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: 5.23.1.1 – 5.23.1.13
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
- 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.
- 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.
- 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.
Policy History:
Date of Adoption: 4/2/2019
Department Owner: Grants
Date and Subject of Revisions:
Next Review Date: 4/2/2023