Sno-Isle Libraries Board Policy

Purpose

The purpose of this policy is to communicate Sno-Isle Libraries' (the Library) commitment, role, and responsibility to safeguard customer data and to describe the obligations and constraints under which the Library operates.

Scope

The Library is committed to protecting the privacy of its customers and restricts access to information used in the normal course of business. In accordance with RCW 42.56.210 and 42.56.310, it is the policy of the Library that "Any library record, the primary purpose of which is to maintain control of library materials, or to gain access to information, that discloses or could be used to disclose the identity of a library user is exempt from disclosure under this chapter."

These records are considered confidential and protected by the right of privacy established by the Constitution of the United States and the Constitution and laws of the State of Washington.

Definition
For the purpose of this policy, such confidential records include but are not limited to: registration records, circulation records, customer requests for information, materials request lists, database search and download records via third party vendors, meeting room reservations, and wireless access and computer use records.

Networked and Digitized Library Environment
The Library provides access to the Internet via its wireless network and by making computers and other devices available to customers. The Library does not monitor what customers do while using the Library's computers or other devices. It does not scrutinize sites customers visit, documents they produce, transactions they make, or emails they create or view.

Customer library card numbers, and the location and time of customer logins are collected to manage the queues for using library computers. For wireless connections, the date and time of a wireless connection and the MAC address of the device that is connected through the wireless network is retained. The USA PATRIOT Act requires that this data be retained for a reasonable period of time. It is currently retained for one year.

The Library's collection is also part of the networked, digitized library environment. Customers may borrow library materials by accessing and downloading them via third party vendors. The Library actively works with third party vendors to support customer data privacy.

Implementation

Information from confidential records shall not be made available to any individual, organization, entity, or any agency of federal, state, or local government except as follows:

• Customers may access data that is about themselves.
• Community Libraries may release reserved materials to a family member or other person who, with the customer's permission, is picking up the material on behalf of the customer.
• Pursuant to a valid court order, or other applicable legal authority, under applicable state or federal law.

The library does not give, share, sell, or transfer customer data for commercial purposes.

Customer information may be used for research purposes, customer notifications, and other efforts which enhance library services to meet community and customer needs.

Names and addresses, only, of adult customers eighteen (18) years of age and older, who have opted in to receive notifications by the Sno-Isle Libraries Foundation, may be shared with the Sno-Isle Libraries Foundation for the sole purpose of notifying users of upcoming events in support of the Library and / or to invite customers to participate in or to financially support Sno-Isle Libraries Foundation activities.

Associated Policies and Laws

• United States. Children's Online Privacy Protection Act.
• United States. Electronic Communications Privacy Act.
• United States. USA PATRIOT Act.
• Washington State RCW 42.56.210. Certain personal and other records exempt.
• Washington State RCW 42.56.230. Personal Information.
• Washington State RCW 42.56.310. Library records.

Process
This policy is reviewed every four (4) years by the Executive Director (or designee) who makes recommendations to the appropriate Board Committee. The Committee reviews and revises as necessary, endorses, and advances to the full Board for approval.

Policy History

Date approved: July 27, 2020
Next review Date: 2024
Date adopted: August 1994