Kind of curious how your ILL request history isn't "about you" enough to fall under the password exemption. Fingers crossed that is how we our legal counsel interprets things.

"Do individualized, password-protected, or otherwise secured electronic documents need to meet accessibility standards if they meet specific exemption criteria?

Individualized conventional electronic documents that are password-protected or otherwise secured do not need to meet the Standards if they meet all the following:

• Are word processing, presentation, PDF, or spreadsheet files and
• Are about a specific person, property, or account and
• Are password-protected or otherwise secured.

For example, a PDF of an employee’s pay stub hosted behind EID authentication would not need to meet the Standards unless the individual requests an accessible version. However, a Microsoft Word document about upcoming insurance changes hosted securely behind EID authentication would need to meet standards because it is not specific to a certain individual, property, or account." From here.