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:
- 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:
- 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
- Review and amend vendor contracts to protect the interests of both the library and library patrons
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!