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PRIVACY POLICIES [DP111]
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        Scope: Enterprise
        Distribution: Executive Leadership Team; Director of Information Technology, Privacy and Data Security
        Purpose: To document the Privacy Steering Committee’s direction with regard to information privacy.
        External Regulation or Standard: GAPP Principle 1: Management


        Who is Responsible    Statement     Policy, Standard, or Procedure Statement
                              Number
        Director of Information   DP111.1   The Director of Information Technology, Privacy and Data Security will
        Technology, Privacy and             maintain the organization's information‐privacy documentation in a way that
        Data Security                       is up to date and easily accessible by the organization.

        Director of Information   DP111.2   The organization's privacy policies will be organized according to the Generally
        Technology, Privacy and             Accepted Privacy Principles framework, HIPAA Privacy Rule, Minnesota
        Data Security                       Government Data Practices Act, and other applicable regulations and
                                            standards.

        Director of Information   DP111.3   The organization will retain the most recent version of its information‐privacy
        Technology, Privacy and             policies if they are in effect, plus an additional year.
        Data Security
        Director of Information   DP111.4   The Director of Information Technology, Privacy and Data Security will
        Technology, Privacy and             administer policy waivers and exceptions, consulting the Privacy Steering
        Data Security                       Committee as appropriate.
        Director of Information   DP111.5   The Director of Information Technology, Privacy and Data Security will initiate
        Technology, Privacy and             an annual review of the organization's information‐privacy policies to
        Data Security                       determine and propose to the Privacy Steering Committee if new risks or
                                            compliance obligations merit policy changes or additions.








































         GES CONFIDENTIAL                                                                                    19
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