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Document #8D.1Board of Library Trustees MeetingMay 28, 20081
DRAFT FOR BOARD CONSIDERATIONDistrict of Columbia Public Library
Policy on Privacy and ConfidentialityPolicy Statement
The District of Columbia Public Library protects the privacy and confidentiality of alllibrary users, no matter their age.Legal basis for policy: The policy is based on DC Official Code Sec 39-108 (2001 Ed.)Confidentiality of Circulation Records.The Library’s commitment to users’ privacy and confidentiality has deep roots not onlyin the law but also in the ethics and practice of librarianship. In accordance with theAmerican Library Association’s code of Ethics: “We protect each library user’s right toprivacy and confidentiality with respect to information sought or received and resourcesconsulted, borrowed, acquired, or transmitted.”This privacy statement explains the users’ privacy and confidentiality rights andresponsibilities, the steps the Library takes to respect and protect a user’s privacy whenusing library resources, and how the Library deals with personally identifiableinformation collected from library users.
Privacy and Confidentiality Practices
The Library avoids creating unnecessary records, avoids retaining records not needed forLibrary business purposes, and does not engage in practices that might place personallyidentifiable information on public view.Information the Library may gather and retain about current library users includes thefollowing:Information required to register for a library card (e.g. name, address, telephone number,e-mail address, birth date)Records of material checked out, charges owed, payments madeRequests for interlibrary loan or reference serviceSign-up information for library classes and programs
Consent
The Library will not collect or retain a library user’s private and personally identifiableinformation without the user’s consent.
 
Document #8D.1Board of Library Trustees MeetingMay 28, 20082The Library will keep the information confidential and will not sell, license or disclosepersonal information to any third party, except an agent working under contract to theLibrary, unless the Library is required by law to do so.
Data Integrity and Security
The Library takes reasonable steps to assure data integrity.The Library has invested in appropriate technology to protect the security of personallyidentifiable information while it is in the library’s custody.The Library assures that aggregate, summary data is stripped of personally identifiableinformation.The Library regularly removes cookies, web browsing history, cached files, or othercomputer and Internet use records and other software code that is placed on the Library’scomputers or networks.
Staff Access to Personal Data
Library staff may access personal data stored in the library’s computer system only forthe purpose of performing their assigned library duties. Staff will not disclose anypersonal data collected from a user to any other party except where required by law. TheLibrary does not sell, lease or give users’ personal information to companies,governmental agencies, or individuals except as required by law or with the user’sauthorization.
Third Party Security
The Library ensures that its contracts, licenses, and offsite computer servicearrangements reflect its policies and legal obligation concerning user privacy andconfidentiality. When connecting users to licensed databases and other electronicresources outside the Library, the Library releases only information that authenticates theuser as library card holder of the District of Columbia Public Library. Nevertheless,users must be aware, when accessing remote sites, that there are limits to the privacyprotection the Library can provide.Some library users may choose to use electronic communication services from the library(hold and overdue notices, program and class announcements) via e-mail. These usersmust also be aware that the Library has limited ability to protect the privacy of thisinformation once it is outside the Library’s control.The Library also offers a wireless network that allows users to connect to the Internet.Users should be aware that data accessed and sent over the Library’s wireless network isnot encrypted.
 
Document #8D.1Board of Library Trustees MeetingMay 28, 20083
Parents and Children
The Library respects the privacy and confidentiality of all library users, no matter theirage. Parents or guardians of a child under the age of 18 may obtain access to their child’slibrary records only if they provide the child’s library card or card number.
Illegal Activity Prohibited and Not Protected
Users may conduct only legal activity while using library resources and services.Nothing in this statement prevents the Library from exercising its right to enforce Rulesof Conduct, protect its facilities, networks and equipment from harm, or prevent the useof library facilities and equipment for illegal purposes. The Library can electronicallymonitor public access computers and external access to its networks and reserves theright to do so when a violation of law or library policy is suspected.
Redress
Any library user with a question, concern, or complaint about the Library’s handling of privacy and confidentiality rights and practices, may file written comments with theChief Librarian. The Library will respond in a timely manner and may conduct a privacyinvestigation or review of practices and procedures.
Law Enforcement Requests
The Chief Librarian is custodian of library records and is the only party authorized toreceive or comply with public records requests or inquiries from law enforcementofficers. The Chief Librarian may delegate this authority to designated members(s) of theLibrary’s management. The Chief Librarian has the right to confer with the Office of theAttorney General before determining the proper response to any request for records. TheLibrary will not make library records available to any agency of state, Federal or Districtgovernment unless a subpoena, warrant, court order or other investigatory document isissued by a court of competent jurisdiction, showing good cause and in proper form. TheLibrary staff will refer any law enforcement inquiries to the Office of the Chief Librarianor her designee.
How the Library Uses Data it Collects
The Library’s Website – When library users visit the DCPL website, the Library collectsand stores only information to measure the number of visitors to different areas of the siteto guide in making the site more useful. The information collected includes:the IP address of the user’s computer or Internet providerthe date and time of access
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