A vast majority of the analyzed policies provide some rationale as to why the library collects data and how it is used. Some policies provide broad umbrella statements, conceivably covering a whole range of systems, data, and transactions. Others include such statements but also provide further detail on one or more particular systems, transactions, or data types. ALA’s “Library Privacy Checklist—Overview” notes that library policies should “specify that the library is not collecting more user information than what it needs” and should “[include] information about what information the library is tracking, why, and for how long the data is kept.”1 ALA’s Resolution on the Retention of Library Usage Records notes that because “library usage records containing personally identifiable information (PII) are maintained for the sole purpose of effectively managing library resources,” libraries should “limit the degree to which personally identifiable information is collected, monitored, disclosed, and distributed” and “avoid creating unnecessary records.”2
As noted in many policies, libraries collect data in association with the library fulfilling its core business and administrative responsibilities of providing access to library resources and services. This chapter provides policy statement examples for both levels of detail—broad and overarching statements, and granular and specific statements. To begin, many library policies incorporate some level of overarching phrasing (some examples of which are provided in the ALA Privacy Tool Kit). For example, Rutgers University Libraries’ policy notes,
The Rutgers University Libraries gather information about current and valid library users for the sole purpose of providing library services. Where it is necessary for the Libraries to identify users, it is our goal to gather only the minimum information necessary and to retain that information for only as long as it is needed to complete a particular transaction. We avoid creating unnecessary records and retaining records not needed for the fulfillment of the mission of the Libraries. Furthermore, we do not engage in practices that might place personally identifiable information in or on public view.3
Additional broad, high-level statements noting data collection associated with fulfilling library operational requirements are provided below (and in some of the instances below, the library’s policy later provides greater detail on one or more data types):
We do not collect information about patron activities . . . beyond what is basic and necessary to conduct and fulfill the mission of the library.4
To aid understanding of the use or value of resources and services, the Kennedy Library may aggregate and retain user data for a reasonable period of time. It will, however, neither collect nor retain information identifying individuals except for the purpose of furnishing a specific service.5
The Libraries collect information about visitors and visits for statistical purposes, to administer access to Library materials and services, and to inform users of Library services and programs.6
For certain defined business purposes the University Libraries do collect PII which data are individually or collectively sensitive or confidential according to current Temple University data classification. Both sensitive information and confidential information are held in strict confidence and exchanged among library staff or other University staff only in relation to the business purpose. . . .
PII collected is made accessible only to those specific individual staff who need access to the information in order to conduct library business or who will be compiling and anonymizing data for statistical or assessment purposes.7
In order to conduct Library business, the Library collects and maintains personally identifiable information about library users. . . .
Identifiable information may be retained, in some cases indefinitely, when doing so serves an institutional purpose.8
The University of Michigan Library may collect some data about your library use in order to improve services and to integrate with broader University teaching and learning initiatives.
. . .
When you use library applications, systems, and websites, you generate data. We use and store these data to provide and improve services and resources.9
The Libraries provide a vast array of services. Many services do not require users to divulge any information to Libraries staff or systems. Other services, however, require users to provide some information in order to receive or benefit from the service.10
All library records that identify patrons by name are strictly confidential, and access to them is limited to staff for legitimate library business.11
The Jessamine County Public Library acts to limit the amount of personally identifiable information it retains. Some information, however, is necessarily and understandably retained for the transaction of day-to-day business.
Most information related to customers is kept for the purposes of circulating materials and ensuring that responsibility is attributed to the correct person when an item is borrowed.12
Staff should create records with patron-identifiable information only as reasonably necessary for the Library’s operations.
Staff should consult records with patron-identifiable information only for legitimate purposes related to the Library’s operations.13
Information and usage records with personally identifiable customer information are maintained for the purpose of effectively managing library resources and providing library services.14
Several policies reference or directly quote state law, which in some instances itself directly speaks to the purpose and use of some data collected by a library within that state. For example, Princeton University Library’s policy notes, “As required under New Jersey law (N.J. Stat. § 18AG73-43.1 – 43.2), Princeton University Library records relating to an individual patron’s use of the Library and its resources shall be treated as confidential,” and then quotes the relative New Jersey statute section passage that speaks to how library records can be “necessary for the proper operation of the library.”15 Deer Park Public Library’s policy quotes New York Civil Practice Law and Rules, Section 4509, which also references how records can be used “for the proper operation” of the library: “Library records, which contain names or other personally identifying details regarding the users . . . may be disclosed to the extent necessary for the proper operation of such Library.”16
Geauga County Public Library references Ohio Revised Code Section 149.432, which notes that a library record includes
a) Information that the library requires an individual to provide in order to be eligible to use library services or borrow materials;
b) Information that identifies an individual as having requested or obtained specific materials or materials on a particular subject;
c) Information that is provided by an individual to assist library staff answer a specific question or provide information on a particular subject.17
Las Vegas–Clark County Library District’s policy references Nevada Revised Statutes NRS 239: “In accordance with NRS 239, the District will not retain any records pertaining to a patron’s use of library resources longer than necessary to provide appropriate stewardship of those resources.”18
Moving to examples of policy statements providing more detail on how particular data may be used, Duke University Libraries’ policy concludes with a section titled “Examples of How the Libraries Use Data to Improve Services.” This section provides details and accompanying data graphs that help illustrate how library staff utilize textbook circulation data, interlibrary loan request data, physical space swipe entrance data, Google Analytics data, and data analyzed from their EZproxy proxy server logs.19 The rest of this chapter will share policy statement examples regarding the following types of data and how and why such data is collected and in the process will surface a rich variety of policy phrasing, nuance, and focus:
Web server logs, their associated analysis through analytics programs such as Google Analytics, and other data related to the library website represented the single most mentioned data or record type with an associated reason provided for such collection. Some level of detail appeared in at least twenty-two of the academic library policies and a dozen public library policies. Phrasing can vary significantly, but many focus on common threads of collecting and using such data to assist with troubleshooting issues, to better understand and meet the needs of users (e.g., improving the website), and for statistical purposes.
The information that is collected automatically is used to improve this Web site’s content and to help the University Libraries understand how users are interacting with its Web site. This information is collected for statistical analysis and to determine what information is of most and least interest to our users.20
Web site developers and owners review usage data on their web pages to identify resources that are being used and to evaluate the provision of information on the site and the effectiveness of the organization and design of that information.21
The Libraries use this information to track site usage, monitor site performance, and generate aggregate statistics.22
The Library may record aggregated data (stripped of identifying characteristics) on website and resource usage in order to improve website usability and collection relevance.23
The UM Librariesʼ web servers may also use browser “cookies” or other technologies to maintain session and preference information and to provide other complex functionality. The Library will use cookies to capture IP addresses for collecting data on web usage.24
This automatically collected information is only used internally for technical troubleshooting, to monitor compliance with the Library’s Policy on Acceptable Use of Electronic Resources, to improve the usability of our website, and to record aggregate statistics.25
For site administration functions, information, other than personal information linked to a particular individual, is collected for analysis and statistical purposes of Web site navigation. This information is used to help diagnose problems, assess what information on the sites is of most interest, determine technical design specifications, identify system performance and/or problem areas, and other administration functions.
. . .
Our use of tracking technologies allows us to analyze trends and statistics to improve our Web site and your Web experience.26
In the course of providing you with Web-based services, The Library collects and stores certain information automatically through our Web site. We use this information on an aggregate basis to maintain, enhance or add functionality to our Web-based services.27
The U-M Library also uses Google Analytics (including the use of demographics and interest reports), a web analytics service provided by Google, Inc. (“Google”) to help understand how U-M Library websites are being used and to improve our interface and services. . . .
The U-M Library uses this information for analytical and feature-improvement related purposes only.28
We routinely collect information from website usage to help us improve functionality, navigation, and performance.29
When users visit our website, we may automatically collect certain information. . . . This is standard practice for websites, and is not used for any purpose other than to evaluate how we can design the site to best serve user needs.30
We use non-identifying and aggregate information to better design our services. For example, we may let it be known publicly that a specific number of individuals visited a certain area on our website, but we would not disclose anything that could be used to identify those individuals.31
This information is collected for statistical analysis using third-party or proprietary software programs to create summary statistics. The statistics are used for the purpose of determining what information is of most and least interest to all visitors and for identifying system performance issues or problem areas in order to better plan future portal enhancements.32
The Berkshire Athenaeum will collect and store only the information necessary to measure the number and timing of visitors to different areas of the Athenaeum’s website to assist in making these sites more useful.33
Statistical Information: This information is used by the Lower Macungie Library for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of Lower Macungie Library web sites.34
We use your IP address to help diagnose problems with our server, and to administer and create generalized statistics on our Web site. We may also use an IP address to block abusive users of public forums.35
The library and its third party vendors do keep track of how users navigate our web sites: which pages are most frequently used, popular search paths, domains of users (to find out where our users are visiting from), and other information that helps us make adjustments and improve our service. This information is not shared, and is used by us for general and not individual statistics.36
Log Files
When a user visits our website, his/her IP address is recorded. We use this information to analyze trends, administer the site, determine popularity of content, and gather broad demographic information for aggregate use.37
Statistical Information: Phoenix Public Library collects information to maintain the quality of its services and to report aggregate information on the usage of its website to City management, as well as state and federal agencies and national library organizations.38
The Library uses this information to help the Library make our site more useful to visitors and to learn about the number of visitors to our site and the types of technology our visitors use.39
Many library policies note the use of cookies and provide brief definitions of what a cookie is. Cookies can be used by website analytics programs, but for other purposes as well, as shown below:
This Site uses cookies for two main purposes: (a) to carry information about your current session at this Site from one web page to the next, which also allows you to automatically login to other Michigan State University websites, and (b) to identify you on this Site on return visits.40
Users of networked computers will need to enable cookies in order to access a number of resources available through the Libraries. . . . Cookies are often used to remember information about preferences and pages visited. . . . Our library servers use cookies solely to verify that a person is an authorized user in order to allow access to licensed library resources.41
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. . . . When you return to the same Josephine Louise Public Library—Walden, New York Web site, the information you previously provided can be retrieved, so you can easily use the Josephine Louise Public Library—Walden, New York features that you customized.42
Examples in which the Library might use cookies would be to customize content areas; to analyze site activity or user behavior; or to maintain the state of authentication for member privileged pages during a given session.43
Los Angeles Public Library’s Online Privacy Policy provides extensive detail on the types of information collected when a user visits the library’s website. Notably, it also states,
How we use information collected on lapl.org for digital advertising of library services
We utilize third-party tools for outreach
Our team and affiliates use third-party web services to conduct outreach and education through the use of digital advertising for the Los Angeles Public Library initiatives.44
It then proceeds to provide definitions for, and details on, the library’s utilization of Google Adwords, Facebook Ads, Google Analytics, Hotjar cookies, web beacons, session cookies, persistent cookies, click tracking, conversion tracking, retargeting, and targeted advertising. It notes why the library uses these technologies as well as methods to opt out of data collection.
A few library policies make references to data collection and use focused on assessing electronic resource usage, such as licensed library databases:
Collection and analysis of data on usage of the licensed commercial online databases and materials offered by the Libraries through its system assists both the publisher and the University Libraries to understand the impact of this technology and service.45
Harvard does gather data about system and resource usage for administrative purposes. . . .
The resulting logs contain information necessary for analyzing the use of resources, troubleshooting problems and improving services.
Log data is also used to distribute resource costs among Harvard libraries and faculties.46
The Libraries may use information that they collect about online database use for internal business purposes and to improve the Libraries’ services.47
We may use these logs to troubleshoot authentication errors or prevent and/or stop security breaches when they occur. We may also anonymize and analyze these logs in order to assess our collections and their use.48
Several policies discuss collection and use of data associated with e-mail and web forms. Examples include the following:
We use e-mail addresses to respond to the e-mail we receive, to send library notices, to confirm online program registrations, and occasionally to alert customers to new services they may want to use. Mailing addresses may be used to send library-related notices. Such addresses are not used for any other purpose and are not shared with outside parties.49
Your e-mail address and the information included in your message will be used to respond to you, to address issues you identify, to improve this Web site, or to forward your message to another SUNY campus for appropriate action.50
If you choose to submit personally identifiable information to the Library (through web forms, email messages, or other communication), that information will be used only for the purpose for which you submitted it, with the exception that the Library may make reasonable statistical reports that do not identify particular individuals.51
We may collect e-mail addresses and other contact information, in order to provide and improve our services.
. . .
If you fill out an electronic form on our site, such as those for reporting a problem, reserving study rooms, requesting a consultation, asking a question, etc., we keep these data in order to trouble-shoot, improve services, and/or to keep statistics on our work.52
The Library may use personally identifiable information to contact you for promotional purposes. For example, on occasion the Library may wish to send e-mails to inform you of new exhibitions or other events the Library deems may be of interest. You will not receive such communications unless you have willingly provided your personal contact information.53
Personally identifying information that you provide by e-mails or web forms will be used only for such purposes as are described at the point of collection (for example on a web form), such as to send information or provide library services to you, update your membership record, or to respond to your questions or comments.
If you provide contact information, the Library may contact you to clarify your comment or question, or to learn about your level of customer satisfaction with library services.54
Any personal information given in email messages, chat sessions, web forms, in-person or telephone reference, or other communications is only used for the purpose for which you submitted it.55
As evidenced above, some policies specifically note how e-mail can be used for reference services. Several library policies provide further details related to virtual reference services (such as chat transcripts), and some libraries have dedicated virtual reference service policies, such as Texas State University Libraries.
The Libraries collect and store personal information that you submit via the Libraries’ web-based management tools, such as forms related to asking reference questions or booking reservable study rooms. We also interact with our library users regularly and receive personal information via email messages, chat sessions, web forms, and other communications. If you submit personal information via one of these platforms, we use your personal information only for the purpose for which you submitted it.56
We access these transcripts to evaluate the quality of our service and for statistical purposes.57
These transcripts are restricted for the purposes of internal training, statistical reporting, and may at times be repurposed, once stripped of any identifying information. . . .
The transcripts are analyzed for the amount and types of questions we are being asked. This helps determine appropriate staffing levels and aids in training librarians to staff the reference service. Frequently asked questions may at times be mined and repurposed in order to populate the FAQ knowledge-base, but no identifying information is made public.58
The Libraries may use information they collect during reference transactions for internal business purposes and to improve the Libraries’ services.60
Several policies discuss data collected through surveys, oftentimes associated with user assessment activities.
Libraries Research Initiatives: In order to improve their service to the community, the Libraries occasionally may conduct survey studies, issue questionnaires, or perform other data gathering activities. During these initiatives, the Libraries may ask visitors to provide Individual Information or University Information. In these circumstances, the Libraries consider this information optional; the visitor or user can choose whether or not to provide this information. Further, a visitor’s decision to withhold Individual Information or University Information from a Libraries employee who is conducting a research initiative will not harm, diminish, or otherwise affect the level of service that visitor receives from the Libraries.61
Library Surveys and Assessments
Periodically, The University of North Carolina at Chapel Hill Libraries conduct library surveys and assessments. Information and data obtained through electronic, group or individual surveys are considered confidential and will adhere to Institutional Review Board policies, as appropriate, unless otherwise publicly stated in the collection process or permission is explicitly obtained from the respondent(s).
Periodically, the libraries review and use demographic and similar aggregated data for reports, both internal and external. This use does not identify individuals.62
Any information the library user chooses to provide, such as information gathered through voluntary library user surveys, will be used only to provide or improve library services.63
Josephine Louise Public Library—Walden, New York may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.64
Survey information is used for purposes of monitoring or improving the satisfaction of LML patrons.65
Patron identification data (e.g., name, address, etc.) and collecting this information to establish a patron record allowing the circulation of materials and the providing of other services is frequently mentioned in policies.
The Libraries maintain personally identifiable information in library users’ online accounts. . . . We use this information to maintain your library account and to provide services to you.66
If you wish to receive borrowing privileges, we must obtain certain information about you in order to provide you with a library account.67
We will use the personally identifiable information only to maintain your library account and respond to your requests.68
The Libraries require all users to provide University Information in order to borrow materials from the Libraries, including books and laptop computers.
The Libraries may use circulation information they collect for internal business purposes and to improve Libraries services.69
The library maintains a confidential database of its users which includes information for personal identification, as well as any library items currently checked out to that borrower. . . . Collection and maintenance of this information is necessary so that the library can account for Borough property.70
Circulation records and other records identifying the names of library users with specific materials are retained while the materials are charged to a patron and when materials are returned until of no further administrative value.71
In order to provide borrowing privileges, the District must obtain certain information about its patrons.72
Interlibrary loan and document delivery services data are also mentioned in several policies.
Interlibrary Loan lending and borrowing records have been retained since at least 2001. They are used in case there are billing problems and to comply with the record keeping requirements suggested by the CONTU (National Commission on New Technological Uses of Copyright Works) guidelines. . . . In some cases, information about requests (including the name of the requestor) is shared within the library staff for collection development purposes, but staff are instructed not to further disseminate such information.73
The Library also collects information in conjunction with Library Express, Interlibrary Loan, or San Diego Circuit patron requests submitted via Roger or Melvyl, to allow us to complete the requested service transaction for you.74
User IDs and passwords associated with providing access to databases or logging on to a computer are mentioned in several policies.
Use of the full resources of the World Wide Web and of the full power of some subscription databases requires that a user log on to the workstation.75
All SDSU affiliated patrons will be required to sign onto internet access terminals using their SDSUid. This is necessary to identify SDSU affiliates from community users and is done solely to be in compliance with legal contracts.76
When using library services through our website, you may need to provide your name, e-mail address, NetID, password, barcode, and/or password. To use licensed subscription electronic resources from an off-campus location, users are required to submit a NetID and password or library barcode and password to be authenticated as a currently affiliated user.77
In order to use the Internet stations at an AADL branch, a user must provide his/her name and address and show valid identification. This information is only used in the event that the user breaks one of the AADL rules of behavior during his/her session.78
Several public library policies note how the libraries may use social media data.
By accessing NPLʼs blog and social media sites, as well as interacting with content there . . .
What You Should Know.
The Library Owns the Content.
What This Means: NPL can use content without limits.79
The Berkshire Athenaeum shall also be granted the right to reproduce comments, posts, and messages in other public venues. For example, a response to a YouTube book review may be quoted in a newspaper or on the library website.80
Many social media sites allow users of those sites to become a “friend,” “fan” or otherwise associate their own “profiles” or virtual presences with the library’s profile on these sites. The library does not collect, maintain, or otherwise use the personal information stored on any third party site in any way other than to communicate with users on the site.81
Several policies include specific references to donor-related data.
Donating to the Library
When a donation is given to AADL, we will record the donor’s name, address and type and amount of gift to comply with AADL auditing procedures and to issue the donor a receipt for tax purposes.82
Donor lists may be used by Genesee District Library for ongoing communication and the solicitation of future gifts, in accordance with Michigan Law, unless the donor has stipulated otherwise.83
Footage captured by video surveillance systems is frequently mentioned in policies, and several libraries have separate, individual policies focused on video surveillance.
The Library uses surveillance cameras in some of its facilities to complement other measures to ensure a safe and secure environment for customers and staff. The equipment helps to protect the libraryʼs property against theft or vandalism and can assist in identifying intruders and persons breaking the law or violating the libraryʼs Rules of Conduct.84
The Library will use digital video to enhance the safety and security of Library customers, staff, and property, while protecting individuals’ right to privacy. The primary use of security cameras is to discourage inappropriate and illegal behavior and to improve the opportunity to apprehend offenders.85
Security cameras are in use to discourage illegal behavior and violations of library policies, and to provide recorded footage to assist law enforcement in prosecuting criminal activity and staff in enforcing library policies.86
The University of Oregon Libraries (UO Libraries) values academic freedom and personal privacy, and employs security cameras only to the extent required to assist in protecting library resources and providing safety for library users.
. . .
Security cameras may be placed strategically in and around the UO Libraries to meet the specific needs of library departments and to assist the UO Police Department (UOPD) in its efforts to deter crime; protect library staff and patrons; protect facilities, collections and equipment; assist with emergency response situations; and investigate suspected criminal behavior.87
Some campus libraries have security cameras installed to improve safety for patrons and staff and to help prevent theft and vandalism. These recordings are used by library staff and law enforcement officials investigating incidents that occur in the libraries.88
Distinct from video surveillance footage, several public library policies reference promotional use of photos and videos.
Photos and videos from general library scenes, public programs and events held in Library facilities and spaces may be used on the Library’s website and/or in social media and publications.89
The Library may utilize photos and videos from public programs and events at Library facilities and Library spaces on its website and in Library publications. Photos, images, and videos submitted to the Library by users for online galleries or contests may also be used by the Library for promotional purposes.90
Several policies address other miscellaneous types of data collected and how such data is used.
We collect data regarding how many people enter/exit the building and peoples’ usage of space during library operating hours. These data are anonymized. They are used to improve the design of physical space within the building.91
Board Meetings
In order to make a citizen’s comment at an AADL Board Meeting, a citizen will be asked to present his/her name and address. The information given will not be used in any other way.92