Page 307
EAP Policy Manual FFY24 Chapter 16 Mechanical Contractors Page 11 • There are corrective actions the Service Provider or contractor considers necessary before providing eligible services. • The household has a documented history of causing or creating inappropriate no heat situations requiring on-site service calls or mechanical services. Data Privacy Mechanical contractors must protect personally identifiable information (PII). EAP information, including household application and eligibility status, 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, mechanical contractors should use EAP household numbers instead of names, addresses or other PII. For example, use “HH 123456” instead of “John Doe.” If the use of PII is necessary, mechanical contractors must use a secure form of communication. For example, use encryption when emailing invoices, completion certificates, inspection forms, or other documents containing names or addresses. Non-Discrimination Mechanical contractors cannot penalize or discriminate against customers for participating in EAP. The Low-Income Home Energy Assistance Act of 1981 (42 U.S.C. § 8624(b)) states that an EAP eligible household must not be treated adversely or differently from other households because of receiving EAP assistance. Safe at Home Program EAP follows the guidelines of the Safe at Home (SAH) program, which helps survivors of domestic violence, sexual assault, stalking, or others who fear for their safety to establish a confidential address. SAH allows its participants to go about their lives without leaving traces of where they live to keep their abuser from locating them. Participants use a SAH assigned address and the Secretary of State’s office forwards their correspondence to their actual mailing address. SAH participants cannot be required to disclose their physical address. The SAH Program may be contacted at 1-866-723-3035 with questions or to confirm a SAH applicant’s participation in SAH. Mechanical contractors must work with Service Providers to safeguard SAH participants’ identity and address. Mechanical contractors must keep the SAH participants’ names separate from their home address. For example, if a work ticket, invoice, or other documentation is generated, use the SAH participant’s EAP household number not their name. This is to reduce the paper trail as much as possible and never link the SAH participant’s name and address.