Library and Software Privacy Policy

General Library Privacy Policy and GDPR

When you use our library services, we will collect certain personal information about you. We use library management software to help us manage and operate our libraries. When you use our library services, you or we will use this software when you look up materials in our library, check out books, ask for loans from other libraries, among other uses. Our library management software is operated and provided to us by a third-party company who will also have access to and use your personal information as set out in this Privacy Notice. References in this Privacy Notice to “we”, “us” and “our” refer to us (the library), to the library staff, to other libraries in our system, and to the company that provides us our library management software. Some of this information we collect will be personal information that may identify, relate to, describe, associate or be linked to you such as:

Personal identifiers such as your name, your postal address, your telephone numbers, your birthdate, your library card or ID number or code, the IP address from the computer you are using to access the library system, and your email addresses.
Information about your library use such as library materials you have checked out and returned, materials you have viewed, used or reserved, search terms you have used in connection with our software, your reading interests, search terms and results, and materials you may store in lists such as “favorites” lists.
Your photograph if the library that uses our software requires one for your library card or other library ID.
If we allow you to access the internet through our software, your electronic network activity information, such as your browsing history and your search history.

The sources from which we collect your information

We collect or receive information about you from the following sources:

Information that you provide to us when you use our services or the software that we use for our library management.
Information that we collect about you when you use our services or the software that we use for our library management.
If we acquire a company or a library joins our group that has access to your information, we may obtain your information from that company or library.
If you contact us, we will use your information to contact you about your use of our services, to enhance the operation of our software and services and to administer our systems.

The reasons we collect your information

Here are the principal reasons we collect information from you:

We collect your name, address, telephone numbers, and email address to help us identify you and help us provide our services to you. We collect this information to help us keep track of the location of materials you may have borrowed from us. We collect this information about you so that the we can help you request or reserve materials or to engage in loans from other libraries. We also collect this information to help us communicate with you concerning these things.
We collect information about your library uses such as library materials you have checked out and returned, materials you have viewed, used or reserved through a library’s system, search terms you have used, and your reading interests, search terms and results to help us provide our services to you and to allow you to view the library materials you have used or searched for in the past. We will use this information to help us keep track of the location of our materials, to determine the level of use of our materials, and to assist us in making acquisition decisions for future library materials.
We may collect your photograph so that we can confirm the identity of persons using our services.
We may collect your electronic network activity information, such as your browsing history and your search history, so that we can assist you in accessing such information in the future if you desire.
We do not sell your information to others. However, if our library joins a new consortium, is acquired, or the company that provides us our software technology is acquired or sold to another person or company, they may obtain your information in connection such acquisition or sale.

Third parties that we may share your information with

We may share your information with the following categories of third parties:

We may share your information with our staff or with other libraries who use our library management software when you access our services. However, we do not share your information with other libraries outside of our system that may use our library management software unless you are a patron those libraries or are requesting an interlibrary loan.
We may share your information with companies or other persons who provide services and software to us such as consultants and software developers who provide our library management software to us and that help us manage or develop our software, or other companies who provide software that help us provide services to you such as authentication services, collection services, and database services, among others services and functions.
Our employees and consultants may have access to your information through our software and may access it to provide our services to you and to assist them in providing their services to you.
If we are acquired, the acquiring company or person will receive the information that we have about you.
If a governmental entity requests information from us, we may share your information with them.
If a person or company obtains information from us through legal process such as a subpoena or litigation discovery, we may share your information with them and the court system.

Libraries may use or share your information in ways different than we do

Other libraries who use our library management software and collect information from you may collect other information about you and may use or share your information in ways that are different than those described above. We cannot control their collection or uses of such information, or who they share it with, and we encourage you to contact the libraries you use to see how they use your information.

Privacy Rights of California Residents

If you are a resident of California, you may have additional rights regarding our use of your personal information. Please review our Privacy Notice for California Residents here. [Insert link to document/web page]

GDPR Privacy Rights of EU Residents

If you are a resident of the European Union, you may have additional rights regarding our use of your personal information. Those rights may include the following:

The right to access – EU residents have the right to make a request to us for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – EU residents have the right to request that we correct any information you believe is inaccurate. You also have the right to request our library to complete information you believe is incomplete.
The right to erasure – EU residents have the right to request that we erase your personal information, under certain conditions.
The right to restrict processing – EU residents have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – EU residents have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – EU residents have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us:

At our email: [Insert library email address]
By Telephone: [Insert library toll-free number]
Or write to us: [Insert library address]

Changes to this Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice and update the notice’s effective date. Your continued use of our Website or our library management software following the posting of changes constitutes your acceptance of such changes.

CCPA - Privacy Policy for California Residents

This Privacy Notice for California Residents supplements the information contained in our GENERAL PRIVACY NOTICE [Insert link to document/web page for General Privacy Notice] and applies solely to visitors, patrons, users and others who reside in the State of California (“patrons” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

The library management software we use helps us manage and operate our libraries. You will use this software when you look up materials in our library, check out books, ask for loans from other libraries, among other uses. Our library management software is operated and provided to us by a third-party company who will also have access to and use your personal information as set out in this Privacy Notice. References in this Privacy Notice to “we,” “us” and “our” refer to us (the library), to our library staff, to other libraries in our system, and to the company that provides us our library management software. Our library management software collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular patron or device (“personal information“). In particular, the software we use has collected the following categories of personal information from our patrons within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, birthdate, education, employment, employment history. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grade level, teacher’s name, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated patron information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, information that you provide to us or other libraries in our library system.
Indirectly from you. For example, information collected about you by us or other libraries in our system when you use our services or software.
If we acquire a company or a library joins our group that has access to your information, we may obtain your information from that company or library.
If you contact us directly, we will obtain information about you, and that you provide to us, during our contact with you.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

We collect your name, address, telephone numbers, and email address to help us and libraries in our system to identify you and to provide our services to you, and to maintain an account for you. We collect this information to keep track of the location of materials you may have borrowed. We collect this information about you so that we or libraries in our system can help you request or reserve materials or to engage in loans from other libraries. We also collect this information to help us communicate with you concerning these things.
We collect information about your library uses such as library materials you have checked out and returned, materials you have viewed, used or reserved through a library’s system, search terms you have used, and your reading interests, search terms and results to help us provide our services to you and to allow you to view the library materials you have used or searched for in the past. We will use this information to keep track of the location of materials, to determine the level of use of materials, and to assist us in making acquisition decisions for future library materials.
We may collect your photograph so that we can confirm the identity of persons using our services.
We may collect your electronic network activity information, such as your browsing history and your search history, so that we can assist you in accessing such information in the future if you desire.
We do not sell your information to others. However, if our library joins a new consortium, is acquired or sold, or the company that operates our library management software is acquired or sold to another person or company, they may obtain your information in connection such acquisition or sale.
We may use your information to provide, support, personalize, and to develop the library management software we use, and our other products, and services, and to respond to your inquiries.
We may use your information to help maintain the safety, security, and integrity of the software we use along with our other products and services, databases and other technology assets, and business.
We may use your information for testing, research, analysis, and product development, including to develop and improve the library management software, products, and services.
We may use your information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We may use your information as described to you when collecting your personal information or as otherwise set forth in the CCPA.
We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our software users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We prohibit selling of the personal data to any and all third parties.

We share your personal information with the following categories of third parties:

We may share your information with our library staff and other libraries in our system who use our software when you access the services they provide. However, we do not share your information with other libraries that use our software who aren’t in our library system unless you are a patron of those libraries or are requesting an interlibrary loan.
We may share your information with companies or other persons who provide services to us such as consultants and software developers who provide our library management software to us and that help us manage or develop our software, or to companies that provide software that help us provide services to you such as authentication services, collection services, and database services among other services and functions.
Our employees and consultants may have access to your information through the software we use and may access it to provide our services to you.
If we are acquired, the acquiring company or person will receive the information that we have about you.
If a governmental entity requests information from us, we may share your information with them.
If a person or company obtains information from us through legal process such as a subpoena or litigation discovery, we may share your information with them and the court system.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category E: Biometric information.

Category F: Internet or other similar network activity.

Category J: Non-public education information.

Category K: Inferences drawn from other personal information.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information to others.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
1. sales, identifying the personal information categories that each category of recipient purchased; and
2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers as applicable to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transactions or services for which we collected the personal information, take actions reasonably anticipated within the context of our ongoing business relationship, or otherwise provide our software services.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another patron to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at [Insert library toll-free phone number].
Visiting [Insert library website URL].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice and update the notice’s effective date. Your continued use of our Website or our library management software following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the General Privacy Notice, [Insert link to document/web page] your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: [Insert library toll-free number]

Website: [Insert library website URL]

Email: [Insert library email address]

Postal Address:

[Insert library name]

Attn: [Insert library contact name or department][Insert library physical address]

Effective Date of this Privacy Notice Version

This Privacy Notice version is effective as of September 1, 2019.