The Board of Trustees of the San Miguel County Public Library District #1, Wilkinson Public Library, adopts and makes public the following written policy.

The staff and trustees of the Wilkinson Public Library are committed to protecting patron privacy and confidentiality as rooted in the ethics and practices of librarianship and in compliance with C.R.S. 24-90-119 Privacy of User Records and C.R.S. 24-73-101: Consumer Data Privacy.

The Library:

• Will not disclose the use of library content, materials, equipment, programs, facilities, and staff assistance unless the disclosure is necessary for the reasonable operations of the Library or is required by law.
• Will take reasonable measures to ensure the confidentiality of patron Library records, accounts, and library use by securing and limiting access to these records to approved Library staff only.
• Will only collect personally identifiable information when needed for reasonable operation of the Library.
• Has appropriate physical, electronic, and managerial procedures in place in an effort to safeguard and secure the information we collect to prevent unauthorized access, maintain data security, and ensure the correct use of information. We cannot, however, guarantee that unauthorized users will never access the information we collect.

Consent/Information Collected
The Library will not collect or retain personally identifiable information without consent. Patrons may provide their names, email addresses, postal addresses, telephone numbers, and unique identification/pin/password to receive Library services such as a Library Card, register for programs, receive personal responses to questions, or be added to group texts or mailing lists. Personally identifiable information will not be sold, licensed, or disclosed to any third party except those
working under contract with the Library or as required by law.

Library Materials and Borrowing History
The Library keeps a record of patron borrowing history only within operational requirements. Patrons may elect to opt in to save their reading history through the Library’s online catalog.

Parents/Guardians and Minors
The Library respects the privacy of all patrons regardless of their age. Parents or custodial guardians of minors (under 18) who wish to obtain access to the minor’s library records, including the titles of materials checked out or overdue, must provide the child’s library card. This policy does not include an exception that allows the Library staff to provide information regarding a child’s location. Library staff
cannot share information regarding a minor’s location or pass messages to a minor.

Third-Party Vendors
The Library enters into agreements with third parties to provide online services, digital collections, streaming content, and website improvements. These services may connect with social networks. The Library may release information that authenticates registered Library patrons. The Library encourages patrons to review third-party providers’ privacy policies as these vendors have their own privacy policies
and terms of service and are not beholden to the Library’s privacy policies.

This policy does not apply to external applications or websites accessed from the Library’s public computers, devices, or wireless networks. Some patrons may take advantage of email or text messages or similar services that send personally identifiable information related to library use via public communication networks, and the Library has limited ability to protect the privacy of this information.

Data/Network/Computers/Website
The Library is committed to data security and keeping personally identifiable information safe. The Library shall maintain reasonable security procedures and practices to protect personal information from unauthorized use, modification, disclosure, or destruction. Personal information is defined in C.R.S. 24-73-103 as a combination of personal data elements that could compromise an individual’s security, confidentiality, or integrity in the event of a security breach and differs from Library User Records and Circulation data that the Library deems confidential as defined by Privacy of User Records C.R.S. 24-90-119. The Library may receive personal information from patrons during activities.

The Library may collect and store information to measure its website use to assist in making it more useful. That information includes the address (IP) of a computer or Internet provider, the date/time the website was accessed, pages accessed, cookie data, website navigation, and the Internet address of the website that referred the patron. The Library monitors network activity to identify unauthorized attempts to upload, change, or cause damage to the network.

Data Breach
In the event of a security breach or unauthorized access of unencrypted personal information data, the Library shall assess the risk and notify the patrons of the breach if the Library determines there is a reasonable likelihood of misuse of personal information no later than 30 days after a determination that a breach occurred. The notification shall provide the patron with the information and directions detailed
in C.R.S. 24-73-103.

Disposal of Data
When paper or electronic documentation containing personally identifiable information is no longer needed, the Library shall destroy or arrange for the destruction of such documents within its custody or control by shredding, erasing, or otherwise modifying the personal information to make it unreadable.

Surveillance
The Library may have closed-circuit video surveillance at its facilities to provide a safe and comfortable environment. Video surveillance may be stored for up to 30 days and destroyed unless other retention policies apply.

Release of Data/Subpoena
Records or any other information containing information that identifies a person or their use of the library or its materials may only be disclosed by the Library Director in the following instances:

• When necessary for the reasonable operation of the Library
• Upon written consent of the patron
• Pursuant to a subpoena, upon court order, or where otherwise required by law
• To a custodial parent or guardian who has access to a minor’s library card to access electronically the Library records of the minor

The Library will refer public records requests and law enforcement inquiries to the Library Director. This Library Director/Board President/Manager in Charge is the custodian of records and is authorized to receive or comply with public records requests or inquiries from law enforcement. The Library Director may confer with legal counsel before determining the proper response to any request for records. Library records may only be disclosed under subpoena, upon court order, or where otherwise required by law.

Illegal Activity Prohibited and Not Protected
Patrons may conduct only legal activity using Library resources and services. The Library may prevent the use of facilities, networks, resources, or equipment for illegal purposes.

Date Approved: 3/20/2024
Approved by: Wilkinson Public Library Board of Trustees
Date Amended/Modified: