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December 15, 2017
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Library Board Policies - Confidentiality and Retention of Patron Information

 

Confidentiality of Patron Information

It is the policy of the Halton Hills Public Library Board to maintain the privacy of the patrons of its services and to consider any library records containing information leading to the identification of an individual patron to be confidential in nature.  The Chief Librarian serves as the Privacy Officer for the Halton Hills Public Library.

The library collects information solely for the purpose of managing library operations.  The purpose for collection is conveyed to the public on the patron registration form, as follows:

Personal information on this form is collected under the authority of the Public Libraries Act, R.S.O. 1990, c. P 44; S. 23 S.S.4 (f) and is subject to the provisions of the Municipal Freedom of Information and Protection of Privacy Act.  This information is used for the administration of the library program including the lending and retrieval of material, the collection of fines and fees, service planning and development.  Questions about this collection should be forwarded to the Chief Librarian, 9 Church St., Georgetown L7G 2A3 (905) 873-2681.

The Board will adhere to the provisions of the provincial “Municipal Freedom of Information and Protection of Privacy Act”, R.S.O., 1990.  Library records of patrons are for the sole purpose of protecting public property.  Access to these records is limited to:

·         library employees for service delivery and planning purposes; and

·         the individual to whom the information relates, or if the individual is less than sixteen years of age, to the parent/guardian.

The individual will be requested to provide proof of identity before any information from his/her patron file will be released.

Under no circumstances shall library staff provide information from a patron’s record to a third party.  No library records containing personal information shall be made available to members of the public, press, or any agency of government except under due process of law.

The Board and staff shall resist the issuance of enforcement of any such process until such time as a proper showing of good cause has been made in accordance with Section 32 of the “Municipal Freedom of Information and Protection of Privacy Act”, R.S.O., 1990.  Such exceptions include “disclosure to an institution or a law enforcement agency in Canada to aid in an investigation with a view to a law enforcement proceeding or from which a law enforcement proceeding is likely to result”.  It also includes compassionate circumstances which would “facilitate contact with the spouse, a close relative or a friend of an individual who is injured, ill or deceased”.  All requests for the disclosure of personal information shall be made in writing to the Chief Librarian.  The Chief Librarian will determine the appropriateness of the request, and may bring the request to the attention of the Library Board, and/or require a court order or subpoena from a competent jurisdiction.  Moreover, any costs incurred by the library in the provision of required information, even under court order, shall be chargeable to the agency or individual demanding such information.

Exceptions

·         If patrons do not return items on time, or owe the library money, the Halton Hills Public Library reserves the right to provide such information to other libraries, a collection agency or to take legal action if warranted.

·         If the library provides an enhanced service or program through a third party, that company must inform the patron of their privacy policy. The third party must receive consent from the patron.

Retention of Patron Information

Information respecting library patrons will be retained according to the schedules described below.  Retention periods depend on whether a patron record has the status of “active” or “inactive”

Active Patrons:

Patrons who have used their Halton Hills Public Library card in the last two years will be considered active.  Any information such as fines/fees paid or waived and lost items returned will be deleted from the active patron’s history file after seven years; other basic contact information such as the patron’s address, phone number and email will be retained.

Inactive Patrons:

Patrons who have not used their Halton Hills Public Library card in two years will be deemed to be inactive, and their records will be purged electronically from the database following three years of inactivity if there are no blocks attached, e.g.,  fines, charges, lost items.  Inactive cards with blocks will be retained for seven years.  After seven years, records will be electronically purged from the database regardless of unresolved blocks.

Patron Data:

For the purposes of following up on lost items or on damages after an item has been checked in, staff can determine the last borrower until the next check in or for 180 days if the item has not been borrowed.

A patron has access to his/her borrowing record which includes his/her contact information, items currently borrowed, items reserved, reserved items awaiting pick-up, items overdue and lost, and outstanding fines/fees.  A patron does not have access to a full history of items borrowed and checked in, unless s/he has agreed to the storage of borrowing history, subject to the retention policies of a third party (e.g., Innovative Interfaces).

Data on a patron’s reserves is kept until the reserve is fulfilled, cancelled by the patron, or until the reserve has expired (one year, but may be extended on request).

Revised/Approved: September 13, 2017

Revised/Approved:  February 11, 2015

Next Scheduled Review: January 2022