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13 MU125\11\850810.v2 may be ambiguous. All records must be disposed of according to the City’s records retention schedule. 11.0 Data Protection. 11.1 Legal Requirement. The adoption of this Section by the City satisfies the requirement in Minnesota Statutes, Section 13.05, subd. 5 to establish procedures ensuring appropriate access to not public data. By incorporating employee access to not public data in the City’s Data Inventory in the individual employee’s position description, or both, the City’s policy limits access to not public data to employees whose work assignment require reasonable access. Please direct all questions regarding this Section to the Responsible Authority. 11.2 Data Inventory. Under the requirement in Minnesota Statutes, Section 13.025, subd. 1, the City has prepared a Data Inventory which identifies and describes all not public data on individuals maintained by the City. To comply with the requirement set forth in Minnesota Statutes, Section 13.05, subd. 5, the City has also modified its Data Inventory to represent the employees who have access to not public data. 11.3 Data Safeguards. 11.3A Not public data will be stored by the City in files or databases which are not readily accessible to individuals who do not have authorized access and will be secured during hours when the offices are closed. 11.3B Not public data must be kept only in City offices, except when necessary for City business. 11.3C The City will assign appropriate security roles to its employees, limit employee access to appropriate shared network drives and implement password protections for not public electronic data. 11.3D Only those City employees whose job responsibilities require them to have access will be allowed access to City files and records that contain not public data. Employee position descriptions will contain provisions identifying any not public data accessible to the employee when a work assignment reasonably requires access. If a City employee does not have a work assignment allowing access to the not public data, the City will ensure that the not public data are secure. The City’s employees will be instructed to: 11.3D1 Release or disclose not public data only to those persons, within and outside of the City, who are authorized by law to have access to the data;