89-692 =N T C I T Y O F s I T �A U L Council �y.
File N0. d`����
Council solution �j����;
_ .�
Pr. ated By
Referred To Committee: Date
Out of Committee By Date
WHERrAS , the Minnesot overnment Data Practices Act and
Minnesota Department of d nistration Rules which implement
that Act require state an ocal government offices to develop
guidelines and procedu-res f r providing access to the data it
develops , receives and mai ta ns ; now, therefore, be it
RESOLVED, that the u cil hereby adopts the attached "City
of Saint Paul Guidelines a Procedures for City Council Offices
in Compliance with the in esota Government Data Practices Act"
and the "Data Retrieval F es Policy" incorporated by reference
in those guidelines and ro edures.
COUNCIL MEMBERS Requested by Department of:
Yeas Nays
Dimond
�� In Favor
Goswitz
Rettman C B
Scheibel A gai n s t Y
Sonnen
Wilson
Adopted by Council: Date
MAY — 4 �989 Form Approved by City Attorney
` B �Cc�Lc_Q_- ,� • �2�C�1�� '�—/!'1��i'
Certified Yas ed un il S t y—
By
Approve iVlavor. —
�� Appcoved by Mayor for Submission to Council
.
By — BY
P Bt c,�j�Y 131989
��-�qz
Date: Friday, Apri 7, 1989
Members:
Kiki Sonnen,Chair
Roger Goswitz
Bob Long
Staff:
Donna Sanders,Secretary
Jane McPeak,Attorney
Committee Report
Rules and Policy o mittee
1. Approval of minutes of the Ma ch , 1989 meeting.
COMMITTEE APPROVED
. DISCUSSION OF CITY COUNCIL'S A PRACTICES, GUIDELINES & PROCEDURES.�`_:�
(Heard itt R & P Committee 12 16 88, 1/6/89, 3/3/$9 and �aid over until
:�/�-�. � .4�
Cp��,��T"�F��. COMME�iI�,.APP�iO L
3. ORDINANCE ��89-463 - An ordi an e amending Chapter 28 of the Saint Paul
Legislative Code entitled " a aign Contributions" to provide for
conformity to state statut a to time limits for filing financial
reports prior to primary a d eneral elections.
COMMITTEE RECOMMENDED LAY E OF SUBSTITUTE ORDINANCES TO MAY 5, 1989
4. ORDINANCE 4�89-425 - An or in nce amending Chapter 15 of the
Administrative Code pert 'n g to meetings of the Council, Committees,
Boards and Commissions b d leting notice requirements that conflict
with state law.
COMMITTEE RECOMMENDED AP RO AL OF SUBSTITUTE ORDINANCE
5. ORDINANCE 4�88-623 - An rd nance amending Chapter 24 of the Saint Paul
Administrative Code per ai ing to a code of ethics for city employees
and officials.
COMMITTEE RECOMMENDED ND FINITE LAYOVER BUT DIRECTED GERRY STRATHMAN
TO PREPARE RULES FOR P IV TE USE OF GOVERNMENT PROPERTY FOR COUNCIL
OFFICES AND COUNCIL R SE CH AND CABLE OFFICES, AND RECOMMENDED
INTRODUCTION OF NEW 0 I ANCE REGARDING LIMITATION OF NUMBER OF TICKETS
AS GIFTS
lfi'0�"`� 'o`
GITY OF AINT PAUL
�ut�Il�
CTTY COUNCIL INVEST A ION AND RESEARCH CENTER
M E M 0 R A N D U M
DATE: April 13, 1989
T0: A1 Olson, City Clerk
FROM: Donna Sanders, Recording Se ret ry
Rules & Policy Committee
RE: APRIL 7, 1989 COMMITTEE REP RT ENCLOSURES
The following materials have been nc osed with the Committee Report for
the April 7, 1989 meeting of the R le & Policy Committee:
1) NEW COUNCIL RESOLUTION - to ado t he City of Saint Paul Guidelines and
Procedures for City Council Off ce in Compliance with the Minnesota
Government Data Practices Act, pr 1 1989 - Item ��2 of Report
(Note: Please put this item on Th rsda , 4/20/89 Council A enda as
Councilmember Sonnen wants Jane Mc eak to provide an explanation and
McPeak would not be able to att nd any other meeting until 5/16/89.)
2) CURRENT COPY OF MINNESOTA GOVE T DATA PRACTICES ACT, APRIL 1989 -
Item 4�2 of Report
3) SUBSTITUTE ORDINANCE ��89-463 - It 4�3 of Report
4) SUBSTITUTE ORDINANCE ��89-425 - It m ��4 of Report
5) NEW ORDINANCE - off-shoot of I em ��5 of Report
DMS/
CITY HALL SEVENTH FLOOR SAINT PAUL,MINNESOTA 55102 612/298-4163
s�aa
��9��9�
C N ENTS
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
I . COLLECTION, STORAGE, AND' D 5POSITION OF
GOVERNMENTDATA . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Collection . . . . . . . . . . . . . . . . . . . . . . 2
Storage and Dispositi n . . . . . . . . . . . . . . . . . . 2
II . CLASSIFICATION OF GOVER E T DATA . . . . . . . . . . . . . 3
General Premise . . . . . . . . . . . . . . . . . . . . . . 3
Data on Individual • , , , , , , , , , , , , , , , , , 3
Summary Data . . . . . . . . . . . . . . . . . . _ . . . 5
Data Not on Indivi ua s . . . . . . . . . . . . . . . . . . 5
III . TEMPORARY CLASSIFICATIO , , , , , , , , , , , , , , , , , , , , , 6
IV. DATA MAINTAINED BY THE IT , , , , , , , , , , , , , , , , , , , 6
_
V. REQUESTS FOR GOVERNMENT DA A . . . . . . . . . . . . . � , . . � 101
Requests for Data G neral . . . . . . . . . . . . . . 10!
Requests for Data n Individ uals
by the Data Subj c , . , , , , , , , , , , , 12
Requests for Summa y Data . . . . . . . . . . . . . . . 12
Requests for Gover m nt Data by
Other Government A encies . . . . . . . . . . . . . . 14
Requests for all 0 h r
Government Data . . . . . . . . . . . . . . . . . . . . . 15
Denying Requests f r .Access
to Government Da a . . . . . . . . . . . . . . . . . . . . . 15
VI . ANNUAL INVENTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
VII . VIOLATION OF THE ACT . . . . . . . . . . . . . . . . . . . . . . . . 16
i .
��g-���
PP NDIX
A. Minnesota Governme t ata Practices Act
A1. Rules of the Depar me t of Administration,
Data Privacy Divis on
B. Minnesota Statutes Se tions 138. 161=138. 226
(Records Retention
C. City of Saint Paul Da a Retrieval Fees Policy
D. Application for Te po ary Classification of
Data on Individual a Private or Confidential
D1. Application for Te po ary Classification of
Data Not on Indivi ua s as Nonpublic or
Protected Nonpubli
E. Office Inventory
ii .
���-��
INT OD CTION
The Minnesota Governm ent Dat P actices Act, found at Minnesota
Statutes Sections 13.01 - 13 9�J, regulates all government data
collected , received , mainta n d, disseminated or stored by a
state agency, political subd v ' sion or state=wide system. See
Appendix A, A1 .
Minnesota Statutes Sectio s 138 . 161 -- 138.226 governs the
retention, storage, and dis o ition of governm ent data. See
Appendix B.
The City Council has adopt d the Data Retrieval Fees Policy
implem ented by Executive O d r on November 11 , 1986. See
Appendix C.
These policies and procedures ar written to assist you in making
decisions in the areas listed a ove. If you have any questions,
please call the City Attorney s ffice at 298-5121 .
1.
���-��a
I . COLLECTION, STORAGE AND D S OSITION OF GOVERNMENT DATA
A. Collection.
Government records ' n lude all cards, correspondence,
discs , maps , me o anda , microfilms , papers ,
photographs, record 'ng , reports, tapes, writings, and
other data, infor a ion or docum entary material ,
regardless of physic 1 form or characteristics, storage
m edia or condition f use, made or received by an
officer or agency o t is city pursuant to state law or
in connection with ransaction of public business by
an officer or agenc .
Government records xc ude data and inform ation that do
not become part of n fficial transaction; library and
museum material ma e or acquired and kept solely for
reference or exh b ' t purposes ; extra copies of
docum ents kept onl or convenience of reference or
stock of publicat ' on or processed documents; and
bonds, coupons or ot er obligations or evidence of
indebtedness whose e truction or other disposition is
governed by other 1 ws
The inform ation colle ted must be accurate, com plete,
and current for h purposes for which it was
collected. At any i e a data subject may contest the
accuracy and comple en ss of the data .
B. Storage and Disposi io .
While som e records u t be kept for a period prescribed
by law, a speci i retention period for many
government records i not prescribed. Those records
may not be dispose f without the prior approval of
the Records Dis o ition Panel . Unauthorized
destruction of gove n ent records is a misdemeanor.
To obtain applica i n forms for either a records
retention schedule or dispositon of specific records,
contact the Reco d Management Division of the
Minnesota Departmen f Administration at 296-0257.
Each Council offic ust keep its records in such an
arrangement and con ition as to make them easily
accessible for conv n 'ent use .
��G-��
II . CLASSIFICATION OF GOVER E T DATA
A. General Premise.
All qovernment da a is presumed to be public unless
otherwise classi ie by state statute, temporary
classification or f deral law. Minnesota Statutes
Section 13. 03, Sub . .
B. Data on Individual .
Data on individual eans all government data in which
any individual is r can be identified as the subject
of the data unless t appearance of the nam e or other
identifying data c 'n e clearly demonstrated to be only
incidental to the at and the data are not accessed by
the name or other de tifying data of any individ ual .
Public data on i !di iduals is data on individuals,
living or dead, hi h is accessible to the public.
Unless classified th rwise by state or federal law or
temporary classif ' c tion, all data on individuals is
accessible to the u lic regardless of its interest in
the data.
Private data on in ividuals is data which is not
accessible to the u lic but is accessible to the data
subject. Data n individuals is private if so
classified by s at or federal law or tem porary
classification. ' In addition to the data subject,
private data is a so accessible to the data subject's
representative, in i iduals, entities or persons given
express written er ission by the data subject, a
minor' s parent or g ardian or individual acting as
parent or guardia , ersonnel within the governm ental
entity whose wo k assignments reasonably require
access, individual , entities or persons authorized by
state or federal 1 w, and pursuant to a court order .
Except when asked o upply investigative data to a law
enforcement offi er , an individual asked to supply
private data conce ' ning the individual must be inform ed
of certain facts as set forth in Minnesota Statutes
Section 13. 4l4, Sub . 2. This is known as the Tennessen
Warning .
3.
L��y��9�
Private data on dece e ts means data which, prior to
the death of a data 'ub ' ect, were classified by state
or federal law or te p rary classification as private
data. Private data n ecedents is accessible to the
representative of th ecedent, the trustee appointed
in a wrongful death ac ion, individuals, entities or
persons given expre s ritten permission by the data
subject or the repre en ative of the decedent, persons,
individuals or entit e authorized by state or federal
law, personnel withi t e entity whose work assignm ents
reasonably require ac ess, and pursuant to a court
order. Private dat o decedents is public ten years
after the actual or r sumed death of the data subject
and thirty years aft r the creation of the data.
Confidential data n ndividuals means data which by
state or federal law o tem porary classification is not
accessible to the p bl c or to the subject of the data.
Confidential data on individuals is accessible to
individuals authori ed by state or federal law,
personnel within t e entity whose work assignm ents
reasonably require a cess , and pursuant to a court
order.
Except when asked t upply investigative data to a law
enforcem ent offic r , an individual asked to supply
confidential data co cerning the individual must be
informed of certa ' n acts as set forth in Minnesota
Statutes Section 1 .� , Subd. 2.
Confidential data n ecedents means data which, prior
to the death of a d ta subject, were classified by
state or federal aw or tem porary classification as
confidential data. onfidential data on decedents is
accessible to in i iduals authorized by state or
federal law, pers n el within the entity whose work
assignments reason bl require access, and pursuant to
a court order. on idential data on decendents is
public ten years a t r the actual or presumed death of
the data subject a d thirty years after the creation of
the data.
4.
���-� ��
C. SUMMARY DATA
Sum mary data mean s atistical records and reports
derived from data on individuals but in which the
individuals are not in any way identifiable.
Summ ary data is pub ic data unless otherwise classified
by state or federal la or temporary classification.
D. DATA NOT ON INDIVID AL
Public data not on i ividuals is data accessible to
the public unless ot erwise classified by state or
federal law or tem p r ry classification.
Nonpublic data not on individuals means data which is
not public but is a cessible to the subject of the
data, i f any. As u e here, the "subj ect of the data"
m eans an individu 1 , partnership, corporation, etc.
Data not on indivi uals is nonpublic if so classified
by state or federa aw or temporary classification.
Nonpublic data is a cessible to the subject of the
data , if any, i dividuals , entities or persons
authorized by stat r federal law, personnel within
the entity whose or assignments reasonably require
access, and pursua t o a court order.
Except for securit nform ation, nonpublic data shall
become public ten y ars after the data was createa,
collected or rec ' i ed by the governmental agency.
Access may be deni d f release of the data will result
in a harm to the pu 1 ' c or data subject which outweighs
the benefit to the , p blic.
Protected nonpublic d ta not on individuals means data
which is not publ 'c nd not accessible to the subject
of the data. Da a not on individuals is protected
nonpubl ic i f so c as i f ied by state or federal law or
temporary classifi a ion. Protected nonpublic data is
accessible to i d viduals , entities or persons
authorized by sta e or federal law, personnel within
the entity whose o k assignments reasonably require
access, and pursu 'nt to a court order.
5.
�� ��-�p / �
Except for security i f rmation, protected nonpublic
data shall become pub i ten years after the data was
created , collected o eceived by the governm ental
agency. Access may e enied if release of the data
will result in a har o the public or aata subject
which outweighs the b ne it to the public.
III . TEMPORARY CLASSIFICATION
Unless a state or fede a law expressly classifies
government data as not pu li (i.e., private, confidential,
nonpublic or protected no p blic) , the data is public and
accessible to anyone. Th t mporary classification system
was established to recl �ss fy data when a governm ental
agency has a com pellin eason to protect otherwise
unprotected data.
Temporary classification f r s may be obtained from the Data
Privacy Division of the S a Departm ent of Administration
(298-6733 ) . See Appendi and D1. The City Attorney' s
Office will assist you in o pleting the forms.
IV. DATA MAINTAINED BY THE CIT ND SPECIFICALLY CLASSIFIED BY
STATE STATUTE* r -`
Appraisal data = Section 13 . g
Confidential or prote ted nonpublic = estimated or
appraised values of ' nd vidual parcels of real property
to be sold or a q ired through purchase or
condemnation.
* The data classifications i ted are dependent on a number of
factors and may cha g back and forth from one
classification to another. Reference should always be made
to the specific statuto y section. The City Attorney' s
Office is available to o fe assistance in interpreting the
statute.
6
���_�9�
The above becomes pub ic upon the occurrence of any of the
following:
a) the negotiati�ng parties exchange appraisals;
b) the data ar ubmitted to a court appointed
condemnation �co missioner;
c) the data are p esented in court in condemnation
proceedings; or
d) the negotiat ' n parties enter into an agreem ent
for the purc �as and sale of the property.
Assessor ' s data = Secti n 13 . 51
Private or non=pu li
1 . Data contai ed on sales sheets received from
private mul ip e listing service organizations
where the co tr ct with the organizations requires
the politica s bdivision to refrain from making
the data availa le to the public.
2. Income property assessment data
(a) detaile i come and expense figures for the
current ye r plus the previous three years;
(b) averag acancy factors for the three
previous y ars;
(c) verifie et rentable areas or net useable
areas, i hever is appropriate;
(d) anticip t d income and expenses for the
current e r ; and
(e) project d vacancy factor for the current
year.
7.
���-10��
Attorney' s data - Section '13 30
Governed by statute, ru es, and professsional standards
"Notwithstanding th rovisions of this chapter and
section 15 . 17 , the u e , collection , storage , and
dissemination of d t by an attorney acting in a
professional capacit or the state, a state agency or
a political subdivis 'o shall be governed by statutes,
rules, and professio al standards concerning discovery,
production of docum e t , introduction of evidence, and
professional respons bi ity; provided that this section
shall not be constr ed to affect the applicability of
any statute, other t a this chapter and section 15.17,
which specifically r q ires or prohibits disclosure of
specific informatio y the attorney, nor shall this
section be constr ed to relieve any responsible
authority, other th' n the attorney, from duties and
responsibilities pur u nt to this chapter and section
15. 17. "
Benefit data = Section 13 31
Private
Child abuse data - Sectio s 3 . 82 and 626. 556
l. Confidential
2 . Private
Civic Center Authority da a Section 13 . 55
Nonpublic � ( 1) let, e or other documentation from
an on who makes inquiry to the
au ho ity as to the availability of
au ho ity facilities for staging
ev nt ;
(2) id nt ' ty of firms and corporations
wh ch contact the city;
(3) ty e f events which they wish to
st ge in authority facilities;
(4) su ge ted terms of rentals; and
(5) re po ses of authority staff to
th se inquiries.
8.
��'9��qa
The above non-publ i ata becomes publ ic upon the
occurrence of any of h following:
(1) a lease or cont a t is entered into between the
authority and th 'nquiring party or parties; or
(2) the event does n t occur ; or
(3) the event occurs e sewhere.
Civil Investigative data � S ction 13 . 39
Confidential or prote t d non
�������
Comprehensive Law Enforce e t data = Section 13. 82
Confidential or p otected non - public active
investigative data ; data that reflects the
deliberative process s or investigative techniques
Private or non-publi :
(1) identity data f child abuse or neglect victim
and of the repo t r;
(2) identity data f an undercover law enforcement
officer;
(3) identity data ,of a victim of criminal sexual
conduct or inte � fa ilial sexual abuse;
(4) under certain co ditions, identity data of an
informant;
(5) under certain c nd ' tions, identity data of a crim e
victim or witne s;
(6) data that uniqu ly describes stolen , lost ,
confiscated or r covered property or property
described in pa n hop transaction records;
(7) under certain c nd ' tions , reward program data.
Public :
(1) certain arrest at ;
(2) certain request fo service data;
(3) certain respons ' o incident data;
(4) inactive invest"ga ive data.
Corrections and Detention da a = Section 13. 85
l. Private
2 . Confidential
10
���-���
Criminal History data - Se 'ti n 13. 87
Private - data m aintain d in criminal history record s
com piled by the BCA and disseminated through the
criminal justice info m tion system; includes, but is
not limited to fi gerprints , photographs ,
identification data , a rest data , prosecution data ,
criminal court data , us ody and supervision data .
Deferred Assessment data - Se tion 13. 52
Private
Domestic Abuse data - Sect o 13 . 80
1. Confidential
2. Private
Economic Assistance data -' S ction 13. 62
Nonpublic
Educational 8ata =- Section' 1 . 32
Student health data - p ivate
Elected officials' corres 'on ence - Section 13 . 33
"Correspondence betw en individuals and elected
officials is privat d ta on individuals, but may be
made public by eithe t e sender or recipient ."
Elected or appointed o'ff cials' financial disclosure
statements -- Section 13. 6
"Financial disclo u e statements of elected or
appointed official hich, by requirem ent of the
political subdivision are filed with the political
subdivision, are pub ic data on individuals ."
Employment and Training d t - Section 13. 47
Pr iva te
Examination data - Sectio 3. 34
Nonpublic
1 .
���--���
Federal contracts data =- e tion 13. 33
Nonpublic
Firearms data - Section 1 . 6
Pr ivate
Foster Care data -- Sectio 13. 53
Confidential
Health data -- Section 13 . 8
Pr i va te
Homestead Application dat - Section 13. 58
Private - social e urity numbers and detailed
financial data submitt d by an individual applying for
a special homestead classification pursuant to
Minnesota Statutes S c ion 273.13. Individuals who may
apply if they meet c rtain requirements are blind
persons, veterans, d�is bled persons, and persons whose
household income fal s elow a specific amount .
Housing Agency data - Sec io 13 . 54
1. Confidential
2. Protected Nonpub ic
3. Nonpublic
Human Rights Department d ta - temporary classification
1. Confidential
2. Private
Investigative Detention d 'ta - Section 13 . 86
Confidential
Labor Relations data - Se ti n 13 . 37
Nonpublic - m anagem e t positions on economic and non-
economic items that a e not been presented during the
collective bargainin ' rocess or interest arbitration,
including inform atio s ecifically collected or created
to prepare the manag me t position.
12
���q�
Protected non-pu lic - specific labor relations
information as se orth above, which relates to a
specific labor orga iz tion.
Library data '- Section 1 . 441
Private
Maltreatment of Vulnerab e Adults data - Sections 13. 82
and 626. 551
1 . Confidential
2. Private
Medical data - 5ection 1 . 2
Private
Personnel data - Section l . 43
With regard to cu rent and former employees ,
volunteers, indep nd nt contractors , and members of
advisory boards o ommissions, only the following
information is public Everything else is private.
Nam e; actual gross sa ary; salary range; contract fees;
actual gross pensi n; the value and nature of em ployer
paid fringe benefits the basis for and the amount of
any added rem n ration , including expense
reimbursement, in ad ition to salary; job title; job
description ; edu a ion and training background;
previous work ex erience; date of first and last
em ployment; the s a us of any com plaints or charges
against the emplo ee whether or not the complaint or
charge resulted in a isciplinary action; and the final
disposition of any d sciplinary action and supporting
documentation; wor location; a work telephone number;
badge number; hono s nd awards received; payroll time
sheets or other co p rable data that are only used to
account for employ e' work time for payroll purposes,
except to the ext nt that release of time sheet data
would reveal the e pl yee's reasons for the use of sick
or other med ical ea e or other not publ ic data; and
city and county of re idence.
3.
����.�yz
Applicants for empl ym nt :
(1) an apl icant' s a e is pr ivate but becomes publ ic
when certifie s eligible for appointment to a
vacancy or w e considered by the appointing
officer to be inalist for a position .
(2) Public - vete a status ; relevant test scores;
rank on eligib e list; job history; education and
training and w r availability.
This may be r leased at any time without
identifiers. d tifiers m ay be used only when an
applicant's n m becomes public as described in
(1) above.
Private:
1) all personne data relating to an employee or
appl icant fo e ployment as an undercover law
enforcement o fi er ;
2) employee assi ta ce program data.
Labor organizatio s ay have access only to that data
needed to conduct n election, to notify employees of
fair share fee a s ssments and to implement the
provisions of the ub ic Employees Labor Relations Act .
When ordered or u horized by the director of the
bureau of inediati n services, personnel data must be
m ade available t abor organizations and to the
bureau.
Saint Paul Port Authori y ata = Section 13 . 551
Protected non-publ c until 30 days before the date of a
hearing on a pr po ed sale pursuant to Minnesota
Statutes Section 4 5.196 =�= financial studies and
reports that are p r of appraisers' estim ates of value
of or concerning p ojects defined in Chapter 474 ,
prepared by per o nel of the Port Authority or
independent acco nt nts , consultants , and appraisers
for the purpose o m rketing by sale or lease a project
which the Port Aut o ity has acquired or repossessed as
the result of the de ault under and the termination of
a revenue agreement efined in Chapter 474.
14.
���-� 9�
Property Complaint data S ction 13. 44
Confidential -- ide ti ies of individuals who register
complaints with s ate agencies or political
subdivisions conce n ' ng violations of state laws or
local ordinances co e ing the use of real property.
Redevelopment data - Sectio 13 . 59
Private =- names and a dresses of individuals and legal
descriptions of prop r y collected in surveys conducted
for planning, develo m nt and redevelopment purposes .
Non=public =- nam es, ddresses and legal descriptions
of business propert ' e and the com mercial use of the
property, to the exte t disclosure of the use would
identify a specifi business, collected in surveys
conducted for planni g, development, and redevelopment
purposes.
Salary Benefit Survey dat =- Section 13. 45
Non=public =- salary a personnel benefit survey data
purchased from c n ulting firms , non =profit
corporations or asso ia ions or obtained from em ployers
with the written und r tanding that the data shall not
be m ade publ ic.
Security Information data '- ection 13. 37
Nonpublic
Trade Secret Information d t '= Section 13 . 37
Private or non=publi -'° government data, includinq a
form ula, pattern, com i ation, program, device, m ethod ,
technique, or process
(1) that was suppli d by the affected individual or
organization,
(2) that is the subjec of efforts by the individual
or organization t at are reasonable under the
circumstances to ma'ntain its secrecy, and
5.
��-��q�
(3) that derives ind pe dent economic value, actual or
potential, from o being generally kno wn to, and
not being readi y scertainable by proper means
by, other perso s who can obtain economic value
from its disclos r or use.
Traffic Accident Reports r q ired to be filed by Minnesota
Statutes Chapter 169 - Sec i n 169. fd9
Confidential
Welfare data - Section 13. 6
1. Confidential
2. Private
V. REQUESTS FOR GO`7ERNMENT DA A
A. Requests for Data =- G n ral .
1. To Councilmembers
Councilm embers m y process requests for data
within their o n offices. Generally, any data
provided to a c u ilmember by a city department
or office or an o tside agency, organization or
person are publi . There are, ho wever , exceptions
to this general r le and you are encouraged to
contact the Ci y Attorney' s Office for advice
should you h ve an uncertainty about the
classification of ata that com es to you.
For example:
1 . Public off c als correspondence is private
unless the r ter OR recipient choose to make
it public. —
2. The identi y f an ind ividual reg ister ing a
com plaint b ut someone else's use of real
property ' s confidential and may only be
released o those whose work assignments
reasonably re uire acccess.
16
�C'�'C�-fp9.Z
As a general ru e information generated by your
office is availab e to the public. Again, there
are exceptions nd you are encouraged to seek the
advice of t e City Attorney's Office. For
example, some p rs nnel data which you maintain on
your em ployees s vailable to the public; some is
private and av ilable only to the em ployee , the
employee's desi ne , those whose work assignments
reasonably requ re access, and anyone with a court
order requiring r lease.
2. To Council Inve ti ation & Research Bureau
Upon reques to the Director of the
Council Investig tion and Research Center , an
authorized ind v 'dual , entity or person shall be
permitted to i s ect and copy government data at
reasonable ti es and places and if the party
reguests , s/he s all be informed of the data's
meaning .
3. General Standar s
a . If the r q est is unclear or for many
documents or for a variety of information or
the data i not easily retrievable and
involves t e collating of data from a number
of sources, ou may require the request to be
put in wr ' ti g.
b, Regardles f where the data originates, if
it is in o r possession, it is government
data and ub 'ect to the access provisions of
the law.
c. Requested i formation is to be released as
promptly s circumstances allow and in an
impartial , ourteous and objective manner .
Data may ot be withheld , delayed or
selective y released to favor any person,
agency o edia. Specific independent
inquiries e pecially from the media, are to
be honore i the order received.
1 .
1����9�
4. Fees
Fees may be c a ged . See the data retrieval
policy (Appendi C) .
B. Requests for Data on In ividuals by the Data Subject.
Upon request and whe cess/copies are authorized, the
designee shall provi e copies of the private or public
data on individuals to the subject of the data or the
subject' s authorized re resentative.
The designee shall c m ly imm ediately, if possible, or
within five working a s of the date of the request if
immediate com plia c is not possible. If the
responsible authori y r designee cannot comply with
the request within h t time, s/he shall inform the
requestor, and may h ve an additional five working days
within which to compl ith the request.
If access is authori e , the responsible authority or
designee must suppl he requested data within ten
working days .
If the requested data is classified so as to deny
access to the data su j ct, then see G.
C. Requests for Summary a .
Unless classified by a state statute , federal law or
temporary classi f ic ti n, summary data der ived from
private or confident al data on individuals is public
and the responsible a th rity or designee shall prepare
the summary data u on the written request of any
i nd iv id ual or per son.
Within ten days of r ceipt of such request , the
responsible authorit r designee shall inform the
requestor of the es i ated costs of preparing the
summary data, if any.
The responsible autho it or the designee shall :
1. Provide the sum a y data requested as soon as
reasonably possib e OR
1 .
��� �q�
2. Provide a wri t n statement to the requestor,
giving a time s h dule for preparing the requested
data , including r asons for any delays ; OR
3. Provide access to the requestor to the private or
confidential a a so that the requestor can
com pile the sum a y. Such access will be provided
only when the re uestor signs a non-disclosure
agrement; OR
4 . Provide a wri t n statem ent to the requestor
stating reason hy the requestor' s access would
com promise the r 'vate or confidential data .
A NON-DISCLOSURE A R EMENT is used to protect the
confidentiality of ov rnm ent data when the requestor
of the summary da a will prepare the summary by
accessing private o c nfidential data on individuals.
A nonLdisclosure ag ee ent shall contain at least the
following :
l . A general d scription of the private or
confidential d t which is being used to prepare
summary data ;
2. The purpose fo hich the summary data is being
prepared;
3. A statement th t the preparer ( requestor)
understands s/ e may be subject to the civil or
criminal pena ty provisions of the Act in the
event that the p ivate or confidential data is
disclosed;
4. A section in w i h the preparer (requestor) , in
consideration f r being given access to private or
confidential da a agrees not to disclose data in
any form that ould identify or tend to identify
an individual nd that s/he also agrees to defend
and indemnify h City of Saint Paul and any of
its employees in any legal actions brought as a
result of his he having access to private or
confidential d ta
5. A description f the civil and criminal penalty
provisions of t e Act.
1
���9�.
6. The signature of the requestor and the responsible
authority, de ig ee or his/her representative.
D. Requests for Gov r m ent Data by Other Governm ent
Agencies.
A responsible auth r ty may allow another responsible
authority access to data classified as other than
public ONLY when t e access is authorized or required
by state statute o f deral law.
An agency that sup li s governm ent data m ay require the
requesting agency to pay the actual cost of supplying
the data when the eq ested data is NOT provided in the
normal course of b si ess and NOT required by state or
federal law.
Data shall have th s me classification in the hands of
the agency recei i g it as it had in the agency
providing it unles he classification is required to
change to m eet jud 'ci 1 or administrative requirem ents.
When practical and n cessary, the agency providing the
requested informat 'on shall indicate the classification
of the informatio if the data is classified as "not
public" .
When necessary, th r questing agency, if not listed on
the "Tennessen War in ", should obtain inform ed consent
from the data subj c (s) for information classified as
private or confid nt al. Minnesota Statutes Section
13. 04 , Subd . 2.
E. Requests for all 0 he Government Data .
For requests from a ties other than individual data
subjects or govern en agencies or persons, when access
is authorized , the r sponsible authority or designee
should provide data o request .
If access is autho i ed and the responsible authority
or designee is not a le to provide copies at the time
the request is mad , s/he shall supply copies as soon
as reasonably possi 1 .
�.
���G��.
F. Denying Requests for A cess to Government Data .
Access to government ata may be denied when the data
is classified by st t statute or federal law as not
accessible to the re u stor .
Any person denied a c ss to government data shall be
inform ed orally at t e time of the request or in
writing as soon af e that tim e as possible of the
specific state statu e, federal law or temporary
classification upon h 'ch the denial is based .
Further , upon the r q est of any person denied acess,
the responsible aut r ty or designee shall certify in
writing that the req e t for access has been denied and
cite the specific s ate statute , federal law or
tem porary classifi a ion upon which the denial was
based .
VI . ANNIIAL INVENTORY
By August 1 of each cal nd r year , each department shall
file copies of its update i ventory with the Offices of the
City Attorney and of th ity Clerk. If the department
determines that the da a istings are complete and the
classifications unchanged hen a letter stating these facts
may be filed in lieu of n pdated inventory. See Appendix
E for your department' s i v tory.
VII . VIOLATION OF THE ACT
A non�-willful violatio ay be punished by assessment
against the City of d m ges suffered by the person
aggrieved. In the case of a willful violation, the City
may, in addition, be liab e o exem plary dam ages of not less
than $ 1001 nor more th n $ 10 , gPJ0 for each violation.
Minnesota Statutes 5ectio 3.A8, Subd. 1.
A person who willfully vi lates the Act is guilty of a
misdemeanor. Willful vi la ion constitutes just cause for
suspension without pay r ismissal , Minnesota Statutes
Section 13. �19.
21
r; . � '� �'� ;�.�,- - (��-�'i-G t�.-
� ! ' �" _� �
.v .�_ R
fC I
CIT O SAINT PAUL �J��D
1NTERDEPAR M TAL MEMORANDUM �
October 29, 1986 , F�S "� 1987
�l TY ATTpR�Y
EY
T0: Department and Office Directo s �
Office Managers
FROM: Mayor George La timer
RE: Implemeating Data Re ieval F es Policy
Attached is the Data Retrieval Fees P li y together with the Executive Order which
provides for an implemeata tion date o N vember 15, 1986.
This policy grew out of discrepancies ia the way various City departmeats/offices
charged for iaforcoatioa aad a consequ nt review by the Citq Attoraey's Office for
compliance with the State Data Practi es Act. The State Law allows a zesponsible �
authority such as ihe City to charge or providing iaformation within certaia
limi ta tions. The Da ta Re trieva 1 Fees Po icy will help to assure tha t our ci tizens
are treated fairly and legally relati e o their right to public data. �
Your previous commeats were integral n riting this policq so many of you are
already familiar with the issues eaco pa sed by it. Briefly, the policy establishes
a f ee s truc ture of:
1. a flat rate of 25 cents per ge (page 3);
2. an op tiona 1 specia 1 ra te ca 1 la ted on s taf f time, copy cos ts, cos t of
materials, etc. (page 3); aa �
3. a commercial rate, e.g. data a s, for public da ta which may have
commercial value (page 3).
There are exceptions in terms of da p vided as part of the aormal course of _
busiaess:
1. publica tions produced for di tr ution to the public (page 2); and
2. fees articulated by state an f deral laW.
The Departmeat of Finance and Manage ea Services Purchasing Storeroom will have an
"Information Disclosure Request & Co y ost Calcula tion Form" in stock af ter
November 5, 1986. Cash receipts gen ra ed should be handled by established City
cash receipts procedures.
If you have further questions about nt rpretation of the policy or implemeatation
please contact Barbara Jeanetta in t e udget Office (298-4323) or Jane McPeak in
the City Attorney's Office (298-4121 .
GL:BJ:fs
cc: City Council Members
Jane McPeak
� �
, � \
• • � r •
. ', •;\
. : •-. • �
� CITY OF SAINT PAUL, MINNESOTA
NOVEMBER 1, 1986
" ' POLICY STATEMENT: DATA RETRIEVAL FEES
I. POLICY �
Pursuant to the Minnesota Government Data Practices Act -
(M.S. c. 13) and unless otherwise provided for by Federal
law, State Statute or rule, fees for obtaining government
data shall be determined by departaients based on the costs
of providing such service. Fees shall be reasonable and
consistent. Fees shall not be charged for viewing of data
only.
Fees may be charged on a flat rate, a special rate or a
commercial rate. Information on appropriate uses and
• calculation of these fees can be found below.
II. RESPONSIBILITIES OF THE CITY ATTORNEY
. The City Attorney has the following .responsibilities:
A. To answer questions and assist departments in .
. implementing these guidelines and procedures.
B. To annually review the Flat Rate fee and the photocopy
cost charged in the Special Rate and recommend
necessary changes to the Budget Director. .
III. RESPONSIBILITIES OF THE BUDGET DIRECTOR �
The Budget Director has the following responsibilities:
A. To annually review the flat rate fee and the photocopy
cost charged in the Special Rate in consultation with
the City Attorney and make necessary changes.
B. To notify all department and office directors of
any changes in the Flat Rate fee and the photocopy
cost charged in the Special Rate.
C. To answer any auestions and assist departments in
. determining Special Rate and Commercial rates to be
charged.
. l_ _ , . . . �-, . ..
� �� � , � - � � � . . . � . � _: . ����:��-
, . .. . . . . . _ , . . .
. . . , � . . . . .
. � . � � � .- . � � .� � .
. -. _ � . . ,. . . .. . . . . . . . . . . . . . ..
. . . .. . . - . . .. . . . :. .
November 3� Z987 . . _ . � . . • . -: • _ . . _ � _
. . . , � . : . . , � �: �
• M E M 0 R A N D U M '. • . ' :' ' : _ - : " � � . � � . � .. , ' . � . • � _ . ..._u
.Y:I
' � :1 . � .
' � . ' •�• � % ' . � .�
' ' ' . . �:�• � ' ' �
. �TO Gregory Blees : . _� -� " ._ .. . � - . - _ . .,�• . .,_ .�:.
� �� • Budget Director�� ' ':'� -. .���-. - . . . . : ._
. � • . � � • . • • - � . .
FROM: Jane A. McPeak . • _ . - -
Deputy City Attorri y . . •� . � � � - � '
RE :' Data Retrieval Fee •
?ursuant to Section •II o he City's Data Retrieval Fees Policy .
effective, by Execut:.ve O der, ori hovember 15 , 1986, �he �City .
Attorney' s Office is ch r ed with �ually revie�.�=ng the flat
ra�e fee znd tne pho�:oc y cost charged in the special rzte .and ..
reco;���ending r.ecessary ch n es to the Budget Dire�tor.
' Based or. 1987 tdinneso�a a s, Chapter 351 , Section -7. , which add'ed �
• - certain clarifying la.ngu g to Mirinesota Statutes Section 13.03
� dealing w.ith access ta go e nment data� I _suggest that the follow-
� � � :�ing paragraph be addeo. t S ction C�• 1 and 2 � of the �City' s policy,: _
. ' . • • r . .
' � For C�, 1 : Persons who equest •~ access for the pur•pose of�: ' �
• �inspectior. m y not be . assessed 'a charge or required _�.. .
. � to pay a f'ee 'to inspect the data. . • . � , �. , .. . .��,
. For C� 2: Persons who � equest access • for �the � purpose of '. �
� . _ inspectior� m y 'not be: assessed a charge ar. required:,;.r'.
. • •� - . � ' • to pay a fe o inspect . that � data�. � Persons, . otHer. : ,
• than thc su e t� of the -re ested � data� who ask �for �. .
� copie� may ,b harged for the actual costs of search- :: :.�.
� � � ing for• aaid re rieving gavernment data and for making ;- ':_
and compili q � the copies of the data but-� not for :
. . separatiny u Iic from � �not public data. :��� Persons''� .
• who are th ub ect of the requested ' data �may not -�
be charged� o. the costs incurred in searching for `,
� and retriev ng the data or in separating pub2ic f:om
not public d t . , �
cc:. t•Sayor Latimer • •
Me:nbers of the City C uncil .
Department b Office D rectors •
_ . _ _ ._ _�. ,.,
\
. � � , � � �,��.�"���
.,
_OLICY STATEMENT: DATA RE R EVAL FEES
PAGE 2
- ./
IV. RESPONSIBILITIES OF E ARTMENT AND OFFICE DIRECTORS
The City Department D'rectors have the following
responsibilities:
A. To establish p o edures pursuant to these guidelines
for r�ceiving n depositing payments for data.
B. To establish p o edures to ensure that requests for
government dat re received and complied with in an
appropriate ma n r in accordance with the Minnesota
Government Dat ractices• Act.
C. To maintain re o ds of each transaction for which a
fee is charged
D. To establish a' S andard Fee Schedule (as described
below) for tho e services which are routinely provided
to the public. end one copy of the Schedule to the
Budget Directo nd one copy to the City Attorney.
E. To, at least n ally, review Special Rate fees,
Standard Fee S h dules and Commercial Rates
established u e these guidelines and �modify as
necessary to f ect changing costs.
F. � To identify d a which may have significant commercial
value and pre ar development cost documentation.
G. To provide de ar ments all necessary forms relating to
information d'sc osure and related fees (Finance
Department)
V. GU�DELINES AND PRO ED ES
A. When access i a thorized, data may be provided at no
charcre when:
1. another ov rnment agency or responsible
authorit r quires or requests data and the data
is usual y rovided as part of the normal course
of busin ss•
2. records, do uments, brochures, pamphlets, books,
reports, pu lications, or other data are produced
or provi ed for free distribution to the public.
B. When access i a thorized, data shall be provided "at
the applicabl r te for all other requests to include:
l. the medi , 'ncluding representatives of
newspape , adio and television;
�
• .
POLICY STATEMEN� DATA RETRIEVAL FEES •
PAGE 3 '.
2. other authorized government agencies or
responsibi'le authorities (defined in the Act) who
require or request records, documents,
publications, or other data which are not usually
provided or reproduced as part of the normal
course of business; 1"
3. records, documents, brochures, pamphlets, books,
. reports, publications, or other data that are not
normall.y provided or reproduced for distribution
to the public;
4. • public and private data on individuals and public
and non-public data not on individuals.
C. FEE .
Fees for data shall be charged at the Flat Rate,
Special Rate, or Coxnmercial Rate.
l. Flat Rate
The Flat Rate is calculated on a per-page basis.
The Flat Rate shall be charged when the cost of
providing requested records, documents,
publications, or data is minimal. The current .
� Flat Rate is 25 cents per page.
The "Information Disclosure Request" form
. (Attachment A) provides space for calculation and
entry of the Flat Rate.
2. Special Rate
The Special Rate shall be charged when the cost
of providing data exceeds the Flat Rate. The
� Special Rate includes actual costs of providing
data, including costs incurred in searching for,
retrieving, compiling, certifying and making
copies of requested data.
Persons who are the subject of the Qovernment
. � data mav not be charcted for the costs incurred in
searchin4 for and retrievincr data. The cost of -
separating public from not public data cannot be
charged to the requestor.
A breakdown of some of the various costs which
may be charged is given in Attachment B.
� �.. �� ��,--��z
• �
POLICY STATEMENT: DATA RET IE AL FEES
PAGE 4
`,
The Specia R te is determined by completing
. Sections C of "Information Disclosure Request
Form'� . Th S ecial Rate may include:
a. cost f aterials, including paper, used to "
provi e he data;
b. cost f abor required to prepare the data;
c. any s ec al costs necessary to produce such
data ro machine-based record keeping
syste s, including but not limited to,
compu er and microfilm systems;
d. maili g osts.
D. Commercial Ra e
Minnesota ta utes provide that the city may
charge a r as nable fee in addition to the
Special Ra e or public government data which has
commercial va ue and is an entire formula,
pattern, d ta base or system developed with a
significan e enditure of public funds. �
The Commer ia Rate is the Special Rate (i.e. ,
the actual co t of providing data) with an
additional ch rge which reflects all or part of
the develo me t costs that relate directly to the
data. •
l. The C mm rcial Rate may be charged to any
indiv ''du 1, partnership, corporation,
assoc at'on, business trust, government
. agenc , olitical subdivision or a legal
repre en ative of an organization when the
reque te information has commercial value.
2. No in iv'dual shall be charged the
Comme ci 1 Rate for government data on
thems lv s. .
3. In or er to charge the Commercial Rate, a
depar me t must clearly demonstrate that the
addit on 1 charge relates to the actual
devel pm nt costs of the information.
Devel pm nt costs include, but are not
limit d o:
- a. ab r costs;
b. os s incurred in design, development,
. es ing, implementation and training;
��
• • ' ..
POLICY STATEMENT: DATA RETRIEVAL FEES
PAGE 5
c. costs necessary to ensure that the data '
is accurate, complete and current, to
include adding to, updating, changing
and deleting information.
4. The total additional charges applied at the �`
Commercial Rate may not exceed the total ,
development costs far the system. However,
the development costs necessary to ensure
that the data is accurate, complete and
current may be added to the original
development costs of an ongoing basis for
the life of the system.
5. Departments should identify data for which
they are responsible and which may have
significant commercial value.
6. Departments responsible for the information
shall prepara and maintain sufficient
documentation to explain and justify any
Commercial Rate beir.g charged. Such
documentation is to include:
a. cost of initial development; .
• b. ongoing information development costs; �
c. a record of Commercial Rate revenues -
received which have been applied
against development cost.
7. When necessary, the Budget Director shall
assist departments in determining
development and ongoing costs of
computer/data base-related requests.
8. Upon the request of any person, a department
. shall provide the documentation which
justifies the Special and Commercial rate
being charged.
E. COLLECTION OF FEES
GenerZlly, fees will be collected before releasing the
data. Except under special circumstances, fees may
not be "charged" and billed to the requestor.
1. Fees should be handled by following the City's
Cash Receipts Procedures in the Accounting
Procedures Manual.
: � �-���G��
' POL7CY STATEMENT: DATA R R EVAL FEES •
PAGE 6
� F. STANDARD FEE S H DULE
For those data s ices which are routinely provided,
departments sh ul use the "Informatian Disclosure
Request Form" o stablish a Standard Fee Schedule for
each type of r co d, document, or data which is -"�
routinely prov' e . The Schedule will preclude the
need for compl i g the calculation form for each .
request for dat hich is provided routinely. The
� Standard Fee Sc e ule and the calculation form must be
made readily av i able to anyone who requests them. A
copy of the Sch d le should be sent to Budget Director
and the City At o ey.
� G. INFORMATION DIS LO URE RE UEST FORM
The "Informatio D sclosure Request Form" (Attachment
A) has been des ' n d to accommodate and facilitate the
charging and col e tion of fees.
. The name of the e estor or any other identifying
� • information aske or on the "Information Discic�sure
Request" form sh 1 not be required for requests for
public data.
If a requestor o je ts to filling out the "Info_�mation
Disclosure Reque t" there is an explanatory flyer
. titled "INFORMAT ON DISCLOSURE - your riqht - our
responsibility" hi h is printed on the backside of
� the "Information Di closure Re'quest Form. "
. • • �:
ATTACHMENT B ,
Costs of Cop,ving� Services Provided
Flat Rate $.25 per page
Special Rate
a. Photocopy Rate $ .06 per page
b. Labor Hourly wage +26%s
c. Postage Prevailing rate
d. Microfilm Services _
1. from film to hard copy $ .50 per page
. 2. copy of fiche card $ .50 per page
' 3 . diazo duplicate
(-roll film) $8.00 each
e. Computer Services For data requests involving
a Data Processing
. Operation, a written
� request must be forwarded
. to 'the Director of Citywide
'Information Services '
� . ' specifying the project. �
•� • f. Tapes '
. 1. � Audio
a. reel-to-reel Cost
. b. cassette Cost
. � 2. Dubbing Fee $5.00/half-hour � ' �
.
� O�TEOfAEOVEST 'NFORMaTiON IS LOSURE REQUFST & COPY COST CALCULATION FORM
` Mi�ota`�Gover m t Oata Practices Act - G
V •-'�/�
: QcGVES`.EF N�.ME�las�.Fusi.►n.) pE0UE5TER NOTE:
' " A.Request freQuency—Priva�e Oata on individuals.Atier you have been
3 �DOAESS l���«c.al s�own lhe data and into�med ot its meaning,t�e date�eed npt be
dixlosed to you s1x months thereatter unkss a dispute o�attion is
pendinfl or additional tlata on you has been tollectet7.
v►+OwE/��n..a.e) 8.You may be required to pay the actusl costs of maki�g,�ertifying a�d/or
compili�g the copies of intormation repuested.
a DESCR�PTiON OF TME INfOFiMATION REOUESTED
5.REOUESTER S�GNATUpE
x
B. DEPARTMENT/DIVISION COMPLETE •
6.DEPAHTMENT/ptV1510N NAME 7.REQUEST MANDLED BY
– D.pEdUEST TYPE 9.REQUESTED 8Y
❑�n-pe+son ❑�Aa�l ' ❑Plwne ❑SuDj.ot Il�a Oata ❑Not tf�e suOj.01 lf+e Oata
�0 TrE iNCOAM�T�JN NEOUES7E01S C1A551F1E0: tt.REOUEST
❑PUEUC � ❑NON-PUBUC , ❑AP0��0 ❑OemeE ❑AOMOveO in paR(aaplaie in 13)
❑Pa�v�TE ❑PNOTEC7ED NON-PUBLtC 12.AUTt+ORIZEO SIGNATURE
O CONFIDENTIAL X
I1J FEMARKS'CCMMQNTS(lll�p�eslet daq�S Uliid�lC 30 IS 10 O�ny ICCISS 10 H7 ip atN uf��utnori�y or n�son.Also�nt��any o���r rsm�rks/tomm�nts apy�opn�t�1.
C. DEPARTMENT/DIVISI��N COMPLETE WHEN FE S RE ASSESSED
lComp�ere Pnorocopy Irne on�y for fIAT AA TE) ESTIMATED COST ACTUAL
(Onry Necessary lor Aepaid) COST
t.labor: X ........................
�NO OF MRS.) (►i0U lY R TE)
X .............. ... , .
. (NO.OF HRS.) (MOU LY R E) �
2.PnotoCOPY: X .......................
• ;�OTpCOPY qA1E)• (NO. PA 5)
3.Ma�ling: .......................
� a.PuDl�cation Pri�ting Cost: ........................
5.Other costs,dese�ibe:(TO i�clude compu:er time,programminy ti ,tsr ina!aecess,vidso tapes, .
m�crol�lming systems and ani other tosts not lislsd abore.J �
a. '
- • b.
C. �
d.
O LCHARGES 5
AM UN TO BE PREPAID �
:ee Adm�n.N.anual tor turrent-ate. (50%ol ST. TOTAL if S50 or over)
QECEi�T• A OUNT DUE
�
(Upo co pletion of copying)
YtiEP�Qf��•FME EPT. iv 0�7E
L
��soo+t�o-ee�