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EAP Policy Manual FFY24 Chapter 11 Data Practices and Records Page 3 Note: Minn. Stat. § 13.355 prohibits a government entity from mailing or delivering an item that displays the SSN on the outside of the item or in any manner where the SSN is visible without opening the item. Safe at Home (SAH) Participant SSN Participants in the state’s Safe at Home (SAH) program are an exception to the policy requiring primary household applicants to provide a verifiable SSN for the household to be eligible for EAP. Service Providers should neither require nor request the SSN for SAH participants. See Chapter 2 – Applications & Application Processing for an explanation of the SAH program. Responsibility for Data Privacy Individuals with access to private data must be aware of their responsibilities under the Minnesota Government Data Practices Act (MGDPA). A best practice is to document regular training on data practices to each staff with access to applications or household information. The Department of Administration’s Data Practices office website https://mn.gov/admin/data- practices/data/rules/ provides links to laws, requirements, and general guidance on Minnesota data practices law. Application Documentation Collecting, creating and maintaining data about individuals and households is a necessary outcome of the Energy Programs’ processes for application, eligibility determination and benefit and services provision. Information can be collected, created, and maintained using manual or electronic means. Whatever method is used, information must be accessible for the purposes of program administration, evaluation research and as requested by the data subject. eHEAT is one source of electronic files. eHEAT software is an on-line database incorporating most of the business practices needed to operate EAP, especially collecting, creating and maintaining data about individuals and households and providing eligibility and household information for WAP and CIP. Electronic files include but are not limited to: • eHEAT files accessible using the household number, a unique identification number assigned by eHEAT to each applicant household. • Scanned electronic copies of hard (paper) documents. • Electronic documents created using entered or downloaded private information about an applicant or household and maintained in a Service Provider network, computer directories or electronic storage media (e.g., flash drive, CD). • Email messages.