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Bob Millward
Governance Lead

UC-006_library_recommender_privacy_review_signed.pdf

EV-2026-0136 ยท DPIA ยท linked to Library โ€” children's reading recommender

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Artefact ID
EV-2026-0136
Type
DPIA
Linked use case
Uploaded by
Privacy Officer
Uploaded at
2026-05-17 10:08
Size
188 KB
SHA-256
5566โ€ฆ77aa (truncated for display)
Hash chain
Verified ยท chained to previous entry
Summary

Privacy Impact Assessment for the children's library reading recommender. Personal information involved (parent's library account history); concludes Low residual risk with controls in place.

Chain of custody

Drafted by Library Services + Privacy Officer. Hash chained at upload.

Sections

1. What personal information is processed?

Parent/guardian library account ID and borrowing history of titles. Child's name and age (where parent has provided it). No browsing behaviour outside the catalogue captured.

2. Who can access outputs?

Only the account holder (parent/guardian) via authenticated session. Library staff can view aggregate (popular recommendations across all accounts) but not per-account. Vendor (SirsiDynix) cannot access tenant data.

3. PPIPA applicability

Applies (s.4 personal information). Lawful basis: necessary for the function of the library (s.10(b)). Consent confirmed at library card sign-up.

4. Risks identified

Risk: child's reading inferred by other household member with account access. Mitigation: per-child profile feature deferred to v2; parents advised in privacy notice. Risk: vendor scope creep (e.g. ML model trained on borrowing data). Mitigation: contract addendum prohibits cross-customer model training (signed 2026-05-14).

5. Sign-off

Signed
Privacy Officer
2026-05-17

Approved by Privacy Officer 2026-05-17. PPIPA breach risk: Low. Next review: 2027-05-17 or upon material change.