MN Data Practices Advisory Opinions Archive

November 13, 2025 · November 13, 2025; Itasca Medical Care

A county-based purchasing plan asked whether it was subject to the requirements of a Minnesota Statutes, section 13.46 after receiving a request from a media member for data it maintained. The purchasing plan denied the…

Contracts/privatization Welfare data #Privatization #Response to data request #Welfare system

Advisory Opinion 15-003 15-003

May 21, 2015 · May 21, 2015; Foth, Inc. (Bloomington)

A member of the public asked about a government contractor’s obligation to respond to a request for data the contractor maintained in connection with its work for a City. The contractor did not respond to the request. T…

Contracts/privatization Response to data requests #No response #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).)

Advisory Opinion 14-018 14-018

November 17, 2014 · November 17, 2014; Department of Public Safety

A requester asked for access to copies of contracts and non-disclosure agreements for cell phone exploitation equipment. The entity said it could not redact the documents because they contained inextricably intertwined …

Contracts/privatization Law enforcement data Trade secret #13.03 subdivision 11 #Classification generally #Contracts #Deliberative processes (13.82, subd. 25 / subd. 16) #Privatization

Advisory Opinion 14-011 14-011

September 17, 2014 · September 17, 2014; Office of the Legislative Auditor

A requester asked for all data submitted in response to RFPs for third party auditors to conduct, or help conduct certain audits, and all resulting contracts. The request was denied based on the entity’s conclusion that…

Contracts/privatization #Contracts are public #Office of the Legislative Auditor #RFP (request for proposals/request for bids

Advisory Opinion 11-016 11-016

November 7, 2011 · November 7, 2011; City of Sauk Rapids

Did the City of Sauk Rapids comply with Minnesota Statutes, Chapter 13, when it denied access to data provided to the City and/or the City’s contractor by a private company that the City then used to determine whether t…

Contracts/privatization #Business data (13.591) #Official records

Advisory Opinion 11-005 11-005

May 26, 2011 · May 26, 2011; Johnson Controls, Inc. (ISD 2142-St. Louis County)

Did Johnson Controls, Inc. (JCI) comply with Minnesota Statutes, Chapter 13, when it charged $3,900 for copies of government data related to a contract JCI has entered into with Independent School District 2142, St. Lou…

Contracts/privatization Contracts/privatization #Contracts #Copy costs

Advisory Opinion 11-001 11-001

January 3, 2011 · January 3, 2011; Johnson Controls, Inc. (ISD 2142-St. Louis County)

Did Johnson Controls, Inc. comply with Minnesota Statutes, Chapter 13, when it denied access to data related to a contract JCI has entered into with Independent School District 2142, St. Louis County?

Contracts/privatization #Official records

Advisory Opinion 10-024 10-024

November 16, 2010 · November 16, 2010; City of Wayzata

Did the City of Wayzata comply with Minnesota Statutes, Chapter 13, when it charged $265 to copy approximately 61 pages from the approximately 473 pages that the requestor inspected?

Contracts/privatization Copy costs #Copy costs #Copy costs #Copy inspection hybrid #Electronically maintained data (See also: Electronic data)

Advisory Opinion 10-018 10-018

September 14, 2010 · September 14, 2010; City of Fergus Falls

Did the City of Fergus Falls comply with Minnesota Statutes, Chapter 13 and Minnesota Statutes, section 15.17, in responding to a data request for data on individuals and corporations that have made contributions or ple…

Contracts/privatization #Obligation to maintain and preserve records #Official records #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Privatization

Advisory Opinion 10-008 10-008

April 8, 2010 · April 8, 2010; Minnesota Department of Commerce

Pursuant to Minnesota Statutes, Chapter 13, what is the classification of the following data that the Minnesota Department of Commerce maintains: the names of propane companies and their weekly residential propane price…

Contracts/privatization #Federal contracts data (13.35)

Advisory Opinion 09-022 09-022

September 22, 2009 · September 22, 2009; City of Saint Paul

Did the City of Saint Paul comply with Chapter 13 in response to a March 27, 2009 (and subsequent), request for access to “all policies and procedures governing the duties of the St. Paul Intervention Project, Inc., to …

Contracts/privatization #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Private party response to data requests

Advisory Opinion 09-014 09-014

June 30, 2009 · June 30, 2009; Minnesota Municipal Utilities Association

Is the Minnesota Municipal Utilities Association subject to Minnesota Statutes, Chapter 13? If the answer to Issue 1 is yes, did MMUA comply with Minnesota Statutes, Chapter 13, in its response to a March 16, 2009, requ…

Contracts/privatization #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Private party response to data requests

Advisory Opinion 09-003 09-003

January 27, 2009 · January 27, 2009; Knutson, Flynn and Deans

Does Minnesota Statutes, Chapter 13, require Knutson, Flynn & Deans to provide to KSTP-TV any list Knutson, Flynn & Deans created setting forth the public schools or school districts it has represented from 2003 to 2008…

Contracts/privatization #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Private party response to data requests

Advisory Opinion 08-024 08-024

August 26, 2008 · August 26, 2008; City of Buffalo

Pursuant to Minnesota Statutes, Chapter 13, what is the classification of the data when they are not collected, created, received, maintained, or disseminated by the City of Buffalo, but are collected and maintained by …

Contracts/privatization Electronic data #Computer data (13.15) #Email/internet #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Privatization #Subscriber information (e.g., email address, name)

Advisory Opinion 08-023 08-023

August 26, 2008 · August 26, 2008; School District 192 (Farmington)

Did Independent School District 192, Farmington, comply with Minnesota Statutes, Chapter 13, in its response to a request for a copy of its Superintendent’s employment contract?

Contracts/privatization Personnel data #Employment #Employment contract

Advisory Opinion 07-019 07-019

September 27, 2007 · September 27, 2007; Teachers Retirement Association

Pursuant to Minnesota Statutes, Chapter 13, can the Teachers Retirement Association (TRA) provide names and mailing addresses of members and/or retirees to a private vendor with which TRA has contracted to mail retireme…

Contracts/privatization #Teachers Retirement Association (TRA)

Advisory Opinion 06-025 06-025

August 17, 2006 · August 17, 2006; City of Rice

Is the City of Rice in compliance with Minnesota Statutes, Chapter 13, if it releases certain data relating to vehicle accidents to Watab Township?

Contracts/privatization Data sharing #13.03 subdivision 11 #Contracts #Privatization

Advisory Opinion 05-039 05-039

November 30, 2005 · November 30, 2005; City of Saint Paul

Did the City of Saint Paul comply with Minnesota Statutes, Chapter 13, regarding an August 11, 2005, request from the data subject for the following data: the complete record of the scoring for the B-PAD portion of the …

Contracts/privatization Personnel data #Obligation to maintain and preserve records #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Test scores

Advisory Opinion 05-034 05-034

November 9, 2005 · November 9, 2005; Lake Superior Center

Did the Lake Superior Center comply with Minnesota Statutes, Chapter 13, in regard to an August 16, 2005, request for government data?

Contracts/privatization #Clause to be inferred #Lake Superior Center #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).)

Advisory Opinion 05-033 05-033

October 27, 2005 · October 27, 2005; Minnesota Partnership for Action Against Tobacco

When the Minnesota Partnership for Action Against Tobacco (MPAAT) commissions another person or entity to perform a research study, and MPAAT thereafter receives and makes a public report from that person or entity whic…

Contracts/privatization #Court - discretion to subject non-government entity to Chapter 13 #Research/raw data

Advisory Opinion 04-077 04-077

November 29, 2004 · November 29, 2004; City of Saint Paul

Did the City of Saint Paul comply with Minnesota Statutes, Chapter 13, in responding to a request to gain access to the addresses of those businesses and individuals who are the ultimate recipients of either loans or gr…

Contracts/privatization Legislative authority and intent #Business data (13.591) #Loan or grant #RFP (request for proposals/request for bids

Advisory Opinion 04-009 04-009

March 2, 2004 · March 2, 2004; Gary Fischler and Associates

Pursuant to Minnesota Statutes, Chapter 13, did Gary Fischler and Associates violate a data subject's rights by not providing a Tennessen warning notice prior to collecting data as part of a psychological evaluation? Pu…

Contracts/privatization Data subjects Educational data Legislative authority and intent Tennessen warning #Clause to be inferred #Informed consent vs. Tennessen #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).) #Relationship of informed consent to Tennessen warning #Vocational rehabilitation data

Advisory Opinion 03-033 03-033

September 2, 2003 · September 2, 2003; School District 625 (St. Paul)

Pursuant to Minnesota Statutes, Chapter 13, what is the classification of the following data that Independent School District 625, Saint Paul, maintains: the names of school bus drivers provided by the bus companies?

Contracts/privatization #Clause to be inferred #Driver’s Privacy Protection Act (DPPA) #National Labor Relations Act (NLRA) #Private party contracts with government (13.05, subd. 11; see also: Helmberger v. Johnson Controls, Inc., 839 N.W.2d 527 (Minn. 2013).)

Advisory Opinion 03-027 03-027

August 7, 2003 · August 7, 2003; City of Grant

Pursuant to Minnesota Statutes, Chapter 13, did the City of Grant respond appropriately to a May 16, 2003, request for access to government data?

Contracts/privatization Records management/retention Records management/retention #Contracts are public #Official Records Act (15.17) See also: Records management #Records retention schedule

Advisory Opinion 02-054 02-054

December 30, 2002 · December 30, 2002; Central Minnesota Jobs and Training Services, Inc.

Is Central Minnesota Jobs and Training Services subject to the requirements of Minnesota Statutes, Chapter 13?

Contracts/privatization #Employment and training data (13.47) #Joint powers agreements/entities (471.59)

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