9.7 Protecting Personally Identifiable Information and Sensitive Data Policy

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Chapter 9: Grants and Sponsored Projects

9.7 Protecting Personally Identifiable Information and Sensitive Data Policy

Related Minnesota State Board Policies: 5.23 Security and Privacy of Information Resources
Related Minnesota State Board Procedures: –

Purpose:  To ensure that grant-funded projects protect student education records per applicable laws and regulations including the Family Educational Rights and Privacy Act (FERPA) and protect the security and privacy of information resources.

Part 1: Responsibilities

A. During initiation of a Federally-funded project, a “kick-off” meeting is held at which time the Principal Investigator/Project Director, Grants Specialist, and other key grant personnel meet to discuss project compliance matters.

B. During the kick-off meeting, the Grants Specialist will inform the Project Director and other key personnel will be advised – either verbally or in writing – of the requirement to safeguard personally identifiable and sensitive data and information. This will include a reminder of what are and are not education records per FERPA, security and privacy practices, data suppression, and the types of information on grant-funded projects that must be made available to the public if requested.

C. The Principal Investigator/Project Director will be responsible for secure storage of data during the period of the grant, at which time files will be submitted to the Office of Grants & Sponsored Projects for retention per Normandale and Minnesota State policies.

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  Policy History:
Date of Adoption:  4/02/2019
Department / Owner: Grants
Date and Subject of Revisions:
Next Review Date:  4/02/2023
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