Private and Nonpublic Data

Effective Date: 07/01/2017

Financial records and other grant files that you keep may contain private and nonpublic data.  Private data are data identifying an individual that are only available to the individual or with the individual’s consent (for example, social security numbers, or documentation of an individual’s low income status).  Nonpublic data are data on a business or other entity that are only available to the subject of the data or with the subject’s consent (for example, bank account or credit card information).  For more information on these categories and the Minnesota Data Practices Act, see http://www.house.leg.state.mn.us/hrd/pubs/dataprac.pdf.)

Compliance with the Minnesota Data Practices Act requires collection and storage of data on individuals to be limited to only what is needed to administer programs authorized by law (Minn. Stat. §13.05, subd. 3).  For example, if you need to verify low-income status for a cost-share payment, you may collect and store evidence of that status. Additionally, BWSR may collect private and nonpublic data to verify compliance to the terms of the grant agreement, and we may need to store data to answer to our own auditors.  The Data Practices Act requires that access to private and nonpublic data be limited to those with a need to know.  Documentation that is stored electronically, without controlled access, should have all private and nonpublic data redacted or blacked out before scanning.