AtlanticOER Privacy Policy

AtlanticOER Privacy Policy

Approved by Board: February 13, 2023
Last Revised: February 15, 2023
Policy Number: POL4
Responsibility: CAAL-CBPA Executive Director
Revision Schedule: Annually

Definitions

Personal Information: “Personal information” is defined by the federal government of Canada to mean information about an identifiable individual (PIPEDA, 2009). Some personal information such as business addresses may be found in the public domain by accessing publications like telephone or professional directories. The focus of this policy is personal information collected, used, and disclosed by AtlanticOER, that is NOT in the public domain.

Purpose

AtlanticOER is committed to maintaining and protecting the confidentiality and privacy of personal information, as mandated by the Government of Canada (PIPEDA, 2009). This policy has been developed to set out AtlanticOER’s collection, use, disclosure, and protection of the personal information of users. We manage and share your personal information only as outlined in this policy or otherwise with your consent. If you do not agree with the terms laid out in this policy, you should not access AtlanticOER services or website(s), as use of the services implies consent to the terms. 

Scope

This Policy covers the use of the AtlanticOER service, including the website(s) on which the service is hosted. Policies on handling personal information apply to all employees, volunteers, members, and other users who may have access, to varying degrees, to personal information. This Policy does not apply to services, institutions, or other entities that AtlanticOER does not directly oversee or manage. It does not eliminate any other obligations that AtlanticOER may have under applicable privacy or human rights legislation, nor does it displace its obligations under another policy or any applicable collective agreement.

Who We Are

AtlanticOER is a pilot service that supports the hosting and creation of open educational resources by educators and students in the Atlantic provinces of Newfoundland and Labrador, New Brunswick, Nova Scotia, and Prince Edward Island. 

The AtlanticOER website is: https://atlanticoer-relatlantique.ca/. 

The AtlanticOER Pressbooks website is: https://caul-cbua.pressbooks.pub/. 

Contact Information

Council of Atlantic Academic Libraries
120 Western Parkway, Suite 202
Bedford, Nova Scotia
Canada, B4B 0V2
902-830-6467
oer@caul-cbua.ca

Policy Review

  1. The Executive Director and Board of Directors undertake responsibility for the administration of this Policy.
  2. This Policy will be reviewed in accordance with CAAL-CBPA’s Communications Policy review process.

Type of Information

AtlanticOER may collect and use the following forms of personal information:

  1. User-provided information: Name, email address, personal account preferences, and other information may be provided by users.  This may occur upon registration for a Pressbooks account, or via communications (email, phone, and in-person).  These are also detailed below.
  2. Personal data from technical processes: Contact forms, comments, cookies, website analytics, plug-ins, and third-party embedded content may generate data upon users interacting with them.  These are outlined in more detail below.

Collection and Use of Personal Information

User-Provided Information

AtlanticOER collects user-provided personal information only to the extent needed to provide and run our services. Below are ways we may collect and use personal information. 

Contact forms: AtlanticOER uses contact forms provided by a plug-in to provide users with an easy way to communicate with us.  To enable us to assist users, we ask for minimum information for identification and communication (name, email address, and anything the user may wish to provide in the body of the message).  We will not disclose such information other than in the course of providing services (unless required by law), nor will we sell users’ information or use it for marketing purposes.  The plugin, Captain Form, is a third-party plug-in and has its own separate privacy policy which AtlanticOER does not control: https://www.captainform.com/privacy-policy/ 

Account registration: Users who wish to register for a Pressbooks account with AtlanticOER consent to providing AtlanticOER with basic personal information needed to complete the registration process, such as name and email address.  Your professional role and institutional affiliation are also collected, but these generally fall outside of the domain of personal information.

Comment forms: When visitors leave comments on our websites, we collect the data shown in the comments form (email address, name, comment form), as well as the IP address.  Messages will be reviewed before being posted.  

Communications: Users may contact us directly via email, phone, or another communication method. As above, we only use any personal information to provide services, such as website administration, password recovery, or to resolve issues and respond to inquiries.  Any personal information users provide in such communications will not be disclosed (unless required by law), nor will we sell users’ information or use it for marketing purposes. 

Mail lists: Users may opt-in to certain mail lists to receive further communications from AtlanticOER.  We will always ask for users’ express consent (verbally or in writing) before including any email addresses for such purposes.  We will also provide an unsubscribe mechanism for each communication through which users can withdraw consent (typically, a reply to an email).  AtlanticOER complies with Canada’s anti-spam legislation (CASL): https://fightspam.gc.ca/eic/site/030.nsf/eng/home 

Third-party content: Users should note that AtlanticOER does not have control over, nor a privacy policy, for any third-party content embedded in our services (such as a YouTube video).  Use and interaction with such third-party content that discloses personal information will be subject to the privacy policies of those parties. 

Media: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Information from Technical Processes

WordPress, the website platform used by AtlanticOER, provides a number of default and optional functionalities and features whose technical processes may generate personal data. 

Cookies: Cookies are small data files that are stored on your computer when interacting with websites. AtlanticOER uses cookies to help streamline technical processes for our users, such as authentication, and to enable website analytics.  When logging into your Pressbooks account, we will set a temporary cookie to determine if your browser accepts cookies (WordPress test cookie). This cookie contains no personal data and is discarded when you close your browser.  We use both temporary and persistent cookies to facilitate and enhance the use of our websites.  Many browsers allow users to control cookies or disable them in their privacy settings, however, the website may not function as intended if cookies are disabled. 

Usage and analytics: Visitors to AtlanticOER websites may generate usage data collected by our analytics plug-ins and website platform. Tools that we may use to collect and analyze such data are Google Analytics, Koko Analytics, and basic stats about website usage provided by the platform (such as the number of resources created).  Google Analytics and Koko Analytics use cookies to track usage data.

As stated above, cookies enable us to use analytics tool to analyze and improve our services.  However, if you do not wish to allow them, many browsers allow users to control cookies or restrict them in different ways.

Plugins: AtlanticOER uses a number of third-party plug-ins to improve our services and technologies. These third-party plug-ins have their own privacy policies, and may capture technical data linked to users.  Below is a list of plug-ins that AtlanticOER uses:

Third-party content: As above, users should note that AtlanticOER does not have control over, nor a privacy policy, for any third-party content embedded in our services (such as a YouTube video).  These services may collect data about you, use cookies, or embed additional third-party tracking.

Handling Your Personal Information

The handling of personal information will be performed only by employees, volunteers, and other members at AtlanticOER who require personal information to fulfill their duties and provide services, such as responding to inquiries and account creation.  Employees, volunteers, and other individuals will comply with the collection and use of personal information outlined in this policy, and they will be given sufficient training on handling personal information.

Disclosing and Sharing of Personal Information

AtlanticOER recognizes the importance of protecting your personal information.  As such, we do not sell or rent personal information to third-parties, nor do we disclose any personal information except where necessary to provide services.  AtlanticOER may aggregate statistics or anonymized personal data for the purposes of analysis and tracking, which may be shared with third parties and stakeholders; this data is not personally identifiable.  AtlanticOER may use contractors to provide additional services on our behalf, for instance technical services, payment processors (where applicable), or data analysts.  In such cases, we may provide personal information to these companies solely for the express purpose of fulfilling the task which we requested. 

If you have an account on an AtlanticOER website, you can request to receive a file of the personal data we hold about you, including any data you have provided to us.  You can also request that we erase any personal data we hold about you.  This does not include any data we are obliged to keep for administrative, legal, or security purposes.

In the case of legal or security issues, AtlanticOER has the right to disclose your personal information when required by law or when your use of AtlanticOER poses a security or legal risk, including the detection of spam, fraud, copyright infringement, and safety risks.

Retaining and Storing Personal Information

AtlanticOER retains your personal information to ensure continued provision of services.  For this reason, the duration we retain personal information may vary depending on the type of information.  Registration and account information are retained for as long as the individual remains a registered user, whether active or inactive, unless a request is made to AtlanticOER to delete the account, or a technical capacity has been reached.  This is to ensure continuity of service and continued access to users.  Analytics and usage data may be retained indefinitely for the purposes of analysis; this data will be retained in an aggregate and anonymized form.  Information from communications and contact forms, including the body of the inquiry, will be retained for five years to ensure continuity in service. 

AtlanticOER stores personal information (email addresses and names) on these platforms: OneDrive, Google Drive, Outlook servers, and website platforms themselves for Google Analytics, Koko Analytics, and WordPress.  Access to personal information on these platforms is limited to those whose roles and responsibilities require access to personal information.  Files are kept as securely as possible on these platforms by limiting sharing, and we will make every effort to keep files securely.  While cloud servers enable us to perform necessary tasks, no cloud storage is entirely secure.

Privacy and Sharing on Pressbooks

In addition to the sections outlined above, individuals who register for and use the AltanticOER Pressbooks website should make note of these additional considerations.  AtlanticOER only manages your personal information according to the sections of the policy outlined above, however, users of the Pressbooks platform may share additional personal information at their discretion that may be viewable to select audiences or the public. 

Individuals who create or modify open educational resources on Pressbooks may share the contents of their learning objects with others, including any personal information that may be contained therein (such as author biographies, or other identifiable details).  Access has multiple settings, including chapter-level privacy settings, with the ability to allow for different levels of visibility; see more here: https://guide.pressbooks.com/chapter/privacy-settings/.  You may also provide additional personal information in your profile, such as links to personal websites or location; we will not ask or require this information in order for you to use our services. 

Policy Supports

  1. Canada’s anti-spam legislation (2021, March 19). https://fightspam.gc.ca/eic/site/030.nsf/eng/home Cookie Policy. Retrieved August 17, 2021. https://en-ca.wordpress.org/about/privacy/cookies/
  2. Google Analytics Terms of Service. (2019, June 17). https://marketingplatform.google.com/about/analytics/terms/us/
  3. Holt, C. (2019, December 2). Benchmarking CAUL-CBUA Communications. https://drive.google.com/file/d/1fM7nOEnhrdvu-bsT7g_P-Bc-dLDCdMha/view?usp=sharing
  4. Our use of cookies and similar technologies. Retrieved August 17, 2021. https://help.twitter.com/en/rules-and-policies/twitter-cookies
  5. Personal Information Protection and Electronic Documents Act, 66 (2009). https://laws-lois.justice.gc.ca/PDF/P-8.6.pdf
  6. Privacy Policy. Retrieved August 18, 2021. https://www.captainform.com/privacy-policy/
  7. Privacy Policy Guide. Retrieved August 23, 2021. From Pressbooks.pub, privacy section.