Category: Privacy

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Caring Who Is Sharing Your Patron Data

Welcome to this week’s Tip of the Hat! Last week Tom Boone stated his intent to boycott two vendors – Thomson Reuters and RLEX Group – at the American Association of Law Librarians annual conference based on the current business relationships that both companies have with U.S. Immigration and Customs Enforcement [ICE]. While the objections are based on the relationships themselves, the boycott posts brings us back to a question posed by Jason Griffey about LexisNexis’s interest in assisting ICE in building an “extreme vetting” system for immigrants to the US – what role would data collected from libraries that subscribe to those vendors’ products play in building such a system? For this week’s letter, we’ll broaden the – what do vendors do with library patron data and what say do libraries have in the matter?

Patron data is as valuable to vendors as it is to libraries. To vendors, patron data can be used to refine existing services while building newer services based off of patron needs and behaviors. The various recommendation systems in several library products are powered partially by patron borrowing activity, for example. Nonetheless, while vendors use patron data for their products and services, many vendors share patron data with other service providers and third-party businesses for a variety of reasons. For example, some vendors run their applications on commercial cloud servers, which could mean storing or transferring patron data to and from these servers. Depending on the agreement between the vendor and the commercial cloud service, the service might also have access to the data for performance tracking and analysis purposes.

How do you find out what vendors are doing with your patron data? One of the first places to look is their privacy policy. Like libraries, vendors too should inform patrons how they are handling patron data. The library should have a separate privacy policy that indicates how library data is shared with vendors, but vendors also need a privacy policy that clearly communicates to patrons using the vendor service on how the data is handled by the vendor, including any sharing of data with service providers or other third parties. LexisNexis’ privacy policy provides some of this information in their How We Use Your Information and Sharing of Your Information sections (which, BTW, you should read if you do use LexisNexis!).

If you can’t find the information you need in the privacy policy, the vendor contract might have some information regarding the collection, use, and sharing of patron data by the vendor. The vendor contract can also serve another purpose, particularly when you are at the contract negotiation or contract renewal stages. The contract can be a good place to lay out expectations to the vendor as to what level of data collection and sharing is permissible. Some data sharing is unavoidable or necessary, such as using aggregated patron data for analyzing infrastructure performance, so if you come to the negotiation table with a hardline “no reuse or sharing with third parties” position, you will most likely be making some compromises. This is also a good place to bring up the question about “selling” vs “sharing” data with service providers – while some vendors state in their privacy policy that they do not sell patron data, they might not mention anything about sharing it with others. Setting expectations and requirements at the point of negotiations or renewal can mitigate any surprises surrounding data use and sharing down the road for all parties involved.

Having the discussion about patron data use and sharing by the vendor will not only allow you to find out what exactly happens to your patrons’ data when they use vendor products, but it also opens up the opportunity for your library to introduce language in the contract that will protect your patrons’ data. You can do this through line edits, or through a contract addendum that has been vetted by your local legal team. Before going to the negotiation table with your proposed changes and requests, you will need to determine what points will you be willing to compromise on, and which points are dealbreakers. Ideally negotiations provide a workable outcome for all, but in reality, sometimes the best outcome for your patrons and staff is to leave the negotiations. Not giving a vendor your library’s business is a valid option – an option that could signal to the vendor that some of their practices need to change if enough libraries choose to follow suit.

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CRMS 101

Welcome to this week’s Tip of the Hat! Today we have a brief overview of an acronym that is becoming a popular tool in libraries – the customer relationship management system [CRMS] – and how this new player in the library field affects patron privacy. While some folks know about CRMS, there might be others that are not exactly sure what they are, and what they have to do with libraries. Below is a “101”- type guide to help folks get up to speed on the ongoing conversation.

What is a CRMS?

A customer relationship management system [CRMS] manages an organization’s interactions with customers with the goal to grow and maintain customer relationships with the organization. CRMS products have been used in other fields outside of librarianship for decades, mostly in commercial businesses, but the increased importance in data analysis and improving customer experiences has led for wider adoption of CRMS products in other fields, including libraries.

What is a CRMS used for?

Many organizations use CRMS products to track various communications with customers (email, social media, phone, etc.) as well as data about a customer’s interests, demographics, and other data that can be used for data analysis. This analysis is then used to improve and customize the user experience (targeted marketing, personal recommendations, and invitations, etc.) as well as making business decisions surrounding products, services, and organization-customer relations. This analysis can also be used to create user profiles or for market segmentation research.

What are some examples of CRMS?

There are many proprietary and open source options, though Salesforce is one of the most recognized CRM companies in the overall field. In the library world, several library vendors sell standalone CRMS products, such as OrangeBoy’s Savannah. Other library vendors have started offering products that integrate the CRMS into the Integrated Library System [ILS]. OCLC’s WISE is one such example of this integration, while other library vendors plan to release their versions in the near future.

What data is collected in a CRMS?

A CRMS is capable of collecting a large quantity of very detailed data about a customer. Types of patron data that can be collected with a library CRMS includes (but not limited to):

  • Demographic information
  • Circulation information like total checkouts, types of materials checked out, and physical location of checkouts
  • Public computer reservation information
  • Electronic resource usage
  • Program attendance

In addition to library supplied data, other data sets from external sources can be imported into the CRMS ranging from US Census data to open data sets from cities and other organizations that could include other demographic information by geographical area (such as zip code) or by other indicators.

How is patron privacy impacted by CRMS?

The amount of information that can be collected by a CRMS is akin to the type of information collected by commercial companies who sell services and products. By creating a user profile, the company can use that information to personalize that customer’s experience and interactions with the company, with the ultimate goal of creating and maintaining return customers. Traditionally libraries do collect and store some of the same information that CRMS products collect; however, it is usually not stored in one central database. Creating a profile of a patron’s use of the library leaves both the library and the patron at high risk for harm on both a personal and organizational level. This user profile is subject to unauthorized access by library staff, data breaches and leaks, or intentional misuse by staff or by the vendor that is hosting the system. This user profile can also be subject to a judicial subpoena, which puts patrons who are part of vulnerable populations at higher risk for personal harm if the information is collected and stored in the CRMS.

Further reading on the conflict between the CRMS, data collection, and library privacy:

What can we do to mitigate privacy risks if we use a CRMS?

If your library chooses to use a CRMS:

  • Limit the type and amount of patron data collected by the system. For data that is collected and stored in the CRMS, consider de-identification methods, such as aggregation, obfuscation, and truncation
  • Perform risk assessments to gauge the level of potential harm connected by collecting and storing certain types of patron information as well as matching up patron information with imported data sets from external sources
  • Negotiate at the contract signing or renewal stage with the vendor regarding privacy and security policies and standards around the collection, storage, access, and deletion/retention of patron data, as well as who is responsible for what in case there is a data breach
  • Perform regular privacy and security audits for both the library and the vendor

We hope that you find this guide useful! Please feel free to forward or pass along the guide in your organizations if you are having conversations about CRMS adoption or implementation. LDH can also help you through the decision, negotiation, or implementation processes – contact us to learn more!

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Data Analytics @ Your Library: An Executive Summary of the Santa Cruz Report

Welcome to this week’s Tip of the Hat!

Last week was a busy week in the world of library privacy, and not just because there were a variety of privacy-related presentations and events at ALA Annual. While folks were wrapping up and traveling back from DC, a Santa Cruz county civil grand jury published a report that will shape the library and vendor data analytics landscapes. Running short on time due to ALA travel last week and this week’s holiday schedule? Here’s an executive summary so you can get a head start on thinking about how to approach the report at your own organizations.

What was the report about?

The report, “Patron Privacy at Santa Cruz Public Libraries: Trust and Transparency in the Age of Data Analytics,” is the result of an investigation by the Civil Grand Jury about the Santa Cruz Public Library’s (SCPL) use of a commercial analytics program, Gale’s Analytics on Demand (AoD), to analyze patron data.

Who wrote the report?

The report was written by the Civil Grand Jury. The county of Santa Cruz has a Civil Grand Jury comprised of 19 private citizens. One of their roles in the county is to examine and investigate government operations and to recommend actions to improve said operations. The Consolidated Final Report for 2018-2019 lists other investigations undertaken by the Jury, including detention facilities and public defense contracts.

What did the report find?

The report found that the Santa Cruz Public Library did not adequately inform patrons about the use of AoD at SCPL or do a thorough privacy risk analysis on using AoD at SCPL. The major themes in the Grand Jury’s findings are:

  • Mismatch between use of AoD and SCPL confidentiality and privacy policy
  • Lack of communications between SCPL and library patrons regarding use of data analytics, including giving the patrons the option to give consent to the library to use their data for data analytic use
  • Failure on SCPL’s part to thoroughly investigate the risks, effectiveness, and best practices in using data analytics in processing patron data
  • Lack of contract language with the vendor that protects the interest of both SCPL and library patrons

What are the recommendations?

The Grand Jury recommendations to SCPL include:

  • Updating the SCPL confidentiality and privacy policy to reflect the use of data analytic tools to process patron data
  • Create a system that allows patrons to consent to having their data used for data analytics
  • Follow professional and industry best practices around patron privacy
  • Create a data privacy officer role whose responsibility will be implementing and enforcing the privacy policy
  • Review and amend vendor contracts to protect the interests of both the library and library patrons

What’s next?

ALA will most likely release a response to the report in the near future; however, the next major updates will most likely come at the time where the library will submit their responses to the Grand Jury’s finding and recommendations later in the year.

We use analytics software – based on this report, what do we do?

The recommendations provide a good outline to where to begin. If you need a place to start, here are four key actions to focus on:

  • Review privacy policies – does your policy clearly tell patrons that you use analytics to process patron data?
  • Review current patron communications – how are you communicating with patrons about how the library uses their data? Can your patrons give consent to having their data processed by analytics software? Is there a way they can opt-out?
  • Review your privacy practices – Go through the ALA Library Privacy Checklists and make a plan of action for any areas in the Priority 1 Actions sections of the lists that your organization has not implemented
  • Review vendor contracts – pay close attention to areas in which contracts can be amended to shore up patron privacy protections including reflecting local and state regulations surrounding patron data and responsibilities of the vendor in the event of a data breach.

Feel free to forward this summary to folks in your organization! We highly recommend giving the full report a read, but we recognize that time is sparse during the summer season, so we hope that the above summary can help you start conversations at your organization. LDH will keep you updated as the official responses from SCPL, ALA, and others are published in the coming months.

As a reminder, LDH Consulting Services can assist your organization in reviewing privacy policies and practices in addition to risk assessments, staff training, and data inventories. If you have any questions, or would like to discuss how LDH can help your organization’s privacy practices, give us a ping!

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To Renew Or Not To Renew

Welcome to this week’s Tip of the Hat! We at LDH are furiously getting ready for ALA Annual next week, and the Executive Assistant is bummed that she was not able to register for the conference. It appears that the only cats that are allowed at Annual are Baker and Taylor. Worry not, for the Executive Assistant has lined up someone to go in her place. You will get a chance to meet this new team member if you are heading to Annual. Stay tuned…

In the meantime, it’s Monday, and Mondays are the best days to talk contract renewals, right?

(Right?)

Last week Samantha Lee wrote about the upcoming changes to Lynda.com’s authentication process for library patrons, which would require patrons to either create or link a LinkedIn account to use their library’s Lynda.com subscription. Lee details the various issues surrounding patron privacy with this upcoming change:

LyndaLibrary had access to library card numbers for verification purposes. With the proposed change to require patrons to get LinkedIn accounts to access the Lynda resources, LinkedIn Learning would have access to more personally identifiable information than they would have as LyndaLibrary. To get a LinkedIn account, patrons would need to provide an email address and their first and last names. This is more PII than other library e-content vendors would require (OverDrive requires library card numbers only, Hoopla requires a library card and email). After a user creates an account, they are prompted to then add employment history and import their email contacts – under the presumption to help users expand their professional network. So LinkedIn would not only have patron information, but also information for others who did not agree to use its platform. [emphasis added]

In the post, Lee pointed out that several libraries have already decided not to renew their Lynda subscriptions. In the comments section, two commenters related their less-than-positive experiences in asking their vendor representative about the proposed changes, as well one commenter a vendor representative, explaining why the changes were being made.

This recent change highlights the long-standing tension between libraries and vendors regarding patron data. As Lee mentioned, other vendors do use some patron data to verify that the patron is with that particular library and can use the service. This tension is complicated by a number of factors, from the administrative (what data is being collected and why) to the technical (what data is needed for the service to function). Cloud-based applications add another layer of complicating factors, particularly if third-party contractors (sub-contractors) are involved in providing the infrastructure or other services for the application, which then increases the number of potential people that have access to patron data.

Some libraries use the contract negotiations and/or renewal phases to include contract clauses holding vendors to privacy and confidentiality policies set by the library, along with other privacy and security requirements surrounding patron data. Other times vendors work with libraries to create privacy-driven development and practices, closely aligning their applications to the standards of privacy laid out by libraries. And then there are times when vendors are proactive in creating a service or application with patron privacy in mind!

The Lynda.com change seems to be following the usual conflict pattern if you read through the comments – libraries pushing vendors for changes, vendors pushing libraries about why the changes are necessary. Sometimes, though, one party leaves the negotiations in hopes to gain an advantage over the other party. This is not without risk. Considering that many library patrons use Lynda.com for professional development and learn much-valued technical skills, some libraries might hesitate leaving the Lynda.com contract on the table. Nonetheless, some libraries are taking that risk in hopes that if there is a critical mass of unsigned contract renewals, then the vendor would have to respond to their requests. As Lee states, “If LinkedIn Learning cannot take our profession’s concerns seriously… then we can and will take our business elsewhere. Maybe then they will be willing to adopt the changes we require to protect patron privacy.” There is already some momentum for this strategy as mentioned by Lee and the commenters, and perhaps we might observe a critical mass sooner than later.

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You Say Security, I Say Privacy…

Welcome to this week’s Tip of the Hat!

You might have seen the words “security” and “privacy” used interchangeably in articles, blog posts, and other areas of discussion surrounding protecting sensitive data. Sometimes that interchange of words further complicates already complex matters. A recent article by Steve Touw explores the confusion surrounding encryption and redaction methods in the CCPA. Touw breaks down encryption and redaction to their basic components which shows that each method ultimately lives in two different worlds: encryption in the security world, and redaction in the realm of privacy.

But aren’t privacy and security essentially the same thing, which is the means of protecting an asset (in our case, data)? While both arguably have the same goal in protecting a particular asset, privacy and security are different in the way in which they approach risk assessment and evaluation. In the scope of information management:

Security pertains to actions that protect organizational assets, including both personal and non-personal data.

Privacy pertains to the handling, controlling, sharing, and disposal of personal data.

Security and privacy do share key concepts and concerns, including appropriate use, confidentiality, and access to organizational assets (including personal data). Nonetheless, implementing security practices doesn’t necessarily guarantee privacy; a quote that makes the rounds in privacy professional groups is “You can have security without privacy, but you cannot have privacy without security.”

An example of the above quote comes from when you log into a system or application. Let’s use staff access to the integrated library system for this example. A login allows you to control which staff can access the ILS. Assigning individual logins to staff members and ensuring that only those logins can access the staff functions in the ILS is a security measure. This security measure protects patron data from being inappropriately accessed by other patrons, or others looking for that data. On that point of using security to protect privacy, so far, so good.

Once we get past the login, though, we come to a potential privacy issue. You have staff logins, which prevent unauthorized access to patron data by the public, but what about unauthorized access to patron data by your own staff? Not every staff member needs to have access to patron data in order to perform their daily duties. By leaving staff logins to have free reign over what they can access in the ILS database, you are at risk of violating patron privacy even though you have security measures in place to limit system access to staff members. To mitigate this risk, another security measure can be used – assigning who can access what through role or group level access controls. Most ILSes have a basic level of role-based access controls where systems administrators can assign the lowest level of access needed for each role, and applying these roles consistently will limit the instances of unauthorized access to data by staff.

All the security measures in the world, nonetheless, will not mitigate the risk of privacy harm to your patrons if your ILS is collecting highly sensitive data in the first place! These security measures don’t prevent you from collecting this type of data. This is where privacy policies and determining what data needs to be collected to meet operational needs come into play. If you don’t collect the data, the data cannot be breached or leaked.

It’s clear from this example that both privacy and security have parts to play in protecting patron privacy. Understanding these parts – where they overlap, and where they diverge – will help you through building and maintaining a robust set of data privacy and security practices throughout your organization.

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Lightbeams and Stickers and Summer, Oh My!

Welcome to this week’s Tip of the Hat and to the unofficial start of summer. This week’s newsletter comes to you in two parts as you get back into the work routine after the holiday weekend.

Trackers, trackers everywhere

Many of you probably have at least some protection against web site trackers in your browser of choice, but do you know the true extent of user tracking on the web – perhaps even the website for your library or business? The Firefox Lightbeam add-on provides a comprehensive overview of the various trackers on a website that you’d otherwise miss if you try to compile this information on your own. The overview not only captures trackers from the web site but also third-party trackers. Once you have installed the add-on, disable your tracker blockers and browse the web, and Lightbeam will visualize how you are being tracked throughout your entire web browsing session. Give this tool a try if you want to get a sense of the extent of tracking of library patrons visiting multiple sites across different owners (for example, a patron going from a library home page to search for an ebook, landing on a results page in the discovery layer, and then going to the ebook vendor’s site). H/T to SwiftOnSecurity for tweeting about the extension!

Stickers, stickers everywhere

The Executive Assistant has been busy as LDH prepares for our trip to ALA Annual in DC, but she’s found some time to give us a sneak peek of what will be available at our table…

A brown hat sticker placed on top of a black cat looking at the camera.
For those who will be at the Exhibit Hall Grand Opening on Friday, June 21st, we will have laptop stickers! Below are the two designs that will be available: a hat sticker and a hexagon sticker.

Two stickers: one hexagon sticker with a brown hat, and the other a brown hat.

Subscribers to this newsletter don’t have to wait until Annual to get their stickers – reply to this email and we will mail a few stickers your way. Stick them to your laptop, your door, your water bottle, or any other place where you want to tell folks that you care about library privacy and to “Follow The Hat.” Many thanks to Scott Carlson for creating the sticker design.

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Humans, Tech, and Ethical Design: A Summit Reflection

Welcome to this week’s Tip of the Hat!

Last Saturday LDH attended the All Tech Is Human Summit with 150+ other technologists, designers, ethics professionals, academics, and others in discussing issues surrounding technology and social issues. There were many good conversations, some of which we’re passing along to you all as you consider how your organization could approach these issues.

The summit takes inspiration from the Ethics OS Toolkit which identifies eight risk zones in designing technology:

  1. Truth, Disinformation, Propaganda
  2. Addiction & the Dopamine Economy
  3. Economic & Asset Inequalities
  4. Machine Ethics & Algorithmic Biases
  5. Surveillance State
  6. Data Control & Monetization
  7. Implicit Trust & User Understanding
  8. Hateful & Criminal Actors

Each risk zone has the potential to create social harm, and the Toolkit helps planners, designers, and others in the development process to mitigate those risks. One of the ways you can mitigate risk in many of the areas in the design process (like the Data Control and Surveillance zones) is incorporating privacy into the design and development processes. Privacy by Design is an example of integrating privacy throughout the entire process, instead of waiting to do it at the end. Much like technical debt, incorporating privacy and other risk mitigation strategies throughout the design and development process will lessen the need for intensive resource investment on short notice when something goes wrong.

Another way to approach ethical design comes from George Aye, co-founder of the Greater Good Studio. In his lightning talk, George identified three qualities of good design:

  • Good design honors reality
  • Good design creates ownership
  • Good design builds power

Viewed through a privacy lens (or, in the case of LDH, with our data privacy hat on), these qualities can also help approach designers and planners in addressing the realities surrounding data privacy:

  • Honoring reality – how can the product or service meet the demonstrated/declared needs of the organization while honoring the many different expectations of privacy among library patrons? Which patron privacy expectations should be elevated, and what is the process to determine that prioritization? What societal factors should be taken into account when doing privacy risk assessments?
  • Creating ownership – how can the product or service give patrons a sense that they have ownership over their data and privacy? How can organizations cultivate that sense of ownership through various means, including policies surrounding the product? For vendors, what would it take to cultivate a similar relationship between library customers and the products they buy or license?
  • Building power – building off of the ownership questions, what should the product or service do in order to provide agency to patrons surrounding data collection and sharing when using the product or service? What data rights must be present to allow patrons control over their interactions with the product or process? Libraries – how can patrons have a voice in the design process, including those more impacted by the risk of privacy harm? Vendors – how can customers have a voice in the design process? All – how will you ensure that the process will not just be a “mark the checkbox” but instead an intentional act to include and honor those voices in the design process?

There’s a lot to think about in those questions above, but the questions illustrate the importance of addressing those questions while still in the design process. It’s hard to build privacy into a product or services once the product is already out there collecting and sharing high-risk data. Addressing the hard ethical and privacy questions during the design process not only avoids the pitfalls of technical debt and high-risk practices, but also provides the valuable opportunity to build valuable relationships between libraries, patrons, and vendors.

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AI, Read The Privacy Policy For Me

Welcome to this week’s Tip of the Hat! Last week we took a deep dive into ALA’s privacy policy to figure out where our information was going if we agreed to receive information from exhibitors while registering for the Annual Conference.

[Which, ICYMI, LDH will be exhibiting at Annual! Let us know if you want to meet up and talk about all things privacy and libraries!]

As we encountered last week, privacy policies are not the most exciting documents to read. In fact, you can test out this theory by checking out the impressive list of electronic resource vendor privacy policies generated by the folks at York University (the code is available on GitHub). Try picking out a couple of privacy policies and read them from start to finish now. We’ll be here waiting for you.

…

…..

……. all done?

Chances are, you probably found yourself skimming the policies if you made it all the way to the bottom. If so, you’re not alone – studies have shown that the majority of folks do not read these policies, which could lead to surprises and confusion when your data is collected, shared, or breached. The fact is that it takes a long time to get through long, detailed documents – a recent study showed that many privacy policies require a high reading level and up to around a half hour to read. What’s a busy person to do?

One way some folks are addressing this is to let the machines do the reading for you. The last few years have seen several tools that use AI and machine learning (ML) to analyze privacy policies, selecting the very important parts that users should know. For example, the Usable Privacy Policy Project, an NSF funded project, used a collection of 115 privacy policies annotated by law students to train machine classifiers to annotate over 7000 privacy policies. Another group of researchers used the same 115 annotated privacy policies for ML training, creating two different tools for AI-generated analysis of policies. The first is Polisis, which creates a Sankey diagram based off of the AI’s analysis of the policy, while the second is Pribot, a chatbot that allows users to explore and ask questions about specific privacy policies.

Each AI privacy analysis tool takes a different approach in displaying the results to the end users. Let’s use OverDrive’s privacy policy as our test policy. [1] The Usable Privacy site uses different colored fonts to indicate which parts of the policy belong to 10 different categories. The site also directs us to another policy analysis of OverDrive’s Privacy Policy for Children. Users can click on a category to only show the colored sections of the policy, or to exclude it.

A screenshot of Usable Privacy's analysis of the OverDrive privacy policy.

For Polisis’ analysis of OverDrive’s policy, the site takes the same ten categories and creates separate visualizations for most of them. Users can click on a stream to highlight it in the diagram – for example, showing what information is shared and for what reason.

A screenshot of Polisis' analysis of OverDrive's privacy policy.

We are still a ways away before widespread adoption of AI-annotated privacy policies; however, the possibilities are promising. With GDPR, CCPA, and other upcoming privacy regulations, AI and ML could help end users in keeping up with all the changes in policies, as well as dig through mountains of text in a fraction of the time it would have taken to manually read all of the text. It will still take a considerable human role in training the AI and supervising the ML to ensure proper analysis, though, as well as human labor in creating effective and accessible interfaces. Perhaps one day there could be an API service that can have AI analyze the privacy policies listed on the York University page.

[1] Both sites are analyzing older versions of OverDrive’s privacy policy. The most up to date privacy policy is at https://company.cdn.overdrive.com/policies/privacy-policy.htm.

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Monday Mystery: Conference Information Sharing

Welcome to this week’s Tip of the Hat! It seems that spring has just arrived for many of us in the US; however, the calendar tells us that we are only weeks away from the ALA Annual Conference in Washington DC in June. Our Executive Assistant was going through the PDF registration form the other day and noticed the following question:

A text box with the following text: "Attendees may receive exciting advance information from exhibitors like invitations, contests and other hot news. COUNT ME IN!" Yes/No checkboxes are next to the last sentence.

The above question on the registration form asks if the person (or in this case, cat) wants to receive information from conference exhibitors. The Executive Assistant paused. What does checking the “Yes” box all entail? Since we’re in the data privacy business, this is a perfect Monday Mystery for us to investigate.

After a quick search of the conference website, we land on ALA’s Privacy Policy at http://www.ala.org/privacypolicy. If you haven’t spent time with a privacy policy, it can seem daunting or downright boring. Let’s walk through this policy to find out what happens when we check the “Yes” box.

The “Information Collection & Use” section lays out what information is collected and when. They define “personal data” as information that can be used to identify someone: name, email, address, etc. The section breaks down some common actions and situations when ALA collects data, including event registration. We already guessed that ALA was collecting our information for event registration purposes, but we need to dig deeper into the policy to answer our question.

We then find a section labeled “Information Sharing” in which we might find our answer! The section lists who ALA shares information with in detail, including the type of data and circumstances that the data is shared. “Services Providers” seems promising – that is until we get into the details. The data listed that is shared to service providers is mostly technical data – location data, log files, and cookies – and has nothing regarding giving information to receive updates from exhibitors. Back to square one.

Moving down the policy, we arrive at the “Your Rights and Choices Regarding Your Information” section, which lists the following right:

“Object to processing – You have the right to object to your Personal Data used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and (c) processing for purposes of scientific/historical research and statistics;”

Okay, we have the right to ask ALA not to use our personal data for marketing purposes. That’s a very important right to have, though that doesn’t exactly solve the mystery of what happens when we click on the “Yes” box.

This, readers, is where we are going to cheat in this investigation. It’s time to put our exhibitor hat on!

Exhibitors at major conferences are usually offered some form of registrant/member list as a means to promote their business before the conference. ALA does the same with Annual, and exhibitors can rent attendee lists. From https://2019.alaannual.org/list-rental, exhibitors have the option to “[t]arget buyers by industry segment, demographic profile or geographic area.” So, just not names and emails are shared!

On the exhibitor side, having that information would allow for targeted marketing – instead of blasting the entire attendee list, exhibitors can reach out to those most likely to be receptive to their service or product. On the attendee side, some want to have this type of targeted marketing to plan their time at the conference efficiently, or to do homework before hitting the exhibit hall. For other attendees, though, it means more emails that they’ll just delete or unsubscribe. And then there’s the question about what happens to that attendee data after the conference…

In the end, we still have a bit of a mystery on our hands. The only reason we got this far in our little Monday Mystery investigation is that LDH has been bombarded with emails trying to sell us attendee lists which tipped us off to start looking at the exhibitor section of the conference site. Your average conference attendee wouldn’t have that information and would be left scratching their heads due to the lack of information at the point of registration about what information is shared on these attendee lists. While we don’t have a clear answer to end today’s investigation, we hope that this gives our readers a little reminder to do some research the next time they are asked a similar question on a registration form.

Speaking of ALA Annual, LDH Consulting Services is excited to announce that we will be exhibiting in DC in booth 844! Many thanks to Equinox Open Library Initiative for making exhibiting at ALA Annual possible for LDH. Give us a ping if you will be at Annual and would like to talk more about LDH can do for your organization.

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#ChoosePrivacy 2019: Privacy and Equity

Welcome to this week’s Tip of the Hat! This week marks the start of Choose Privacy Week, hosted by the ALA Office of Intellectual Freedom. We briefly covered CPW in our National Library Week newsletter, but we couldn’t pass up the chance to join in the festivities of a week dedicated to library privacy.An image of two arms coming together in front of a padlock, with the text "Inclusive Privacy, Closing the Gap" below it. To the right of the image is the text "May 1-7 Choose Privacy Week #chooseprivacy".

This year’s Choose Privacy Week is focusing on how privacy in libraries is vital for those who are otherwise targeted for surveillance and data-based discrimination elsewhere in the US. Library workers stress privacy as a core tenet of Intellectual Freedom; however, this focus can be very narrow with regard to protecting a subset of patron information from specific unauthorized uses and access, e.g. a government entity accessing a patron’s circulation records. This narrow interpretation of the role privacy plays in the library does not take into account the evolution of the role of data in libraries and in society. Data has taken its place as a critical tool in ensuring funding and continued operations. We see this evolution with the increasing prevalence of customer relations management systems, learning analytics, and identity-based services (such as RA21) in the library environment.

With the rise of data-as-valuable-asset, comes the dark side, or taking a cue from Bruce Schneier, the toxicity of data. Data has been used to target marginalized populations via surveillance and other means. How can data harm vulnerable populations? Taking a look around the Seattle area, here are two recent cases in which data collection inflicted real-world harm on people:

Another resource highlighting past and potential harms is http://neveragain.tech/. This pledge site started when the current US president proposed a registry of Muslims in the US. The page highlights some of the ways that technology was used against marginalized populations throughout recent times, as well as the harms that come with data collection.

Reframing the conversation about why privacy is important in libraries requires rethinking the field’s approaches surrounding privacy practices and policies. Privacy with regard to pursuing intellectual interests needs to take into account the social factors that come into play when someone from a vulnerable population uses the library. Many libraries market themselves as a “third place” or a place where the community can gather together for a variety of reasons, be it studying, meetings, programs, or even a safer space to spend free time outside of the home, work, or school. While data is useful in relation to building and maintaining operations that best benefit all patrons in the library’s third place role, care needs to be taken to ensure that the same data is not used to harm patrons as demonstrated in the cases above.

If you are looking for how to approach your privacy practices with an equity lens, you will hear from a variety of backgrounds and viewpoints during this year’s CPW. Maybe you’ll find something that you haven’t considered in relation to your privacy practices, or find an opportunity to be proactive in building trust with patrons. In either case, we’re looking forward to finding out more about how libraries can align privacy with equity during Choose Privacy Week!