This is a draft for consideration at the August Board Meeting.
This policy covers personally identifiable information collected or stored by the Society on its servers in relation to the projects hosted by the Society (“Projects”) and their communities. Consistent with its Data Retention Policy, the Foundation collects and retains the least amount of personally identifiable information needed to fulfill the Projects' operational needs.
Personally Identifiable Information refers to information which can be used to distinguish or trace an individual’s identity, including (but not limited to) their name, social security number, biometric records, credit card information, date or place of birth, mother’s maiden name, or other information that either alone, or in combination with other personal or identifying information is linked or linkable to a specific individual.
Society means the Wiki Society of Washington, DC, Inc.
Activities on Society projects
In general, this Policy only applies to private information stored or held by the Society which is not publicly available.
Interactions with the Projects not covered by this Policy include, but are not limited to, aspects of browsing and editing pages, use of the wiki "email user" function, subscribing and posting to the Society’s hosted email lists, and corresponding with volunteers via the Society’s email addresses. These interactions may reveal a contributor's IP address, and possibly other personal information, indiscriminately to the general public, or to specific groups of volunteers acting independently of the Society.
Users may also interact with one another outside of Society sites, via email, IRC or other chat, or independent websites, and should assess the risks involved, and their personal need for privacy, before using these methods of communication.
The Society does not require editors to register with a project. Anyone can edit without logging in with a username, in which case they will be identified by network IP address. Users that do register are identified by their chosen username. Users select a password, which is confidential and used to verify the integrity of their account. Except insofar as it may be required by law, no person should disclose, or knowingly expose, either user passwords and/or cookies generated to identify a user. Once created, user accounts will not be removed. It may be possible for a username to be changed, depending on the policies of individual projects. The Society does not guarantee that a username will be changed on request.
Purpose of the collection of private information
The Society limits the collection of personally identifiable user data to purposes which serve the well-being of its projects, including but not limited to the following:
- To enhance the public accountability of the projects.
- To solve technical problems. Log data may be examined by developers in the course of solving technical problems.
- To contact members regarding the conduct of Society business, including the provision of notice of the Society’s membership meetings.
Details of data retention
IP and other technical information
- When a visitor requests or reads a page, or sends email to a Society server, no more information is collected than is typically collected by web sites. The Society may keep raw logs of such transactions, but these will not be published or used to track legitimate users.
- When a page is edited by a logged-in editor, the server confidentially stores related IP information for a limited period of time. This information is automatically deleted after a set period. For editors who do not log in, the IP address used is publicly and permanently credited as the author of the edit. It may be possible for a third party to identify the author from this IP address in conjunction with other information available. Logging in with a registered username allows for better preservation of privacy.
Users are free to choose a user name on the Society’s websites. No inference should be drawn between the user name used on the Society’s computer systems and a user name on systems operated by the Wikimedia Foundation. The Society does not have access to confidential information on the Wikimedia Foundation systems and does not require its members to disclose their other user names to it.
- The sites set a temporary session cookie on a visitor's computer whenever a web page is visited. Readers who do not intend to log in or edit may deny this cookie; it will be deleted at the end of the browser's session. More cookies may be set when one logs in to maintain logged-in status. If one saves a user name or password in one's browser, that information will be saved for up to 30 days, and this information will be resent to the server on every visit to the same Project. Contributors using a public machine who do not wish to show their username to future users of the machine should clear these cookies after use.
- Users are not required to list an email address when registering. Users who provide a valid email address can enable other logged-in users to send email to them through the wiki. When receiving an email from other users through this system, one's email address is not revealed to the sender. When choosing to send an email to other users, one's email is displayed as the sender.
- The email address put into one's user preferences may be used by the Society for communication. Users whose accounts do not have a valid email address will not be able to reset their password if it is lost. In such a situation, however, users may be able to contact one of the Society’s administrators to enter a new e-mail address. A user can remove the account's email address from his preferences at any time to prevent it from being used. Private correspondence between users may be saved at those users' discretion and is not subject to Society policy.
- On mailing lists:
- The email addresses used to subscribe and post to Project mailing lists are exposed to other subscribers. The list archives of most such mailing lists are public, and searches of public archives may be performed on the Web. Subscribers' addresses may also be quoted in other users' messages. These email addresses and any messages sent to a mailing list may be archived and may remain available to the public permanently.
- Some e-mail addresses forward mail to a team of volunteers.The team may discuss the contents of received mail with other contributors in order to respond effectively.
Access to and release of personally identifiable information
The Society is run by volunteers. Selected volunteers will have access to personally identifiable information to the extent necessary to carry on the Society’s operations.
Release: Policy on Release of Data
The Society will release personally identifiable data collected in the server logs, or through records in its data files, or through other non-publicly-available methods, in any of the following situations:
- In response to a valid subpoena or other compulsory request from law enforcement,
- With permission of the affected user,
- When necessary for investigation of abuse complaints,
- Where the information pertains to page views generated by a spider or bot and its dissemination is necessary to illustrate or resolve technical issues,
- Where the user has been vandalizing or persistently behaving in a disruptive way, data may be released to a service provider, carrier, or other third-party entity to assist in the targeting of IP blocks, or to assist in the formulation of a complaint to relevant Internet Service Providers,
- Where it is reasonably necessary to protect the rights, property or safety of the Society, its users or the public.
- When necessary to work with the Society’s vendors (for example, to provide housing and dining services during Wikimania.)
- To the extent required by D.C. Code § 29-301.26 or other provisions of law.
Except as described above, the Society’s policy does not permit distribution of personally identifiable information under any circumstances.
Third-party access and notifying registered users when receiving legal process:
As a general principle, the access to, and retention of, personally identifiable data in all projects should be minimal and should be used only internally to serve the well-being of the projects. Occasionally, however, the Society may receive a subpoena or other compulsory request from a law-enforcement agency or a court or equivalent government body that requests the disclosure of information about a registered user, and may be compelled by law to comply with the request. In the event of such a legally compulsory request, the Society will attempt to notify the affected user within three business days after the arrival of such subpoena by sending a notice by email to the email address (if any) that the affected user has listed in his or her user preferences.
The Society cannot advise a user receiving such a notification regarding the law or an appropriate response to a subpoena. The Society does note, however, that such users may have the legal right to resist or limit that information in court by filing a motion to quash the subpoena. Users who wish to oppose a subpoena or other compulsory request should seek legal advice concerning applicable rights and procedures that may be available.
If the Society receives a court-filed motion to quash or otherwise limit the subpoena as a result of action by a user or their lawyer, the Society will not disclose the requested information until the Society receives an order from the court to do so.
Society members or other registered users are not required to provide an email address. However, when an affected registered user does not provide an email address, the Society will not be able to notify the affected user in private email messages when it receives requests from law enforcement to disclose personally identifiable information about the user.