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41 Section IV: Duties Relating to Right of Subjects and/or completeness of public and private data about her/himself. The data subject has the right to challenge the accuracy and/or completeness of public and private data about her/himself. If a data subject believes that public or private data about him/her are inaccurate and/or incomplete, s/he has the right to file a data challenge with the entity. See the document, CHALLENGING THE ACCURACY AND/OR COMPLETENESS OF DATA THAT GOVERNMENT ENTITIES KEEP ABOUT YOU, at the end of this section. The subject may challenge only accuracy and completeness of data. The Rules of the Department of Administration provide these definitions: • Accurate means the data are reasonably correct and free from error. • Complete means that the data describe all of the subject's transactions with the entity in a reasonable way. Data may be inaccurate or incomplete because a wrong word, name, or phrase was used; because the data give a false impression about the subject; because certain information is not in the record; because certain information in the record should not be there; or for other reasons. To challenge the accuracy and/or completeness of data, the data subject must communicate in • written form to the responsible authority for the entity that the subject is challenging the accuracy and completeness of data the entity maintains about her/him. Written form includes commumcation via letter, a-mail message, or fax. The written communication must identify the specific data being challenged; describe why or how the data are inaccurate or incomplete; and state what the subject wants the entity to do to make the data accurate or complete, i.e. add, alter or delete data. Upon receipt of the challenge notice, the responsible authority, or someone within the entity designated by the responsible authority, must review the notice and the challenged data promptly. Although it is not required, appointing a disinterested person to review the challenge often enables a more expeditious resolution of the dispute. Within 30 business days, the responsible authority must determine if the data are inaccurate or incomplete. The responsible authority may agree with all, part or none of the data challenge, and must notify the subject of the determination about the challenge. If the responsible authority agrees that challenged data are inaccurate and/or incomplete, the entity must make the changes requested and try to notify anyone who has received the data in the past, including anyone named by the subject. If the responsible authority does not agree that the challenged data are inaccurate and/or incomplete, the entity must notify the subject, who then has the right to appeal the entity's determination to the Commissioner of the Minnesota Department of Administration. July, 2000 Model Policy: Access to Government Data & Rights of Subjects Data