Privacy Tool Kit
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III. PRIVACY PROCEDURES
| Responsibilities of Governing Bodies/Policy Makers | Responsibilities of Administrators | Responsibilities of Supervisors | Staff Responsibilities |
Responsibilities of Governing Bodies/Policy Makers
- Keep informed about issues relating to library patron and user privacy and confidentiality
- Be aware of applicable federal, state and local laws and regulations
- Adopt appropriate policies
- Provide the library administration with sufficient resources to develop procedures and provide staff training in support of policies
- Understand and respect the library's organization and administrative hierarchy
- Understand the library's plan for routine and crisis communication
- Be knowledgeable about techniques for dealing with the media
- Be aware of the library's relationship to governmental agencies and officials (elected and appointed) and to other organizations
Responsibilities of Administrators
- Keep informed about issues relating to library patron and user privacy and confidentiality
- Be aware of applicable federal, state and local laws and regulations
- Inform and educate policy makers about relevant professional, ethical and legal issues
- Recommend privacy and confidentiality policies to policy makers:
- Ensure that knowledgeable legal counsel is consulted
- Include ALA and other relevant documents, laws and regulations;
- Make sure that all contracts with ILS (integrated library system) and other vendors are consistent and compliant with the library's policies
- Conduct privacy audits
- Review and evaluate current practices and procedures
- Develop guidelines and procedures in support of policies:
- Define patron privacy and confidentiality
- Include relevant library policies
- Identify the type and nature of all records and files that contain library patron and user personally identifiable information
- Establish a schedule for the retention of records and files containing library patron and user personally identifiable information
- Create a chart of the library's organizational hierarchy, indicating:
- Chain of command
- Staff members authorized to respond to requests for patron or user personally identifiable information
- Define and describe the type and nature of requests for personally identifiable information:
- Informal
- Define the circumstances under which, the manner of and extent to which, patron and user personally identifiable information may be disclosed in person, over the phone or electronically
- Law enforcement
- Detail the specific steps staff should follow in responding to investigatory requests for patron and user personally identifiable information from:
- Local and state agencies
- Federal agencies
- Detail the specific steps staff should follow in responding to investigatory requests for patron and user personally identifiable information from:
- Informal
- Write a ready-reference card with a clear and concise description of the library's privacy policies
- Make available in all departments and public service areas
- Be authorized to accept and comply with all investigatory requests
- Designate a library staff member to serve as the Library Privacy Officer who will:
- Keep abreast of news and information about privacy issues
- Train all library staff on privacy and confidentiality issues, polices and procedures:
- Specify what, how, when and which staff may respond to public, media or law enforcement requests for library patron and user personally identifiable information
- Examine staff practices and procedures on a regular basis for compliance with policies
- Evaluate training methods and effectiveness
- Develop a routine and crisis communication plan:
- Prepare an organizational chart/hierarchy of whom staff should contact
- Maintain current contact information
- Designate a library spokesperson
- Provide media training for policy-makers and key staff
- Educate the public about issues of library privacy and confidentiality and the library's policies, practices and procedures to protect library patron and user personally identifiable information
- Maintain contact with local, regional and national affinity organizations
- Forge alliances with community groups
Responsibilities of Supervisors
- Reinforce training to ensure that all staff have a basic understanding of the library's policies, practices and procedures
- Monitor staff for compliance with library practices and procedures in their daily activities
- Report flaws or failures of training or procedures to the Privacy Officer
- Be prepared to discuss privacy and confidentiality policies, practices and procedures with library patrons and users
Staff Responsibilities
- Understand and follow library practices and procedures:
- Apply equally to all library patrons and users regardless of age, origin, background or views
- Maintain privacy and confidentiality when assisting library patrons and users
- Discuss matters of library patron and user personally identifiable information with other staff only when necessary for operational purposes:
- Conduct discussions in non-public areas
- Refrain from discussing matters of library patron and user personally identifiable information with friends, family or members of the public
- Refer requests by the public, the media or law enforcement for access to, or view of, non-public computers, files or records to a library administrator
- Direct all requests from law enforcement or government officials for library patron and user personally identifiable information to a library administrator
- Keep confidential the source of any request or the nature of the information requested with staff, family, friends or members of the public
Introduction revised March 5, 2004