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iSchools Inc

Data Management and Data Protection Policy (Draft)

27. August 2019

Policy

1.  Who is responsible for personal data collected by the iSchools?

The Executive Director, the Executive Committee, and the core team have primary responsibility for collecting, storing, and using these data.

Insofar as personal information about members (names, photos) may appear in communications or on the website and social media presence, the Executive Director has primary responsibility to ensure the appropriate use of this information. The Executive Committee sets policies for the use, and the core team carries out the policies.

2.  What personal information do the iSchools collect and how does this information serve the purposes of the organization?

The iSchools are an international organisation composed of member institutions and their representatives. The only data about persons that the organisation keeps on file are the names of official representatives and their support staff, plus the names of persons who have won awards, such as the doctoral dissertation award or the best paper at the iConference.

The iSchools are also obliged under US law to collect financial information about those receiving payments, including staff and prize winners. The Treasurer and the Executive Director share responsibility for this with the Treasurer completing the tax forms and the Executive Director making the payments.

Personal information includes:

  • Name
  • Institution
  • Institutional address
  • Email address
  • Social Media address when relevant
  • Telephone number
  • Tax ID number (only for those receiving payments)
  • Bank account
  • Postal address

3. How do the iSchools use this information?

  1. Members’ email addresses are used for communication with members and for voting on issues.
  2. The Wild Apricot membership database allows members to communicate with others.
  3. Invoices for dues are sent via email.
  4. Photos and descriptions of events may be posted on the website or via social media when provided  by member institutions.

4.  What risks would this personal information pose to individuals’ rights and freedom if it were not protected?

Most of the information that the iSchools hold is already freely available on the websites of the member institutions. Theoretically, members’ rights to privacy could be violated if their contact information and/or photos were accessible outside the iSchools community. The iSchools collect no sensitive personal information about members (e.g., health, personal financial, religion, or legal records).

5.  How is this personal information stored and protected?

The information is stored in the following locations:
  • Microsoft Office 365, which is password protected
  • Google Docs, which is password protected
  • Wild Apricot database, which is password protected and accessible by administrators only
  • Survey tools of Humboldt-Universit├Ąt zu Berlin, which is password protected
  1. The address book is in a password protected area on the Wild Apricot database.
  2. Communication is via mailing lists where individual email addresses other than those of team members do not appear.
  3. Personal information from the past is kept in password-protected storage.
  4. Personal tax information is deleted after the tax forms are filed.

6.  How are members informed of their rights to accuracy and protection of their personal information?

Members will be informed as follows: 
  1. The iSchools will inform members about what information is kept and allow individuals to opt out, if their home member institution allows that. The iSchools will also ask routinely for updates.
  2. Members may request information about personal information at any time from the Executive Director.
  3. A page will be added to the iSchool website to make the data privacy policy public.

7.  When is personal information deleted from iSchool records?

Members’ personal data will be deleted from the iSchool files upon request. It may also be deleted when a member institution informs the Executive Director that the representative has changed or when a school ceases to be a member by request or by non-payment of dues.
Checklist

  1. Pseudonymization:   Generally, not used.
  2. Encryption:  The website traffic on ischools.org is secured and encrypted with Wild Apricot’s traffic encryption capability (https) and with the Let’s Encrypt Certificate (SSL) to ensure the security and privacy of personal data.
  3. Guarantees of confidentiality:  Contact information provided by institutional members is not shared outside the iSchools, except by member request. Photos are used only by permission. Computer files containing personal information are password-protected, with passwords known only to relevant Club officers. No paper copies are kept.
  4. Guarantees of integrity: The iSchools depend on member institutions to inform the Executive Director when representatives or other information changes.
  5. Guarantees of availability:  The Executive Director or members of the Core Team are typically available to provide access to information, when requested.
  6. Guarantees of the resilience of the system: The iSchools rely on the security measures of Microsoft Office 365, of Wells Fargo Bank, of Google, of Wild Apricot, and of Humboldt-Universit├Ąt zu Berlin.
  7. Procedures for restoring access to data after a physical or technical accident: All data is kept in online systems that provide secure backups.
  8. Procedures for regular review, assessment, and evaluation of the effectiveness of the technical and organizational measures: The Executive Committee should review the data protection procedures annually.

Change records

The iSchools generally maintain register of changes to personal data in the Wild Apricot database.

8. How we use Google Analytics

  1. This website uses Google Analytics, a web analysis service by Google LLC (“Google”). Google uses “cookies”. Cookies are text files that are saved on your computer to enable the analysis of how you use our website. The information generated by the cookie concerning your use of this website (including your IP address) will be transmitted to and stored by a Google server in the USA. Google shortens your IP address within member states of the European Union including other contracting states of the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is transmitted to a Google server in the USA where it is shortened. Under the authority of the provider of this website, Google will use this information to evaluate your use of the website, generate reports about website activities and to provide further services connected to the website use and internet use for the website provider. The legal basis for this is Article 6 Paragraph 1, Sentence 1, lit. f GDPR, which allows the legitimate processing of personal data without the expressed consent of the data subject, if the processing is necessary to safeguard the legitimate interests of the responsible party or third party, and if the interests or fundamental rights and freedoms of the data subject who requires the protection of personal data do not prevail, especially if the data subject  is a child. The iSchools Inc.’s legitimate interest is to measure user behaviour on this website. We preserve your interests by employing means of anonymizing your data and providing options to opt out of the placement of cookies, which prevents the collection of your data. Moreover, we have concluded an Order Processing Contract with Google LLC to instruct and authorize Google with the processing of collected information. Google deletes collected information after 14 months.
  2. The IP address that your browser transmits within the scope of Google Analytics is not associated with any other data held by Google.
  3. You can prevent the placement of cookies by  making a particular adjustment in your browser. Please note that, if you disable the generation of cookies, you might not be able to use all functions of the website to the full extent. Furthermore, you can prevent the collection of information by the cookie regarding your use of the website (including your IP address) as well as the processing of this data by Google by downloading and installing the browser plug-in provided at the following location:https://tools.google.com/dlpage/gaoptout?hl=en
  4. This website uses Google Analytics with the “_anonymizeIp()“ extension so that IP addresses are only processed in abbreviated form to prevent the identification of individuals. If the collected data contain any references to individuals, the references and associated data will be deleted immediately.
  5. We use Google Analytics to measure and analyse the traffic on our website in order to continuously improve its appearance and functionality as well as our service. For those exceptional cases in which personal data is transmitted to the USA, Google has committed itself to the EU-US Privacy Shield,https://www.privacyshield.gov/EU-US-Framework.
  6. Information about Google: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

Terms of Service:https://marketingplatform.google.com/about/analytics/terms/us/

Privacy Policy:https://policies.google.com/privacy?hl=en-US

You can prevent the collection of your data by Google Analytics by pressing the button below. An Opt-Out Cookie will be placed in your browser that prevents the collection of your data for future visits to the website.


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iSchools Inc.
2885 Sanford Ave. SW, Box 40576
Grandville, MI 49418
USA

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