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* blank personal disclosure form added * adding ncip details * returns personal info (adding transmits)
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## Overview | ||
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The purpose of this form is to disclose the types of personal data[^1] (PD) stored by each module. This information enables those hosting FOLIO to better manage and comply with various privacy laws and restrictions, e.g. GDPR. | ||
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It's important to note that PD is not limited to that which can be used to identify a person on it's own (e.g. Social security number), but also data used in conjunction with other data to identify a person (e.g. date of birth + city + gender, or dynamic IP address + date + time), and any information about such a person (e.g. has loaned 5 items, 2 of which are overdue). | ||
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For the purposes of this form, "store" includes the following: | ||
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* Persisting to storage - Either internal (e.g. Postgres) or external (e.g. S3, etc.) to FOLIO | ||
* Caching - In-memory, etc. | ||
* Logging | ||
* Sending to an external piece of infrastructure such as a queue (e.g. Kafka), database (e.g. Elasticsearch, Library Data Platform), distributed table, etc. | ||
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## Personal Data processed by this Module | ||
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- [ ] This module does not store any PD. | ||
- [ ] This module does not process any PD. | ||
- [ ] This module provides [custom fields](https://github.com/folio-org/folio-custom-fields). | ||
- [ ] This module stores fields with free-form text (tags, notes, descriptions, etc.) | ||
- [ ] This module caches PD | ||
- [x] This module logs PD | ||
- [ ] Log level ERROR includes PD | ||
- [ ] Log level WARNING includes PD | ||
- [ ] Log level INFO includes PD | ||
- [ ] Log level DEBUG includes PD | ||
- [x] This module transmits PD (including queues, additional databases, etc.) | ||
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--- | ||
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### Identifiable information | ||
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- [ ] Passport number / National identification numbers | ||
- [ ] Driver’s license number | ||
- [ ] Social security number | ||
- [ ] Financial account information | ||
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### Identifiable information if linked | ||
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Information can be combined with others to form a person’s identity. | ||
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- [x] First name | ||
- [x] Last name | ||
- [ ] Gender | ||
- [ ] Date of birth | ||
- [ ] Place of birth | ||
- [ ] Racial or ethnic origin | ||
- [x] Address | ||
- [ ] Location information | ||
- [ ] Geolocation data | ||
- [x] Phone number(s) | ||
- [ ] Pseudonym / Alias / Nickname | ||
- [x] Username / User Identifier (UUID) | ||
- [x] Email address | ||
- [ ] Financial information / Fees or Fines | ||
- [x] Circulation transaction(s) | ||
- [ ] Web cookies | ||
- [ ] IP address / MAC address | ||
- [ ] Photographs of users (profile picture) | ||
- [x] Other PD | ||
* User status (blocked or okay) | ||
* Patron group | ||
* Patron service point preference | ||
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**NOTE** This is not intended to be a comprehensive list, but instead provide a starting point for module developers/maintainers to use. | ||
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## Privacy Laws, Regulations, and Policies | ||
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Numerous laws and policies were considered when creating the list of personal data fields above. For additional information, please refer to the following: | ||
* [General Data Protection Regulation (GDPR)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02016R0679-20160504) | ||
* [What are identifiers and related factors? (ico.org.uk)](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/what-is-personal-data/what-are-identifiers-and-related-factors/) | ||
* [What is the meaning of 'relates to'? (ico.org.uk)](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/what-is-personal-data/what-is-the-meaning-of-relates-to/) | ||
* [Opinion 4/2007 on the concept of personal data (Article 29 working party)](https://ec.europa.eu/justice/article-29/documentation/opinion-recommendation/files/2007/wp136_en.pdf) | ||
* [California Consumer Privacy Act (CCPA)](https://oag.ca.gov/privacy/ccpa) | ||
* [U.S. Department of Labor: Guidance on the Protection of Personal Identifiable Information](https://www.dol.gov/general/ppii) | ||
* Cybersecurity Law of the People's Republic of China | ||
* https://www.newamerica.org/cybersecurity-initiative/digichina/blog/translation-cybersecurity-law-peoples-republic-china/ | ||
* http://en.east-concord.com/zygd/Article/20203/ArticleContent_1690.html | ||
* [Personal Data Protection Bill, 2019 (India)](https://www.prsindia.org/billtrack/personal-data-protection-bill-2019) | ||
* [Data protection act 2018 (UK)](https://www.legislation.gov.uk/ukpga/2018/12/section/3/enacted) | ||
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[^1]: Personal data is "any information relating to an identified or identifiable natural person". [GDPR Article 4](https://web.archive.org/web/20220308161519/https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679#d1e1374-1-1) | ||
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v1.1 |