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Extracted from Consolidated Report
This investigation was originally published as part of a larger consolidated report containing multiple investigations. View the consolidated PDF for the complete document.
Santa Cruz County Grand Jury
• 2018-2019
2018-19 Consolidated Final Report with Responses 43 Patron Privacy at Santa Cruz Public Libraries Trust and
⚠️ Translation Notice: This content has been automatically translated. The original English text is the official version. Translation may contain errors.
⚠️ Este contenido ha sido traducido automáticamente. El texto original en inglés es la versión oficial. La traducción puede contener errores.
Findings and Recommendations 9 findings
F1
Page 55
The use of Gale Analytics on Demand by Santa Cruz Public Libraries was inconsistent with the Library’s long-standing policy on Confidentiality of Library Records (policy 303, adopted February 2006; revised November 2010) and companion document, “Information We Keep About You.”
Related Recommendations (1)
R1
Page 55
Santa Cruz Public Libraries (SCPL), in coordination with the Library Advisory Commission (LAC) and Library Joint Powers Authority (JPA) board, should revisit the Library’s revised privacy policy (adopted June 6, 2019) to specifically address the use of data analytics and other tools utilizing patron information. (F1–F4, F7)
F2
Page 55
The use of Gale Analytics on Demand, or any other data analytics tool, by Santa Cruz Public Libraries is not clearly addressed in the Library’s newly revised policy, Confidentiality of Library Records & Patron Data Privacy Policy (policy 303, adopted June 6, 2019).
Related Recommendations (1)
R1
Page 55
Santa Cruz Public Libraries (SCPL), in coordination with the Library Advisory Commission (LAC) and Library Joint Powers Authority (JPA) board, should revisit the Library’s revised privacy policy (adopted June 6, 2019) to specifically address the use of data analytics and other tools utilizing patron information. (F1–F4, F7)
F3
Page 55
Santa Cruz Public Libraries did not adequately inform its patrons about the Library’s use of Gale Analytics on Demand or obtain their consent for this use.
Related Recommendations (1)
R1
Page 55
Santa Cruz Public Libraries (SCPL), in coordination with the Library Advisory Commission (LAC) and Library Joint Powers Authority (JPA) board, should revisit the Library’s revised privacy policy (adopted June 6, 2019) to specifically address the use of data analytics and other tools utilizing patron information. (F1–F4, F7)
F4
Page 55
Santa Cruz Public Libraries used Gale Analytics on Demand without adequately considering the patron privacy aspects of current California law.
Related Recommendations (2)
R1
Page 55
Santa Cruz Public Libraries (SCPL), in coordination with the Library Advisory Commission (LAC) and Library Joint Powers Authority (JPA) board, should revisit the Library’s revised privacy policy (adopted June 6, 2019) to specifically address the use of data analytics and other tools utilizing patron information. (F1–F4, F7)
R3
Page 56
SCPL management and staff, in coordination with LAC and the JPA board, should stay abreast of changes to state law, especially as it concerns patron privacy and evolving technology, and update Library policies and practices in response to such changes. (F4)
F5
Page 55
Santa Cruz Public Libraries used Gale Analytics on Demand without examining the contract for this service, thus raising potential liability issues related to data ownership, data breaches, and patron privacy.
No recommendations for this finding
F6
Page 55
The contract is unclear and does not contain language that protects the interests of the Pacific Library Partnership, its member libraries, and their patrons.
No recommendations for this finding
F7
Page 55
The use of Gale Analytics on Demand by Santa Cruz Public Libraries is inconsistent with best practices in the library community regarding patron privacy.
Related Recommendations (1)
R1
Page 55
Santa Cruz Public Libraries (SCPL), in coordination with the Library Advisory Commission (LAC) and Library Joint Powers Authority (JPA) board, should revisit the Library’s revised privacy policy (adopted June 6, 2019) to specifically address the use of data analytics and other tools utilizing patron information. (F1–F4, F7)
F8
Page 55
Santa Cruz Public Libraries used Gale Analytics on Demand without adequately evaluating the effectiveness of the tool.
No recommendations for this finding
F9
Page 55
The use of Gale Analytics on Demand by Santa Cruz Public Libraries has created disagreement among Library staff concerning the traditional responsibility of libraries to protect patron privacy, the validity of data analytics as a planning tool, and potential security vulnerabilities of the system.
No recommendations for this finding
Additional Recommendations 6
These recommendations are not explicitly linked to specific findings.
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R2Page 55SCPL should implement a system for obtaining and managing patron consent for data analytics and other tools that use patron information. (F3) Published June 24, 2019 56 Santa Cruz County Civil Grand Jury
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R4Page 56SCPL should review the contracts for all third-party digital services used by the Library, including those provided by library consortia. (F5, F6)
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R5Page 56SCPL should adopt guidelines and practices suggested by the American Library Association with regard to patron privacy and data analytics services. (F7)
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R6Page 56SCPL should designate a data privacy officer and give this officer full authority and responsibility to implement and enforce the privacy policy, and to periodically report to the SCPL director, JPA board, LAC, and the public. (F7)
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R7Page 56SCPL should perform a meaningful evaluation of any tool that uses patron information to determine if the benefits outweigh the risks to patron privacy. (F8)
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R8Page 56SCPL should offer workshops for patrons to explain how the Library uses patron information and to explore related privacy issues. (F3, F4)