Confidentiality of Library Records & Privacy Policy

Policy Statement

NCW Libraries is committed to protecting the privacy and confidentiality of all users in alignment with federal and state laws and the ethical standards of the library profession. Our commitment is grounded in the American Library Association’s Code of Ethics, which affirms: “We protect each library user’s right to privacy and confidentiality with respect to information sought or received and resources consulted, borrowed, acquired, or transmitted.” This principle guides our policies and practices in handling user information across all services we offer.

NCW Libraries is also a public agency subject to the Washington State Public Records Act (RCW 42.46, et seq), which may necessitate disclosure of certain non-confidential information. Revised Code of Washington (RCW) 42.56.310 states: “Any library record, the primary purpose of which is to maintain control of library materials, or to gain access to information, that discloses or could be used to disclose the identity of a library user is exempt from disclosure under this chapter.” Library records deemed confidential pursuant to RCW 42.56.310 will not be made available to members of the public, press or any agency of state, federal or local government without an order from a court of competent jurisdiction, or as otherwise required by law.

Related Laws & Resources

• RCW 19.188.030. Library access policies
• RCW 40.14 – Preservation and Destruction of Public Records
• RCW 42.56.310 – Library Records
• Children’s Internet Protection Act (CIPA)
• Children’s Online Privacy Protection Act (COPPA)
• US Patriot Act
• ALA Privacy Toolkit
• NCW Libraries’ Internet Use Policy, Records Retention and Destruction Policy, and Public Records Policy

The Purpose

The purpose of this policy is to outline NCW Libraries’ commitment to user privacy and confidentiality while maintaining compliance with state and federal laws. It also defines NCW Libraries’ practices for collecting, using, and safeguarding personally identifiable information necessary to deliver effective services and support

Personally Identifiable Information (PII) collected by NCW Libraries PII refers to information that can be used on its own or with other information to identify or contact individuals. Confidential records covered by this policy include, but are not limited to the following:

• Registration and account records
• Circulation and materials requests
• Search and download history via third-party services
• Program and event registration data
• Interlibrary loan requests
• Public computer and wireless internet usage data
• Meeting room reservations
• Patron feedback and survey responses

Privacy Principles

• NCW Libraries staff access PII only when necessary for library operations.
• NCW Libraries records that contain PII are exempt from public disclosure unless disclosure is mandated by a lawful directive.
• NCW Libraries limits creation and retention of unnecessary records and complies with the Washington State CORE Records Retention Schedule.
• While NCW Libraries records are typically confidential, physical library spaces are public, and users should not expect privacy beyond the confidentiality of their records.

Library Card Registration & Account Information

To provide library services and maintain user accounts, NCW Libraries collects limited personal information during registration, which includes:

• Full name
• Mailing address
• Phone number(s)
• Email address

This information is used solely by NCW Libraries staff to deliver services, communicate with patrons, and support library operations. It is protected under the confidentiality standards outlined in this policy.

Use & Disclosure of Information

• NCW Libraries will not disclose PII to any federal, state, or local agency unless legally required, and only upon presentation of a valid subpoena, court order, or search warrant issued by a court of competent jurisdiction.
• Patrons may access their own records and may authorize others to pick up materials or access information on their behalf.
• Library data may be used internally to improve operations or inform planning.
• Data may be anonymized and aggregated for reporting or analysis.

Minors & Confidentiality

All users of NCW Libraries, regardless of age, are entitled to privacy and confidentiality in their library use. This is consistent with Article VII of the Library Bill of Rights, which affirms that “all people, regardless of origin, age, background, or views, possess a right to privacy and confidentiality in their library use.”

In accordance with RCW 42.56.310, any library record—regardless of the user’s age—that could disclose or be used to disclose the identity of a library user is exempt from public disclosure. This includes circulation records, account details, and internet usage logs.

Because NCW Libraries does not collect age information when issuing library cards, all accounts are managed under the same confidentiality standards. An exception may be made for parents or legal guardians of minors with overdue materials. Upon request, the parent or guardian may be provided with the titles and due dates of items checked out on the child’s card solely for the purpose of facilitating their return.

Parents and legal guardians are encouraged to engage in open conversations with their children about library use and expectations. They may also choose to accompany their child when selecting materials or using NCW Libraries services.

Third-Party Services

NCW Libraries partners with third-party vendors to offer services such as digital borrowing, catalog search, streaming content, and event registration. While these tools enhance service delivery, they operate under their own privacy policies and data practices.

• Vendors are expected to meet strong data protection standards.
• Information collected by vendors is governed by their privacy polices.
• Patrons are encouraged to review the privacy policies of third-party services accessed through NCW Libraries.

Website Privacy & Use of Cookies

NCW Libraries is committed to safeguarding the privacy of individuals using our website. Patrons are not required to submit PII unless they voluntarily provide it for services such as account access, event sign-ups, or newsletters.

Information Collected Automatically

In order to improve user experience and functionality, NCW Libraries may collect limited non-personal data, including but not limited to the following:

• Browser type and version
• Operating system
• IP address and approximate location
• Referring site
• Date, time, and duration of visit
• Pages visited on the site

Cookies

Cookies and similar technologies may be used by NCW Libraries to:

• Support login and session continuity
• Monitor site performance and usage
• Personalize content and layout based on usage
• Maintain secure sessions
• Improve accessibility and user experience

Most browsers allow users to manage cookie preferences. Disabling cookies may limit website functionality. For details on vendor-specific cookies, refer to their respective privacy policies.

Security

NCW Libraries implements reasonable technical and administrative safeguards to protect data collected online. However, NCW Libraries is not responsible for the privacy practices of external websites that link to or from our website.

Digital Personalization & Opt-In Services

• Patrons may enable optional features such as reading history, recommendations, or newsletters.
• All such services are opt-in and can be discontinued at any time.
• Contact information provided may be used to notify patrons about library materials, events, or relevant services.

Data Retention & Secure Disposal

• PII is retained only as long as necessary to support library operations.
• Records are securely disposed of according to the Washington State Local Government CORE Records Retention Schedule.

Enforcement & Redress

The Executive Director or designee serves as the custodian of library records and is responsible for responding to legal inquiries and public records requests. Upon receipt of a subpoena, warrant, or court order, the Executive Director or designee will consult legal counsel to ensure compliance with applicable laws while upholding NCW Libraries confidentiality obligations.

Board of Trustees Approval/Enactment
By approving this policy, the Board of Trustees of NCW Libraries rescinds any previous policy that conflicts with or expands upon the provisions stated herein.

Effective Date:
Applicability: