and "privileges" is a distinction without a difference. To the extent that Fulton Bag & Cotton Mills, 212 Ga. at 785(1), 95 S.E.2d 848, Evans, 193 Ga.App. at 758(2), 388 S.E.2d 914, Atha, 159 Ga.App. at 433, 283 S.E.2d 654, and Goolsby, 141 Ga.App. at 607(1), 234 S.E.2d 165, suggest that courts must distinguish between "rights" and "privileges" in considering whether a law can apply retroactively, we disapprove those decisions.

In other cases, this Court has said that "the term vested rights ... means interests which it is proper for the state to recognize and protect and of which the individual cannot be deprived arbitrarily without injustice." Hayes v. Howell, 251 Ga. 580, 584(2), 308 S.E.2d 170 (1983) (citations and punctuation omitted). See also Fulton County v. Action Outdoor Advertising, 289 Ga. 347, 349(1), 711 S.E.2d 682 (2011) (citing Hayes); Jackson County Bd. of Health, 270 Ga. at 668-669(2), 514 S.E.2d 28 (same); Recycle & Recover, Inc. v. Georgia Bd. of Natural Resources, 266 Ga. 253, 254(2), 466 S.E.2d 197 (1996) (same). No doubt, these statements are accurately descriptive of "vested rights." After all, no one reasonably could dispute that "vested rights" are "interests which it is proper for the state to recognize and protect," or that they are "interests ... of which the individual cannot be deprived arbitrarily without injustice." But these descriptive statements do not amount to a meaningful standard that can be applied to discern whether a statutory right might properly be capable of vesting.15 See 2 STATUTES AND STATUTORY CONSTRUCTION, supra, § 41:6, p. 426 ("Most of the numerous attempts at definition are essentially circuitous in nature, as in the pronouncement that `a vested right, as that term is used in relation to the constitutional guarantees, implies an interest which it is proper for the state to recognize and protect, and of which the individual may not be deprived arbitrarily without injustice.'" (Citations omitted)).

We also have noted a distinction in some cases between "substance" and mere "procedure," explaining that "there are no vested rights in any course of procedure." Mason v. Home Depot U.S.A., Inc., 283 Ga. 271, 278(4), 658 S.E.2d 603 (2008) (citation and punctuation omitted). See also EHCA Cartersville v. Turner, 280 Ga. 333, 337(3), 626 S.E.2d 482 (2006) (same); Day v. Stokes, 268 Ga. 494, 495, 491 S.E.2d 365 (1997) (same); Hunter v. Johnson, 259 Ga. 21, 22(2), 376 S.E.2d 371 (1989) ("Ordinarily, there is no constitutional impediment to giving retroactive effect to statutes that govern only procedure of the courts." (Citations omitted)); Ballew v. Riggs, 244 Ga. 232, 234(1), 259 S.E.2d 482 (1979) ("No person has a vested right in any course of procedure...." (Citation and punctuation omitted)). This distinction is a more meaningful one, and it is a distinction that is familiar to the courts, even if the line between "substance" and "procedure" sometimes can seem a bit hazy. Moreover, this distinction has proved to be a sufficient standard in many cases, insofar as it resolves any constitutional doubt about the retroactive application of a statute affecting only procedural rights. See, e.g., Mason, 283 Ga. at 278-279(4), 658 S.E.2d 603; EHCA, 280 Ga. at 337-338(3), 626 S.E.2d 482; Hunter, 259 Ga. at 22(2), 376 S.E.2d 371; Ballew, 244 Ga. at 233-234(1), 259 S.E.2d 482. Here, no one disputes that the right of access to public records conferred by the Open Records Act is something of substance. But to say that no right of "procedure" is a "vested right" is not to say that every right of "substance" is capable of vesting. Although the distinction between "substance" and "procedure" is an important and meaningful one, we conclude that this distinction alone is not sufficient to mark the boundary between "vested rights" and those that may properly be impaired by retroactive legislation. To mark the boundary, we must consider not only the nature of the right, but also to whom it is afforded.

American law long has distinguished between the "public rights belonging to the people at large" and the "private unalienable rights of each individual." Lansing v. Smith, 4 Wend. 9, 21 (N.Y. Sup.Ct. of Errors 1829).16 This distinction has been regarded as especially important in cases concerning the extent to which legislation can modify rights retroactively. See, e.g., Holen v. Minneapolis-St. Paul Metro. Airports Comm., 250 Minn. 130, 84 N.W.2d 282, 287(5) (1957) ("Clearly, there is a definite distinction between the effect to be given to a retroactive statute when it relates to private rights and when it relates to public rights."); Bradford v. Suffolk County, 257 A.D. 777, 15 N.Y.S.2d 353, 363 (N.Y.App.Div.1939) ("There is a definite distinction between the effect to be given to a retroactive statute when it relates to private rights and when it relates to public rights."); Robinson v. City of Winfield, 114 Kan. 387, 219 P. 273, 274 (1923) (distinction between public and private rights with respect to effect of retroactive legislation "is a distinction which has always been recognized"). Private rights may become vested in particular persons, and when they are vested, our Constitution does not permit those rights to be denied to those persons by subsequent legislation. But this principle does not apply with respect to public rights, which are shared by the People in common, and which can be modified by the People — through their elected representatives — as they see fit. See Hodges v. Snyder, 261 U.S. 600, 603(2), 43 S.Ct. 435, 67 L.Ed. 819 (1923) ("It is true, as they contend, the private rights of parties which have been vested by the judgment of a court cannot be taken away by subsequent legislation.... This rule... does not apply to a suit brought for the enforcement of a public right, which may be annulled by subsequent legislation...."). See also Pennsylvania v. Wheeling & Belmont Bridge Co., 59 U.S. 421, 431-432, 18 How. 421, 15 L.Ed. 435 (1855) (to the extent that prior judgment was to enforce a public right, it properly could be repudiated by subsequent legislation, although such legislation could not repudiate judgment to vindicate a private right); Georgia Assn. of Retarded Citizens v. McDaniel, 855 F.2d 805, 812(III) (11th Cir.1988) (recognizing that legislature might properly overturn judgment to enforce public rights but not one founded upon private rights); Inman v. R. Comm. of Texas, 478 S.W.2d 124, 128 (Tex.App.1972) ("The rule ... which recognizes that private rights of parties, which have become vested under judgment of a Court, cannot be taken away by subsequent legislation but must thereafter be enforced by the Court regardless of such legislation, does not apply to a suit brought for the enforcement of a public right, which, even after it has been established by the judgment of a court, may be annulled by subsequent legislation and should not thereafter be enforced." (Emphasis in original)); Holen, 84 N.W.2d at 288(5) ("In the instant case[,] plaintiff taxpayers are seeking the enforcement of a public right, a right in which they have no more interest than any other taxpayer, a right which is, therefore, subject to divestment by curative legislation after judgment, even though in the particular suit the action was brought by individuals primarily for their own benefit."); People v. B. Mercil & Sons Plating Co., 378 111. 142, 37 N.E.2d 839, 850 (1941) ("The fact that the curative act in this case was passed after the judgment was entered in the trial court would not affect private rights, because the suit is for the enforcement of a public right...." (Citations omitted)); Bradford, 15 N.Y.S.2d at 363 ("[P]laintiffs are proceeding as taxpayers to establish a public right and not to obtain any private right or property."); State ex rel. Newbury v. Patterson, 53 N.J.L. 120, 20 A. 828, 829 (1890) ("It is not a private right or interest, but a public right...."); Newton v. Commrs. of Mahoning County, 1876 WL 6061, *3, 1876 Ohio Misc. LEXIS 46, *5 (Ohio Ct. of Common Pleas 1876) ("It is the private rights that are protected by the Constitution, and they cannot be violated or impaired by legislation. We think the plaintiffs had no right to look upon the language [of a prior version of the statute] as a grant of private rights from the General Assembly, but should have considered it only as legislation for the public good, and subject to future revision and repeal.").

Like our sister states and the federal courts, Georgia recognizes a distinction between public and private rights. See, e.g., OCGA § 9-6-24 ("Where the question is one of public right and the object is to procure the enforcement of a public duty, no legal or special interest need be shown, but it shall be sufficient that a plaintiff is interested in having the laws executed and the duty in question enforced."); Rothschild II v. Columbus Consolidated Govt., 285 Ga. 477, 479, 678 S.E.2d 76 (2009) (noting that Georgia law "confers standing to seek the writ [of mandamus] in those cases wherein the defendant owes a public duty which the plaintiff, as a member of the public, is entitled to have enforced." (Citation and punctuation omitted)). Although our precedents do not expressly employ this distinction with respect to retroactive legislation, a few of our precedents at least hint at the distinction.17 In Bullard, for instance, this Court held that a repeal of a statute might properly apply retroactively, noting that the repealed statute had been "enacted for the protection of the public, and not for the benefit of any particular individual or calling." 184 Ga. at 791(2), 193 S.E. 586. More recently, in Jackson County Bd. of Health, we held that a statutory amendment that altered the requirement of statewide approval of county sewage management systems could apply retroactively, explaining that the former "statewide approval was for the benefit of the counties and cannot be seen as a license granted to a manufacturer." 270 Ga. at 670(2), 514 S.E.2d 28 (punctuation omitted). Moreover, our precedents — certainly our more recent precedents — generally are at least consistent with the distinction. See, e.g., Action Outdoor Advertising, 289 Ga. at 350-351(1), 711 S.E.2d 682 (property owners in a previously unincorporated part of a county have no vested right to continue to maintain their property in an unincorporated area, subsequent incorporations of new cities and annexations into existing cities notwithstanding); DeKalb County v. State of Ga., 270 Ga. 776, 778-779(1), 512 S.E.2d 284 (1999) (new statutory requirements with respect to distribution of tax proceeds did not impair any vested right of county in receipt of proceeds under prior law); Coastal Ga. Regional Dev. Center v. Higdon, 263 Ga. 827, 831(2), 439 S.E.2d 902 (1994) (defendants had no vested right with respect to lack of authority by Department of Community Affairs to conduct audits under prior law); McIntyre v. Miller, 263 Ga. 578, 578-579(1), 436 S.E.2d 2 (1993) (prospective public officer had no vested right in prior law concerning eligibility to hold public office). Cf. Mikesell v. RP Motorsports, Inc., 283 Ga. 476, 476-477, 660 S.E.2d 534 (2008) (offer of settlement provisions of Tort Reform Act of 2005 could not be applied constitutionally in a lawsuit between private parties for money damages, insofar as a private right of action accrued to the plaintiff prior to the effective date of the Act). In light of the settled distinction in American law between public and private rights, considering that this distinction is consistent with Georgia law, and given the settled implications of the distinction with respect to the retroactive application of statutes, we conclude that "vested rights" must be private rights, and public rights — those rights that belong to the People in common — can be modified by the elected representatives of the People prospectively or retroactively, as they see fit.

(b) With these principles in mind, we now consider whether the right of access to public records conferred by the former version of the Open Records Act is a public or private right. The text and structure of the former Act suggest that its right of access is a public one. Prior to the amendment, the Act defined those who might properly request an inspection of public records solely by reference to their membership in the People.18 See, e.g., OCGA §§ 50-18-70(b) (2012) (public records "shall be open for personal inspection by any citizen of this state"); 50-18-71 (a) (2012) ("In all cases where an interested member of the public has a right to inspect or take extracts or make copies from any public records, instruments, or documents...."). Although the Act contemplated requests by individual persons to inspect public records, it did not require that a person requesting inspection have, assert, or prove any special or personal interest in the requested records or the information contained therein. See OCGA § 50-18-71(b) (2012). And although a custodial agency was required to produce records responsive to the request for inspection, the person who made the request had no special or exclusive access to the records.19 See id. With respect to actions for judicial enforcement of the Act, it provided that "[s]uch actions may be brought by any person, firm, corporation, or other entity," OCGA § 50-18-73(a) (2012) (emphasis supplied), and the Act notably did not limit the authority to commence an enforcement action to persons who had made a request for records or to persons with a special or personal interest in the requested records.20 In addition, the Act authorized the Attorney General — who represents the public interest, of course — to bring actions to enforce the Act. OCGA § 50-18-73(a). As a remedy for violations of the Act, a court could award injunctive relief, Bowers v. Shelton, 265 Ga. 247, 248-249(1), 453 S.E.2d 741 (1995), but the Act did not authorize any person to recover damages. McBride v. Wetherington, 199 Ga.App. 7, 8, 403 S.E.2d 873 (1991). In addition, a court could sanction an agency that negligently violated the Act with civil penalties, and a knowing and willful violation of the Act was a crime. OCGA § 50-18-74(a). Moreover, consistent with the statutory text and structure, this Court in a number of cases had described the right as a "public right." See, e.g., McFrugal Rental of Riverdale v. Garr, 262 Ga. 369, 369, 418 S.E.2d 60 (1992) ("public's right of access to public records"); Bd. of Regents of the Univ. System of Ga. v. Atlanta Journal, 259 Ga. 214, 217(4)(b), 378 S.E.2d 305 (1989) ("right of public access"); Harris v. Cox Enterprises, 256 Ga. 299, 299, 348 S.E.2d 448 (1986) ("The public has a right to public records in Georgia."); Houston v. Rutledge, 237 Ga. 764, 764, 229 S.E.2d 624 (1976) ("right of the public to inspect records"). Cf. John Doe Agency v. John Doe Corp., 493 U.S. 146, 151(II), 110 S.Ct. 471, 107 L.Ed.2d 462 (1989) (about federal Freedom of Information Act, "[it] attempts to create a judicially enforceable public right to secure such information from possibly unwilling official hands"). Indeed, in one case, we noted that "the intent of the General Assembly [in enacting the Open Records Act] was to afford the public at large access to public records...." Griffin-Spalding County Hosp. Auth. v. Radio Station WKEU, 240 Ga. 444, 447(3), 241 S.E.2d 196 (1978) (emphasis supplied).

History points in the same direction. Used in the context of cases concerning retroactive legislation, "private rights" traditionally have been understood to refer to "an individual's common law rights in property and bodily integrity, as well as in the enforcement of contracts." Woolhandler, "Public Rights, Private Rights, and Statutory Retroactivity," 94 GEO. L.J. 1015, 1020 (2006). The right of access afforded by the Open Records Act was unknown at common law. McBurney v. Young, ___ U.S. ___ (II)(D), 133 S.Ct. 1709, 185 L.Ed.2d 758 (2013). Indeed, "[m]ost founding-era English cases provided that only those persons who had a personal interest in non-judicial records were permitted to access them." Id. And "Nineteenth-century American cases, while less uniform, certainly do not support the proposition that a broad-based right to access public information was widely recognized in the early Republic." Id. Considering the long history of our State, our Open Records Act — the first version of which was enacted in 1959, see Ga. L.1959, p. 88 — "[is] of relatively recent vintage." McBurney, ___ U.S. at ___ (II)(D), 133 S.Ct. at 1719. The historical context suggests as well that the right afforded by the Open Records Act — both now and as it existed prior to the 2012 amendment — is not in the nature of a personal right, but instead is more fairly characterized as a public one.

Recognition that the former Act afforded a public right also would be consistent with decisions in other jurisdictions that similar statutory schemes may properly be modified retroactively by legislation subsequent to a request to inspect public records or, in some cases, even a lawsuit to compel an inspection. For instance, "the Florida courts have consistently recognized that the right to inspect and copy public records under the Public Records Act is a public right." Campus Communications, Inc. v. Earnhardt, 821 So.2d 388, 399 (Fla. 5th Dist.2002). As such, a retroactive amendment of the Florida Public Records Act that carved out a new exception from its disclosure requirements — an exception for autopsy records — was found not to unconstitutionally impair any vested right in the former disclosure requirements. See id. at 401. Under the Maryland Public Information Act, the Maryland Court of Appeals held that a firm requesting certain records — the identities of all persons maintaining an electronic security or alarm system — had no vested right in the production of those records, even by virtue of submitting the request. Police Patrol Security Systems, Inc. v. Prince George's County, 378 Md. 702, 838 A.2d 1191, 1203(III)(B) (2003). As such, the retroactive application of a new statutory exemption for such records was constitutional. See id. at 1203-1204(III)(B). Even where Congress enacted an exemption from the federal Freedom of Information Act specifically in response to litigation to compel the disclosure of certain records under the Act — exactly what the appellees allege in this case — the United States Court of Appeals for the Ninth Circuit held that the retroactive application of the statutory exemption "would not deprive plaintiffs of any vested right protected by the due process clause of the [F]ifth [A]mendment." Long v. Internal Revenue Service, 742 F.2d 1173, 1184(IV) (9th Cir.1984). See also Southwest Center for Biological Diversity v. Dept. of Agriculture, 314 F.3d 1060, 1062 (9th Cir.2002). In addition, our own Court of Appeals has addressed the retroactive modification of the Open Records Act in two earlier decisions, the only published Georgia decisions to date on this question. Although those decisions did not consider whether the right of access was public or private — they rested instead upon the unsound distinction between "rights" and mere "privileges" — the results of those decisions at least would be consistent with a determination in this case that the right of access is public and, therefore, not a "vested right." See Evans, 193 Ga.App. at 758(2), 388 S.E.2d 914; Clayton County Hosp. Auth. v. Webb, 208 Ga.App. 91, 96, n. 3(2), 430 S.E.2d 89 (1993) (citing Evans).

Based on the text of the former Open Records Act, its structure, its historical context, our prior characterizations of the Act, and the treatment of similar statutes in other jurisdictions, we conclude that the right of access afforded by the former Act is a public right of the People as a whole. As such, it could not vest in any particular persons, whether upon the making of a request for public records, or upon the filing of an action to enforce the public right. Accordingly, there is no constitutional impediment to the retroactive modification of the Act by subsequent legislation.21 The statutory exception in OCGA § 50-18-72(a)(47) constitutionally may be applied in this case,22 and the trial court erred when it concluded otherwise.

3. Having concluded that OCGA § 50-18-72(a)(47) applies in this case, and having concluded that nothing in our Constitution forbids its application, we now turn to the implications of these conclusions for the motions of the Technical College System and Kia to dismiss this lawsuit. At least some of the records at issue in the lawsuit are records to which OCGA § 50-18-72(a)(47) applies. In their requests, the appellees asked to inspect the following records:

The records described in parts 1(a), 1(b), 3, and 6 of the requests seem quite clearly excepted from public inspection as records "relating to job applicants."

But it is not so clear that all the records described in the requests are excepted. No doubt, many of the other records may be excepted, either as records "relating to job applicants," or to the extent that the records contain proprietary information of Kia or other private entities, as records "identifying proprietary hiring practices, training, skills, or other business methods and practices of a private entity." And perhaps all the other records may be so excepted. But as we understand the pleadings, they do not conclusively show that to be the case, and we must remember that this lawsuit is before us only upon motions to dismiss. We certainly can conceive, for instance, of records that could exist, that might be responsive to parts 7 and 8 of the requests, and that would not be excepted by OCGA § 50-18-72(a)(47), even if some other exception might apply. Moreover, the parties have not fully briefed the extent to which particular parts of the requests seek only records that are excepted by paragraph 72(a)(47), at least not in their briefs to this Court. Consequently, it seems most appropriate to leave it to the trial court on remand to sort out the extent to which the specific parts of the requests seek only records that are excepted under paragraph 72(a)(47) and to dismiss the lawsuit as to those parts of the requests.23

Judgment reversed and case remanded.

All the Justices concur.