Personal Information System Policy

Person Directly Responsible for System: Information Technology (I.T.) Department Manager, Jeffrey Wale

DOCUMENTS INCLUDED:

  • Confidentiality of Library Records Policy (Based on Ohio Revised Code: Sec. 149-432. State Law on Confidentiality of Library Records.)
  • Confidentiality of Library Records Guidelines
  • Request for Library Customer Records Information Form
  • Computer Systems, Security, and Data Protection Policy
  • Personnel Records Policy

Disciplinary Guidelines: No reprisal, retaliation, or other adverse action will be taken against any staff member who in good faith reports unauthorized use of personal information contained in the Library system. Any person who violates any section of this policy may be subject to disciplinary action.

Monitoring Procedures: Annually on the anniversary of the adoption of this policy, appropriate administrators from Information Technology, Human Resources, and Circulation Services will review the system for accuracy, relevance, timeliness and completeness of the personal information in the system.

CONFIDENTIALITY OF LIBRARY RECORDS POLICY

The Toledo Lucas County Public Library (TLCPL) considers all customer records, including but not limited to, registration information and use information in the form of circulation records, database search records, computer use records, inter-library loan records or reference records, to be confidential. We will not distribute or disclose this information to outside parties unless required to do so by State or Federal laws or pursuant to a customer's consent as outlined below:

Library records or customer information shall be released in the following situations:

  • In accordance with a subpoena, search warrant or other court order.
  • To a law enforcement officer who is acting in the scope of the officer's law enforcement duties investigating a matter involving public safety in exigent circumstances.
  • To a law enforcement officer responding to the Library's request for help in maintaining its collections.
  • To a Library-authorized, third-party digital content provider who requires customer barcode information for verification, usage, statistics or similar services. Where possible, shared data will be anonymized.
  • To a Library approved recovery agent for the collection of fines, fees, and non­-returned Library materials.
  • To a Library cardholder requesting information on his/her own account, or to the parent of a minor child or guardian or custodian requesting information regarding their ward’s account.

Library Customer records may be used internally for administrative purposes including, but not limited to:

  • The establishment and maintenance of a system to manage Library records.
  • The transfer of Library records from one records management system to another.
  • The compilation of statistics and the collection of fines, fees and non-returned Library materials.

CONFIDENTIALITY OF LIBRARY RECORDS GUIDELINES

As noted in our Confidentiality of Library Records Policy, we consider all library customer records, including but not limited to, registration information and use information in the form of circulation records, database search records, computer use records, inter-library loan records or reference records, to be confidential.

In compliance with Ohio Revised Code 149.432, the Foreign Intelligence Surveillance Act (FISA), and the Uniting and Strengthening America by Provisioning Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act);

  • Requests for the release of any type of Library Customer Information through subpoena or court order must be forwarded to the Director of the Library for review.
  • The Director, or authorized representative, must be notified immediately for requests for any type of Library Customer Information by any Law Enforcement Officer with an appropriate ID and a search warrant.
  • A person supplying personal information must do so, if the personal information is legally required.

Guidelines

Requests for Customer Registration information

  • Staff may access customer registration information for official purposes only.
  • All completed library card applications are used to enter information into our ILS system.
  • Contract/signature cards are removed from the applications and scanned into the Customer Contract Database. All paper applications are to be destroyed once this work is complete.
  • Access to customer information in the ILS system and the customer contract database is restricted to administrative staff, circulation staff or other Library staff, as authorized by administration or by the Manager of Circulation Services.

Requests for Circulation Information in Person or by Telephone

  • If a customer presents a card or card number (user ID): Use the user ID to access the user account and provide information.
  • If a customer presents the card of a minor or card number (user ID): Use the user ID to access the user account and provide information.
  • If a customer does not present card or card number (user ID): Ask customer to present an ID or verify name, address and date of birth.

Provide requested information if verified; if not verified, do not present information
If parent or guardian does not present card or card number of minor:

  • Parent or guardian must verify name, address, and date of birth.
  • Provide requested information if verified; if not verified, do not present information

Requests for Information from a Local Law Enforcement Official or Federal Investigator
When a legal document (subpoena, search warrant or FISA warrant) is presented, follow these procedures:

Subpoena:
Refer the agent or officer to the manager or supervisor on duty at the branch or to the person-in-charge (PIC) at Main Library (if neither are available at the time). At Main Library, refer the agent or officer to the administrative offices during regular business hours or to the PIC at Main Library when the administrative offices are closed.This individual will then:

  • The manager/supervisor/administrator will accept the subpoena.
  • Forward the subpoena to the Director for examination with legal counsel. The Director, or authorized representatives, will follow-up with the agent or officer.
  • Do not disclose any Library customer information.

Search Warrant:
Refer the agent or officer to the manager or supervisor on duty at the branch or the PIC at Main Library (if neither are available at the time). At Main Library, refer the agent or officer to the administrative offices during regular business hours or to the PIC at Main Library when the administrative offices are closed. This individual will then:

  • Examine the search warrant carefully to verify that the warrant is complete and signed.
  • Request and photocopy the agent's/officer's ID Immediately and inform the Library Director of the request.
  • Begin the search for the requested information immediately after attempting to contact the Director. Ask a second staff person to accompany the search to assist in documenting information and/or equipment provided.
  • Use the information provided by the officer or agent to locate the Library customer information.
  • Cooperate with the search to ensure that only the records identified in the warrant are produced and that no other users' records are viewed or scanned.
  • Complete the Request for Library Customer Record Information form and have the agent or officer sign it to verify what was requested and received. If equipment is confiscated, record the inventory number on the form. Attach the copy of the agent's/officer's ID to this form and forward to the Director.

Foreign Intelligence Surveillance Act (FISA), Search Warrant:
The search warrant contains a "gag order" meaning staff are not permitted to disclose that the warrant has been served or that records have been produced to any other party, including the individual whose records are the subject of the search. A FISA gag order allows the staff person receiving the FISA warrant to inform the Director and other members of the staff needed to produce the records.

  • Follow steps as outlined under "Search Warrant" above.
  • Check on the Request for Library Customer Record Information form that the information requested is a FISA warrant.
  • Do not discuss with any other individuals, including fellow staff and the customer who is the subject of the search.

Exigent circumstances (a situation in which there is an immediate threat to human life or property):

Refer the agent or officer to the manager or supervisor on duty at the branch or the PIC at Main Library (if neither are available at the time). At Main Library, refer the agent or officer to the administrative offices during regular business hours or to the PIC at Main Library when the administrative offices are closed. This individual will then:

  • Request and photocopy the agent's/officer's ID.
  • Immediately inform the Director of the request.
  • Begin the search for the requested information immediately after attempting to contact the Director.
  • Use the information provided by the officer or agent to locate the Library customer information.
  • Cooperate with the search to ensure that only the records identified in the warrant are produced and that no other users' records are viewed or scanned.
  • Complete the Request for Library Customer Record Information form and have the agent or officer sign it to verify what was requested and received. If equipment is confiscated, record the inventory number on the form. Attach the copy of the agent's/officer's ID to this form and forward to the Director.

If the request is made by a law enforcement officer who is responding to the Library's request for help in maintaining its collection:
Refer the agent or officer to the manager or supervisor on duty at the branch or the PIC at Main Library (if neither are available at the time). At Main Library, refer the agent or officer to the administrative offices during regular business hours or to the PIC at Main Library when the administrative offices are closed. This individual will then:

  • Request and photocopy the agent's/officer's ID.
  • Immediately inform the Director of the request.
  • Provide the customer information to the officer to assist in the investigation. Complete the request for Library Customer Record Information form and have the agent or officer sign it to verify what was requested and received. If equipment is confiscated, record the inventory number on the form. Attach the copy of the agent's/officer's ID to this form and forward to Library Director.

Requests for library customer information should be forwarded to the Library Director or the Deputy Director.

COMPUTER SYSTEMS, SECURITY and DATA PROTECTION POLICY

Board Policy: Toledo Lucas County Public Library’s computer systems are essential to the Library’s mission, goals, and services that we provide to the community and our customers. The misuse of our computer systems, resources, and failure to protect data could create serious problems inhibiting our ability to effectively serve the citizens of Ohio.

To protect our computer systems, use the technology appropriately, maintain security of our data, and adhere to legal requirements, all staff must use good judgment and follow the guidelines below.

Guidelines:

Related Policies and Forms

  • Confidentiality of Library Records (June 2012)
  • Public Records Retention Schedule (January 2008)
  • Cell phones, pagers, and tablets (January 2013)
  • Social Network Policy (January 2011)

Definition
Computer Systems is defined in general terms to include all technology-related equipment, software, electronic resources, digital content, and data either accessed, produced, or stored by Toledo Lucas County Public Library.

Administrative Oversite
The Library Director and Deputy Director have full authority to investigate, collect evidence, and take appropriate action to protect the Board of Trustees, our customers, staff, and the Library’s reputation. They may involve others, including law enforcement authorities, as needed.

User Accounts and Passwords

  • Staff will be issued individual network logon accounts (username and password) to control access to the data network, resources, and permission levels.
  • All passwords will be complex with eight characters, one uppercase letter, one number, and one symbol. Staff will be required to change their passwords at a set interval.
  • Shared network accounts (ILS system, shared computers, subscriptions, etc.) are used by certain staff and must be protected and treated as confidential.
  • Passwords are not to be shared, written down, posted, or stored electronically unless they are encrypted. Note: sharing your password with an authorized I.T. staff member for troubleshooting is permitted.
  • Staff suspecting an account may be compromised should change the password immediately.
  • Username changes due to legal name changes should be submitted to the Human Resource Department, who will contact the Finance Department and the I.T. Department to make appropriate changes.
  • Upon termination of employment, all network access is disabled. TLCPL will retain all emails and correspondences as deemed necessary. Depending on job duties, emails may be forwarded to others for monitoring.

Electronic Communications (Email, Text Messages, Social Media, etc.)

  • Emails, text messages, and social media posts should be limited to library-related business and are the property of TLCPL.
  • Personal emails, text messages, social media posts are permitted using library-owned equipment (and personal devices) during breaks but should be kept to a minimum. Note: All personal communications using library devices and accounts (email, Verizon, Facebook, etc.), are subject to public FOIA requests and ongoing investigations.
  • All communications should be professionally written, concise, factual, non-threatening, non-judgmental, non-discriminatory, and free of obscenity, pornography, slandering, and disparaging others.
  • Staff must keep an electronic copy of all communications required to comply with the public records retention schedule. All non-essential communications can be deleted. The organization of emails and saving communications is up to each staff member to manage.
  • The Board has authorized the deletion of all non-essential communications after three years.

Storage

  • Server storage is provided for all staff and is backed up nightly. The I.T. department does not back up local hard drives, so all files saved locally are at risk of being lost.
  • Staff may temporarily save files to the web (i.e. Google Docs, One Drive, Dropbox, or mobile apps) for collaboration and sharing of files, but all final copies of files MUST be copied to a Library server for public FOIA requests and record retention.
  • Customer information (name, address, phone, reading history, and credit card information) cannot be saved to the web without prior authorization.

Misuse of Resources
Do not access computer systems using someone else’s account, override computer security settings, download illegal software or movies, send mass mailings or chain letters, use the Library resources to run personal businesses or sell items (eBay, etc.), print personal files excessively, or do any action that can harm our computer resources.

Using authorized shared vendor accounts is permitted, assuming staff has been granted administrative or user permissions to do so.

Data Protection

  • Staff is responsible for using good judgment regarding the protection of data.
  • Staff is required to maintain confidentiality of customer information pursuant to Ohio Revised Code Section 149-43-2 and 1347.05 (Personal Information Systems).
  • All devices (PCs, laptops, tables, iPads, cell phones, etc.) must be password protected and never left unattended. In the event the device is lost or stolen, staff must contact I.T. (to disable it) and
  • Security (to complete an Unusual Occurrence Report).
  • Passwords are to be protected – see Section D for more information.
  • Staff is entrusted with various levels of information and access to data. Use of information for any reason beyond its intended purpose is a violation of trust and may endanger staff and the well-being of TLCPL. Any staff member who uses his/her knowledge to gain access to unauthorized computer systems and data is subject to corrective action which could include employment termination. If staff is presented with confidential documents, the documents must be stamped at the top as “CONFIDENTIAL” and given to the Finance Department for processing and storage. No additional copies can be made or kept in local departments.

Ecommerce (online and in-person)

  • The Library will comply with the Payment Card Industry (PCI) protections, workflows, and network intrusion detection scans to protect cardholder data.
  • Staff involved with customer credit cards will be trained annually on proper handling, storage, and protection of customer credit card data.
  • Staff will not request, accept (in-person, phone, email, text, or mail), store, or share credit card information (includes number and CVV security codes) in any form.
  • When selling event tickets, etc., staff must use the ecommerce iPads with the 4G connection only (never Wi-Fi).
  • Staff must report all suspicious activities, attempts to steal identities or credit card information, and all data breaches to the Security Coordinator and I.T. Manager.

Viruses

  • Do not open a file if our antivirus software reports a virus.
  • Do not open questionable email attachments that you don’t recognize or links that point to a different location or domain.
  • Do not install or open software applications from unknown or non-trusted sites.
  • Do not insert customer flash drives in staff computers.
  • If you accidentally open a file that launches a virus:
  • Unplug the network cable from the wall. This prevents the virus from spreading to servers and other computers.
  • Leave the computer powered on and do not close any applications. This allows I.T. and law enforcement (if needed) to investigate the source and collect evidence.
  • Contact the I.T. Department immediately.

PERSONNEL RECORDS POLICY

It is the policy of the Library to comply with all state and federal laws regulating employee personnel records and access to public records. The Library requests, maintains, and uses only that personal information that is necessary for human resources, payroll and benefit administration.

There is one personnel record for each employee of the Toledo Lucas County Public Library. This record is housed in Human Resources.

The personnel record may include such information as letters of reference; performance evaluations; documented discussions; corrective actions; recommendations; applications for employment; applications for promotion or transfer; leave requests; certificates and records of attendance at job­related workshops, conferences and courses of study; proof of education; and miscellaneous personnel forms and records authorized by the Director or the Human Resources Manager as information necessary and relevant to the function of the Library.

Medical release forms and other health records are kept in a separate file.

A person supplying personal information must do so, if the personal information is legally required.

The personnel records of Ohio public employees are public records. Employees or any member of the public may request to examine the personnel files (except references, citizenship, and medical information) in the presence of the Human Resources Manager, Director, Deputy Director, Finance Manager, or the Director's designated representative.

Human Resources will notify an employee if anyone other than a supervisor asks to view the employee's records.

Employees must notify the Human Resources Department of any change in name, address, home telephone number, marital status, citizenship, tax exemptions, or affiliations with any branch of the armed forces as soon as is practical.

Policy Updated: November 2017