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About Search Results
The advisory opinion library currently includes:
- Data practices advisory opinions issued by the Commissioner of Administration from 1993 to the present.
- Open Meeting Law advisory opinions issued by the Commissioner of Administration from 2003 to the present.
The Commissioner's authority is found in Minnesota Statutes, section 13.072. Opinions are nonbinding, but a court may give them deference in a court action. Parties to a court action that act in conformity with an advisory opinion are not liable for certain damages or attorneys fees.
A written, numbered, and published opinion issued by the attorney general shall take precedence over an advisory opinion issued by the Commissioner of Administration.
Results 1 - 10 of 82
Advisory Opinion 25-006
June 30, 2025; Independent School District No. 623, Roseville
This is an opinion of the Commissioner of Administration issued under Minnesota Statutes, section 13.072 (2024). It is based on the facts and information available ...
Description: A member of the public asked whether a school district responded appropriately to a request for public data. The requester asked for data 11 months prior, and had only received portions of the data after inquiries from the Department of Administration and the requester. Additionally, the District indicated it was providing only a subset of the data due to technical difficulties with retrieving all the data requested. The Commissioner determined that the District did not respond appropriately to the request.
Category: Response to data requests, Requests for data
Keywords: Response to data requests, Requests for data, Appropriate response generally, Inappropriate response, generally, Burdensome or harassing
Commissioner: Tamar Gronvall
Advisory Opinion 24-004
October 3, 2024; City of Kasota
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2023). It is based on the facts and information ...
Description: A member of the public asked whether a city responded appropriately to a request for public data that he made while using a pseudonym. The City had informed the requester that it would not provide access to data until he identified himself. The Commissioner opined that the city did not respond appropriately because Minnesota Statutes, section 13.05, subdivision 12 prohibits government entities from requiring data requesters to identify themselves as a condition to obtain access to public data.
Category: Requests for data, Response to data requests
Keywords: Requests for data, Response to data requests, Reason/justify request and identity not required (13.05, subd. 12)
Commissioner: Tamar Gronvall
Advisory Opinion 23-004
October 3, 2023; City of Fertile
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2022). It is based on the facts and information ...
Description: A data subject asked whether a city council violated the Open Meeting Law when it held multiple closed sessions under Minnesota Statutes, section 13D.05 subd. 2(b), to discuss allegations against an individual subject to its authority. The data subject also asked whether a city responded appropriately to a request for data made under Minnesota Statutes, section 13.04. The Commissioner opined that the Council did not comply with the Open Meeting Law when it held closed meetings under section 13D.05 subd. 2(b), as it had previously determined that discipline may be warranted and discussed matters outside the scope of closure permitted by the section. Additionally, the Commissioner concluded that the City did not respond appropriately to a request from the data subject because it did not provide access to the data within ten business days, as required by section 13.04.
Category: Open Meeting Law, Closed meetings, Requests for data, Data subjects
Keywords: Open Meeting Law, Closed meetings, Requests for data, Data subjects, Timeliness of response to data subject - immediately or ten business days, Recording meetings
Commissioner: Stacie Christensen Temporary
Advisory Opinion 20-003
March 3, 2020; ISD 181, Brainerd Public Schools
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2019). It is based on the facts and information ...
Description: A member of the public made a data request to a school district. He requested an email attachment that contained a district employee’s “contact list.” The school district denied access to the contact list, asserting contact lists are private personnel data. The Commissioner opined that the contact list may contain public data and/or not public data depending on the contacts listed. The fact that an individual maintains a list of contacts does not, by itself, make the contacts about that individual.
Category: Requests for data, Response to data requests, Personnel data
Keywords: Requests for data, Response to data requests, Personnel data, Timeliness of response to public - prompt, reasonable time (13.03, subd. 2), (1205.0300), Timely, generally, Email, Electronic data, email, Email/internet
Commissioner: Alice Roberts-Davis
Advisory Opinion 19-013
November 27, 2019; Rice County
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2018). It is based on the facts and information ...
Description: a data requester asked if a County had responded appropriately to two requests she made for public data. The Commissioner opined that the County responded appropriately to a request for public comments when it emailed the requester a link to the comments, which the requester had previously said would be acceptable. The County did not respond appropriately to a draft spreadsheet when it did not respond to the request promptly and appropriately, did not provide the data in the format in which it was maintained, and failed to assess a reasonable, actual copy cost; the county quoted five different costs and used two different pay scales to calculate costs.
Category: Response to data requests, Requests for data, Copy costs
Keywords: Response to data requests, Requests for data, Copy costs, Copy costs, Timeliness of response to public - prompt, reasonable time (13.03, subd. 2), (1205.0300), To responsible authority or designated person, required, Actual cost - public, Costs, Data access policy, Data does not exist, Data do not exist, Data request policy, Data requests, Designee, Government data
Commissioner: Alice Roberts-Davis
Advisory Opinion 19-010
June 18, 2019; Minnesota Department of Health
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2018). It is based on the facts and information ...
Description: In Advisory Opinion 19-010, a member of the public asked whether a state agency had violated the Data Practices Act because it had not provided her with access to the data he requested (public personnel data on two employees) until eight months after she asked for the data. In previous advisory opinions, the Commissioner has stated that a prompt, reasonable response is relative to the volume of data requested. Here, she opined that given the facts of this specific data request, including the type and amount of data requested, the agency’s response was not timely.
Category: Requests for data, Response to data requests
Keywords: Requests for data, Response to data requests, Untimely, generally, Multiple data subjects, Timeliness of response to public - prompt, reasonable time (13.03, subd. 2), (1205.0300), Responsible authority duties, Responsible authority (RA), Responsible authority, Response to data request, Requestor responsibility, Request for data, Inappropriate response, generally, Government data, Department of Health data, Data request vs. question/inquiry, Data request policy, Request for data
Commissioner: Alice Roberts-Davis
Advisory Opinion 18-010
July 30, 2018; ISD 709, Duluth Public Schools
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2017). It is based on the facts and information ...
Description: A data requester asked whether a school district had responded appropriately to several data requests he made, including one for data about himself. The Commissioner opined that the district did not respond appropriately to the requests for public data in these specific circumstances when it did not communicate with the requester in nearly five months, despite the fact that the district knew that some data the requester sought no longer existed. The Commissioner further opined that the district did not respond appropriately to the requester’s request for data about himself because it did not provide him with any data within ten business days, as required by Minn. Stat § 13.04.
Category: Response to data requests, Requests for data
Keywords: Response to data requests, Requests for data, Timeliness of response to data subject - immediately or ten business days, Timeliness of response to public - prompt, reasonable time (13.03, subd. 2), (1205.0300), Timely response required, access immediately or within ten business days, Timely, generally
Commissioner: Matthew Massman
Advisory Opinion 18-006
May 23, 2018; University of Minnesota
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2017). It is based on the facts and information ...
Description: A member of the public asked whether a University had violated the Data Practices Act because it had not provided him with access to the data he requested (public personnel data on three employees) as of the date of his opinion request, which was two months after he asked for the data. In previous advisory opinions, the Commissioner has stated that a prompt, reasonable response is relative to the volume of data requested. Here, he opined that given the facts of this specific data request, including the type and amount of data requested, the University’s response was not timely.
Category: Requests for data, Response to data requests
Keywords: Requests for data, Response to data requests, Timeliness of response to public - prompt, reasonable time (13.03, subd. 2), (1205.0300), Response to data request
Commissioner: Matthew Massman
Advisory Opinion 18-005
May 21, 2018; Carver County
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2017). It is based on the facts and information ...
Description: A data subject asked if a county responded appropriately to a data request when it failed to comply within ten business days. The Commissioner concluded that Minn. Stat. § 13.04, subdivision 3, is clear: entities must comply with data subject requests within ten business days. The request resulted in almost 3,000 emails and, as of the date of the opinion, the County had failed to provide any emails to the data subject. The Commissioner acknowledged the challenge in producing all of the data within the strict time limit, but also noted that the statute does not allow for additional time in mitigating circumstances.
Category: Data subjects, Response to data requests, Requests for data
Keywords: Data subjects, Response to data requests, Requests for data, Access by data subject or parent, Timeliness of response to data subject - immediately or ten business days, Response to data request, Data subjects (13.04), Data subject rights of access procedures (13.05, subd. 8)/(13.025, subd. 3), Data subject access
Commissioner: Matthew Massman
Advisory Opinion 14-006
June 5, 2014; Independent School District 625 (St. Paul)
This is an opinion of the Commissioner of Administration issued pursuant to Minnesota Statutes, section 13.072 (2013). It is based on the facts and information ...
Description: Pursuant to Minnesota Statutes, Chapter 13, did Independent School District 625, St. Paul, respond appropriately to a March 15, 2014, request for data?
Pursuant to Minnesota Statutes, Chapter 13, did Independent School District 625, St. Paul, respond appropriately to a March 25, 2014, request for data pursuant to Minnesota Statutes, section 13.04, subdivision 3?
Category: Data subjects, Personnel data, Requests for data, Response to data requests
Keywords: Data subjects, Personnel data, Requests for data, Response to data requests, Timely response required, access immediately or within ten business days, Complaint or charge, Clarification of request
Commissioner: Spencer Cronk
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