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DP180.8b    The complaint should be submitted by the complainant and/or his/her designee
                                            as soon as possible to:

                                               Director or Information Technology, Privacy and Data Security
                                               Goodwill‐Easter Seals Minnesota
                                               553 Fairview Avenue N
                                               Saint Paul, MN 55412

        Director of Information   DP180.9a   The Director of Information Technology, Privacy and Data Security shall review
        Technology, Privacy and             the complaint for completeness, validity and jurisdiction.  As soon as possible
        Data Security                       following receipt of the complaint, the Director of Information Technology,
                                            Privacy and Data Security will contact the complainant to discuss the complaint
                                            and possible solutions.
                                DP180.9b    The Director of Information Technology, Privacy and Data Security shall make all
                                            parties to the complaint aware of the alleged violation, obtain additional
                                            information related to the complaint if necessary, and shall attempt to resolve
                                            the complaint.

                                DP180.9c    Within 10 calendar days after the contact, the Director of Information
                                            Technology, Privacy and Data Security will respond in writing, and where
                                            appropriate, in a format accessible to the complainant, such as large print,
                                            Braille, or audio tape.  The response will explain the position of Goodwill‐Easter
                                            Seals Minnesota and offer options for substantive resolution of the complaint.
                                DP180.9d    If the response by the Director of Information Technology, Privacy and Data
                                            Security does not satisfactorily resolve the issue, the complainant and/or his or
                                            her designee may appeal the decision of the Director of Information Technology,
                                            Privacy and Data Security to the Chief Services and Programs Officer or his or her
                                            designee within 30 calendar days after receipt of the response.

                                DP180.9e    Within 30 calendar days after receipt of the appeal, the Chief Services and
                                            Programs Officer or his or her designee will contact the complainant to review the
                                            complaint and discuss possible resolution.  Within 15 calendar days after the
                                            meeting, the Chief Services and Programs Officer or his or her designee will
                                            respond to the complainant with a final resolution of the complaint.  The
                                            response will be in writing, and where appropriate, in a format accessible to the
                                            complainant. If the response by the Chief Services and Programs Officer does not
                                            satisfactorily resolve the issue, the complainant and/or his or her designee may
                                            appeal the decision to the President and CEO or his or her designee following the
                                            same process.
                                DP180.9f    All complaints received by the Director of Information Technology, Privacy and
                                            Data Security, appeals to the Chief Services and Programs Officer, and responses
                                            from the Director of Information Technology, Privacy and Data Security or
                                            President & CEO or designee, will be kept by Goodwill‐ Easter Seals Minnesota
                                            for six years.

        Privacy and Data        DP180.10    The organization will not retaliate against employees, individuals, or others for:
        Security Officer
                                DP180.10a   1)    exercising any right under, or participating in any process established by
                                            federal, state, or local, law, regulations, or policy;
                                DP180.10b   2)    filing a complaint with the organization or the Department of Health and
                                            Human Services;
                                DP180.10c   3)    testifying, assisting, or participating in an investigation, compliance review,
                                            proceeding, or hearing; or






         GES CONFIDENTIAL                                                                                    42
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