Lincoln Trail Librariers System
Privacy Policy (Draft, based on ALA
recommended policy)
I. Introduction
Privacy is essential to the exercise of free
speech, free thought, and free association. In Lincoln Trail Libraries System,
the right to privacy is the right to open inquiry without having the subject of
one's interest examined or scrutinized by others. Confidentiality exists when
Lincoln Trail Libraries System is in possession of personally identifiable
information about users and keeps that information private on their behalf.
The courts have upheld the right to privacy
based on the Bill of Rights of the U.S. Constitution. Many states provide
guarantees of privacy in their constitutions and statute law. Numerous
decisions in case law have defined and extended rights to privacy. This
library's privacy and confidentiality policies are in compliance with
applicable federal, state, and local laws.
User rights—as well as our
institution's responsibilities—outlined here are based in part on what
are known in the United States as the five "Fair Information Practice
Principles." These five principles outline the rights of Notice, Choice,
Access, Security, and Enforcement.
Our commitment to your privacy and
confidentiality has deep roots not only in law but also in the ethics and
practices of librarianship. In accordance with the American Library
Association's Code of Ethics:
"We protect each library user's right
to privacy and confidentiality with respect to information sought or received
and resources consulted, borrowed, acquired, or transmitted."
II. Lincoln Trail Libraries System¹s
Commitment to Our Users Rights of Privacy and Confidentiality
This privacy policy explains your privacy
and confidentiality rights, the steps this library takes to respect and protect
your privacy when you use library resources, and how we deal with personally
identifiable information that we may collect from our users.
1. Notice & Openness
We affirm that library patrons have the
right of "notice"—to be informed about the policies governing
the amount and retention of personally identifiable information, and about why
that information is necessary for the provision of library services.
We post publicly and acknowledge openly the
privacy and information-gathering policies of this library. Whenever policies
change, notice of those changes is disseminated widely to our users.
In all cases we avoid creating unnecessary
records, we avoid retaining records not needed for the fulfillment of the
mission of the Lincoln Trail Libraries System, and we do not engage in
practices that might place information on public view.
Information we may gather and retain about
current and valid library users include the following (This list should be
comprehensive, and should include locally relevant examples):
€User Registration Information
€Circulation Information
€Electronic Access Information
€Information Required to Provide Library
Services
2. Choice & Consent
This policy explains our information
practices and the choices you can make about the way the library collects and
uses your information. We will not collect or retain private and personally
identifiable information without your consent. Further, if you consent to give
us personally identifiable information, we will keep it confidential and will
not sell, license or disclose personal information to any third party without
your consent, unless we are compelled to do so under the law or to comply with
a court order.
If you wish to receive borrowing privileges,
Lincoln Trail Libraries System libraries must obtain certain information about
you in order to provide you with a library account. When visiting our library's
Web site and using our electronic services, you may choose to provide your
name, e-mail address, library card barcode, phone number or home address.
You have the option of providing us with
your e-mail address for the purpose of notifying you about your library
account. You may request that your library remove your e-mail address from your
record at any time.
We never use or share the personally identifiable
information provided to us online in ways unrelated to the ones described above
without also providing you an opportunity to prohibit such unrelated uses,
unless we are compelled to do so under the law or to comply with a court order.
3. Access by Users
Individuals who use library services that
require the function and process of personally identifiable information are
entitled to view and/or update their information. You may either view or update
your personal information online or in person. In both instances, you may be
asked to provide some sort of verification such as a pin number or
identification card to ensure verification of identity.
The purpose of accessing and updating your
personally identifiable information is to ensure that library operations can
function properly. Such functions may include notification of overdue items,
recalls, reminders, etc. The library will explain the process of accessing or
updating your information so that all personally identifiable information is
accurate and up to date.
4. Data Integrity & Security
Data Integrity: The data we
collect and maintain at the library must be accurate and secure. We take every
possible step to assure data integrity, including: using only reputable sources
of data; providing our users access to your own personally identifiable data;
updating data whenever possible; utilizing middleware authentication systems
that authorize use without requiring personally identifiable information;
destroying untimely data or converting it to anonymous form.
Data Retention: We protect
personally identifiable information from unauthorized disclosure once it is no
longer needed to manage library services. Information that should be regularly
purged includes personally identifiable information on library resource use,
material circulation history, and security/surveillance tapes and logs.
Tracking Users: We remove links
between patron records and materials borrowed when items are returned and we
delete records as soon as the original purpose for data collection has been
satisfied. We permit in-house access to information in all formats without
creating a data trail. Our library has invested in appropriate technology to
protect the security of any personally identifiable information while it is in
the library's custody, and we ensure that aggregate, summary data is stripped
of personally identifiable information. We do not ask library visitors or Web
site users to identify themselves or reveal any personal information unless
they are borrowing materials, requesting special services, registering for
programs or classes, or making remote use from outside the library of those
portions of the Lincoln Trail Library System¹s Web site restricted to
registered borrowers under license agreements or other special arrangements. We
discourage users from choosing passwords or PINs that could reveal their
identity, including social security numbers. We regularly remove cookies, Web
history, cached files, or other computer and Internet use records and other
software code that is placed on our computers or networks.
Third Party Security: We ensure that our
library's contracts, licenses, and offsite computer service arrangements
reflect our policies and legal obligations concerning user privacy and
confidentiality. Should a third party require access to our users' personally
identifiable information, our agreements address appropriate restrictions on
the use, aggregation, dissemination, and sale of that information, particularly
information about minors. In circumstances in which there is a risk that
personally identifiable information may be disclosed, we will warn our users.
When connecting to licensed databases outside the library, we release only
information that authenticates users as "members of our community."
Nevertheless, we advise users of the limits to library privacy protection when
accessing remote sites
Cookies: Users of networked
computers will need to enable cookies in order to access a number of resources
available through the library. A cookie is a small file sent to the browser by
a Web site each time that site is visited. Cookies are stored on the user's
computer and can potentially transmit personal information. Cookies are often
used to remember information about preferences and pages visited. You can refuse
to accept cookies, can disable cookies, and remove cookies from your hard
drive. Our Library servers use cookies solely to verify that a person is an
authorized user in order to allow access to licensed library resources and to
customize Web pages to that user's specification. Cookies sent by our Library
servers will disappear when the user's computer browser is closed. We will not
share cookies information with external third parties.
Security Measures: Our security
measures involve both managerial and technical policies and procedures to
protect against loss and the unauthorized access, destruction, use, or
disclosure of the data. Our managerial measures include internal organizational
procedures that limit access to data and ensure that those individuals with
access do not utilize the data for unauthorized purposes. Our technical
security measures to prevent unauthorized access include encryption in the
transmission and storage of data; limits on access through use of passwords;
and storage of data on secure servers or computers that are inaccessible from a
modem or network connection.
Staff access to personal data: We permit only
authorized Library staff with assigned confidential passwords to access
personal data stored in the Library's computer system for the purpose of
performing library work. We will not disclose any personal data we collect from
you to any other party except where required by law or to fulfill an individual
user's service request. The Library does not sell or lease users' personal information
to companies, universities, or individuals.
5. Enforcement & Redress
Our library will not share data on
individuals with third parties unless required by law. We conduct regular
privacy audits in order to ensure that all library programs and services are
enforcing our privacy policy. Library users who have questions, concerns, or
complains about the library's handing of their privacy and confidentiality
rights should file written comments with the Director of the Library. We will
respond in a timely manner and may conduct a privacy investigation or review of
policy and procedures.
We authorize only the Lincoln Trail Libraries System Executive Director to receive or comply with requests from law enforcement officers; we confer with our legal counsel before determining the proper response. We will not make library records available to any agency of state, federal, or local government unless a subpoena, warrant, court order or other investigatory document is issued by a court of competent jurisdiction that shows good cause and is in proper form. We have trained all library staff and volunteers to refer any law enforcement inquiries to library administrators.