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legal expectation of privacy when traveling <br />on public roads, citizens have genuine <br />concerns that the data can be used to harass <br />or embarrass them. <br />(Much LPR data is temporarily classified as <br />private data pursuant to a temporary <br />classification issued by the Information <br />Policy Analysis Division of the Department <br />of Administration. Absent legislative <br />action, the temporary classification expires <br />on August 1, 2015.) <br />The retention of data for an extended period <br />of time increases the potential for misuse of <br />the data and for "retroactive surveillance." <br />The League of Minnesota Cities recognizes <br />that the appropriate use of LPRs must strike <br />the proper balance between the need for <br />robust law enforcement and individual <br />privacy rights. <br />Response: The use of LPRs by law <br />enforcement agencies should be allowed <br />to continue with proper safeguards. LPR <br />data should be classified as nonpublic <br />data or private data on individuals under <br />the MGDPA to prevent abuse and to <br />protect individual privacy rights. The <br />state should adopt a uniform retention <br />period for all LPR data collected by state <br />and local law enforcement agencies that: <br />a) Do not identify a stolen vehicle or <br />license plates; <br />b) Do not identify a vehicle belonging to <br />a person subject to a warrant for <br />arrest; <br />c) Do not identify a vehicle belonging to <br />an owner that has a suspended or <br />revoked driver's license; or <br />d) Are not related to an active <br />investigation. <br />The retention period should be long <br />enough to provide law enforcement <br />agencies adequate time to determine <br />whether the data is related to an active <br />investigation or to crimes reported to <br />police shortly after the data is collected. <br />Federal Employment Law <br />FED-1. Consolidated Omnibus <br />Budget Reconciliation Act <br />(COBRA) <br />Issue: The federal Consolidated Omnibus <br />Budget Reconciliation Act (COBRA) law, <br />which requires employers to offer continued <br />health and dental insurance group benefits <br />after an employee terminates, has been <br />interpreted to apply to Employee Assistance <br />Programs (EAPs), health funding <br />mechanisms such as Health Reimbursement <br />Arrangements (HRA)/Voluntary Employee <br />Benefit Accounts (VEBAs), and flexible <br />benefits. The application of COBRA <br />benefits to these programs results in unlikely <br />and impractical outcomes. <br />Response: Congress should clarify the <br />intended benefits to which COBRA law <br />should apply, excluding programs such as <br />EAPs, HRA/VEBAs, and flexible benefits. <br />FED-2. Medicare/Medicaid <br />Premium Disbursements <br />Issue: Minnesota continues to be a net loser <br />in federal Medicare and Medicaid premium <br />disbursements. <br />Response: Congress must recognize this <br />disparity and provide Minnesota with a <br />more balanced and representative share <br />of the costs of providing health care <br />under Medicaid and Medicare. <br />League of Minnesota Cities <br />2015 City Policies Page 91 <br />