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<br />13 <br />MU125\11\1101989.v1 <br /> <br />10.3 Review. City department managers should periodically review forms used to collect <br />data on individuals to delete items that are not necessary and to clarify items that may be <br />ambiguous. All records must be disposed of according to the City’s records retention <br />schedule. <br /> <br />11.0 Data Protection. <br /> <br />11.1 Legal Requirement. The adoption of this Section by the City satisfies the <br />requirement in Minnesota Statutes, Section 13.05, subd. 5 to establish procedures ensuring <br />appropriate access to not public data. By incorporating employee access to not public data <br />in the City’s Data Inventory in the individual employee’s position description, or both, the <br />City’s policy limits access to not public data to employees whose work assignment require <br />reasonable access. Please direct all questions regarding this Section to the Responsible <br />Authority. <br /> <br />11.2 Data Inventory. Under the requirement in Minnesota Statutes, Section 13.025, <br />subd. 1, the City has prepared a Data Inventory which identifies and describes all not public <br />data on individuals maintained by the City. To comply with the requirement set forth in <br />Minnesota Statutes, Section 13.05, subd. 5, the City has also modified its Data Inventory <br />to represent the employees who have access to not public data. <br /> <br /> 11.3 Data Safeguards. <br /> <br />11.3A Not public data will be stored by the City in files or databases which are <br />not readily accessible to individuals who do not have authorized access and will be <br />secured during hours when the offices are closed. <br /> <br /> 11.3B Not public data must be kept only in City offices, except when necessary <br />for City business. <br /> <br /> 11.3C The City will assign appropriate security roles to its employees, limit <br />employee access to appropriate shared network drives and implement password <br />protections for not public electronic data. <br /> <br /> 11.3D Only those City employees whose job responsibilities require them to have <br />access will be allowed access to City files and records that contain not public data. <br />Employee position descriptions will contain provisions identifying any not public <br />data accessible to the employee when a work assignment reasonably requires <br />access. If a City employee does not have a work assignment allowing access to the <br />not public data, the City will ensure that the not public data are secure. The City’s <br />employees will be instructed to: <br /> <br />11.3D1 Release or disclose not public data only to those persons, within and <br />outside of the City, who are authorized by law to have access to the data;