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EAP Policy Manual FFY24 Chapter 15 Energy Vendors Page 21 Services available to an energy vendor's customers in general cannot be denied to a household solely because of the household's EAP eligibility. These services may include: • Availability of price and fee list. • Deferred payments. • Budget payment plans. • Conditions of sale, credit, delivery or price. • Discounts for cash or prompt payment. • Any service designed to benefit or assist the energy vendor's customer. In addition, propane dealers are required to comply with the following: Price and Fee Disclosure, Budget Payment Plan, Propane Purchase Contracts, and Terms of Sale in Minn. Stat. §§ 216B.0992 - 0995. This includes making available the cash price or other applicable discount programs to EAP households. It is not discrimination under the statute to provide additional benefits for households receiving EAP services. Additional benefits, especially those that increase the buying power of EAP grants, are desirable and encouraged and can be included as leveraging activities. Data Privacy Energy vendors are responsible for protecting personally identifiable information (PII). EAP information, including application and eligibility status of households, is classified as private data under the Minnesota Government Data Practices Act (MGDPA), Minn. Stat. § 13. Immediately report possible violations to Commerce. When communicating with Service Providers about EAP participants, energy vendors should use EAP household numbers instead of names, addresses or other PII. For example, use “HH 123456” instead of “John Doe.” If it is necessary to use PII like names or addresses, energy vendors must use a secure form of communication such as encrypted email. Sharing EAP Private Data With Energy Vendors Applicants sign the EAP application to authorize use of their private data to determine eligibility and provide EAP services. New uses of the data contained in the EAP application or the household’s file require a new authorization from the data subject. The household data collected by EAP has restricted uses. Generally, an EAP household’s consent allows use of their data only for determining and delivering EAP services. Use of EAP household private data details are in Your Rights and Responsibilities Privacy Notice (also known as the Privacy Notice) and the “Consent and Signature” Part of the Minnesota Energy Programs Application provided to the households.