Pat 1

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Trine University *

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Information Systems

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Nov 24, 2024

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Pat 1 Data Management Policy Introduction The goal of the data management policy is to ensure that AI-DNA is adhering to all applicable laws, regulations and industry best practices related to the handling of genetic data. This policy provides guidance to AI-DNA personnel and third-parties to follow when handling data related to genomic DNA profiling in order to protect the privacy and security of the individuals whose data are being analyzed. Applicability This data management policy applies to any and all data related to AI-DNA’s predictive genomic DNA profiling process, and applies to all AI-DNA personnel and third parties that handle the data. Responsibilities The responsibilities for the management of data related to predictive genomic DNA profiling are separated between AI-DNA personnel and third-party partners, as outlined below: AI-DNA Personnel AI-DNA personnel are responsible for ensuring that all applicable regulations, best practices and laws outlined in this policy are followed. AI-DNA personnel must also ensure that data quality is maintained and that reasonable steps are taken to protect data collected during predictive genomic DNA profiling. Third-Party Partners Third-party partners are responsible for ensuring the data related to predictive genomic DNA profiling is securely stored and for maintaining the accuracy and integrity of the data. They should also ensure that reasonable steps are taken to protect the data and to ensure that its use is in accordance with industry best practices and relevant laws and regulations. Regulations, Guidelines and Best Practices

AI-DNA personnel and third-party partners should adhere to the following regulations, guidelines and best practices related to the handling of data related to predictive genomic DNA profiling: Health Insurance Portability and Accountability Act (HIPAA) The Health Insurance Portability and Accountability Act (HIPAA) is a federal law that establishes several standards to ensure the protection of the privacy and security of individually identifiable health information. The HIPAA Privacy Rule protects all kinds of genetic data, including data related to predictive genomic DNA profiling, and requires covered entities to take reasonable steps to secure the confidentiality of the data. Family Educational Rights and Privacy Act (FERPA) The Family Educational Rights and Privacy Act (FERPA) protects the privacy of student educational records and provides guidelines for data collection, storage and sharing. This law applies to data collected from students during predictive genomic DNA profiling, and requires that the data be securely stored and that reasonable steps be taken to protect its confidentiality. Genetic Information Nondiscrimination Act (GINA) The Genetic Information Nondiscrimination Act (GINA) is a federal law that prohibits discrimination in health care and employment based on genetic information. GINA applies to data collected during predictive genomic DNA profiling, and requires that all data related to genetic testing be kept confidential and not shared with third parties without the permission of the individual. California Consumer Privacy Act (CCPA) The California Consumer Privacy Act (CCPA) is a state law that provides California residents with the right to access, delete or opt out of the sale of their personal information. This law applies to data collected during predictive genomic DNA profiling, and requires companies to be transparent about the data they collect and how it is used. EU General Data Protection Regulation (GDPR) The EU General Data Protection Regulation (GDPR) is a law that governs the collection, storage and use of personal data in the European Union. This law applies to predictive genomic DNA profiling, and

requires that data subject's consent be obtained before data can be collected and that reasonable steps be taken to ensure the security of the data. Implementation AI-DNA will implement the regulations, guidelines and best practices related to the handling of data related to predictive genomic DNA profiling in the following ways: Data Collection AI-DNA will obtain written consent from individuals before collecting any data related to their predictive genomic DNA profiling. AI-DNA will also maintain records of all consent forms and will take reasonable steps to ensure that the data is collected in a secure and confidential manner. Data Storage AI-DNA will securely store all data related to individuals' predictive genomic DNA profiling and will take reasonable steps to ensure that the data is safely stored and not subject to any unauthorized use, access or disclosure. Data Usage AI-DNA will use all data related to predictive genomic DNA profiling for the purposes outlined in the consent form and will not share the data with any third parties without the permission of the individual. AI-DNA personnel and third-party partners will also take reasonable steps to ensure that the data is used in accordance with all applicable laws and regulations. Data Rights AI-DNA will provide individuals with the right to access, delete or opt-out of the sale of their predictive genomic DNA profiling data upon request. AI-DNA personnel and third-party partners will take reasonable steps to ensure that the requests are fulfilled in a timely fashion. Logging and Monitoring

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AI-DNA will maintain a complete audit trail and log of all activities related to its predictive genomic DNA profiling process. AI-DNA personnel and third-party partners will take reasonable steps to review and monitor all log entries to ensure that all data is compliant with this policy. Conclusion This data management policy outlines the regulations, guidelines and best practice that AI-DNA and its personnel and third-party partners must adhere to when handling data related to predictive genomic DNA profiling. AI-DNA is committed to adhering to all applicable laws, regulations and industry best practices in order to ensure the privacy and security of the individuals whose data are being analyzed.

Pat 1

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