From APEC HRDWG Wiki
This policy covers personally identifiable information collected or stored by the U.S. Department of Education and its contractors on its servers in relation to the APEC Human Resources Development Working Group Wiki.
The public and collaborative nature of the Wiki
All pages of the APEC Wiki are collaboratively developed by its users using the MediaWiki software. Anyone with Internet access and a user account (and not otherwise restricted from doing so) may edit the publicly editable pages of these sites. By doing this, editors create a published document, and a public record of every word added, subtracted, or changed. This is a public act, and editors are identified publicly as the author of such changes. All contributions made to a Wiki page, and all publicly available information about those contributions, are irrevocably licensed and may be freely copied, quoted, reused and adapted by third parties with few restrictions.
User accounts and authorship
Users are identified by their assigned 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, however the U..S. Department of Education and APEC do not guarantee that a username will be changed on request.
Purpose of the collection of private information
The U.S. Department of Education limits the collection of personally identifiable user data to purposes which serve the well-being of the Wiki, including but not limited to the following:
- To provide site statistics. The U.S. Department of Education statistically samples raw log data from users' visits. These logs are used to produce the site statistics pages; the raw log data is not made public.
- To solve technical problems. Log data may be examined by developers in the course of solving technical problems and in tracking down badly-behaved web spiders that overwhelm the site.
Details of data retention
IP and other technical information
- When a visitor requests or reads a page, or sends email to an APEC Wiki server, no more information is collected than is typically collected by web sites. The U.S. Department of Education or its contractors may keep raw logs of such transactions, but these will not be published or used to track legitimate users.
- When a page is edited, the server confidentially stores related IP information for a limited period of time. This information is automatically deleted after a set period.
- The sites set a temporary session cookie on a visitor's computer whenever a Wiki 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. 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.
- Edits or other contributions to APEC Wiki articles, user pages and talk pages are generally retained forever. Removing text from a page does not permanently delete it. Normally, in pages, anyone can look at a previous version of an article and see what was there. Even if an article is "deleted", a user entrusted with higher level of access may still see what was removed from public view. Information can be permanently deleted by individuals with access to APEC Wiki servers, but aside from the rare circumstance when the U.S. Department of Education or its contractors are required to delete editing-history material in response to a court order or equivalent legal process, there is no guarantee any permanent deletion will happen.
- User contributions are also aggregated and publicly available. User contributions are aggregated according to their registration and login status. Data on user contributions, such as the times at which users edited and the number of edits they have made, are publicly available via user contributions lists, and in aggregated forms published by other users.
- No more information on users and other visitors reading pages is collected than is typically collected in server logs by web sites. Aside from the above raw log data collected for general purposes, page visits do not expose a visitor's identity publicly. Sampled raw log data may include the IP address of any user, but it is not reproduced publicly.
- Edits to Wiki pages are identified with the username of the editor, and editing history is aggregated by author in a contribution list. Such information will be available permanently on the pages.
- Logged in users do not expose their IP address to the public except in cases of abuse, including vandalism of a Wiki page by the user or by another user with the same IP address. A user's IP address is stored on the Wiki servers for a period of time, during which it can be seen by server administrators and by users who have been granted CheckUser access.
- IP address information, and its connection to any usernames that share it, may be released under certain circumstances (see below).
- On Wiki discussion pages:
- Any editable page can theoretically be the location of a discussion. In general, discussions on Wiki pages occur on user talk pages (associated with particular users) or on article talk pages (associated with particular articles). Privacy expectations apply to discussion pages in the same way as they do elsewhere.
- Via email:
- 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 them. 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 U.S. Department of Education or its contractors 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 APEC Wiki server 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 this 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.
Access to and release of personally identifiable information
The APEC HRDWG Wiki is maintained by the U.S. Department of Education and its contractors. Some employees of these entities are given privileged access. User group rights and group members are reachable in the Wiki from the Special:ListGroupRights page.
Other users who may have access to private identifiable information include, but are not limited to, U.S. Department of Education employees, appointees, and contractors and agents employed by the Department of Education, and developers and others with high levels of server access.
Access to and publication of this information is governed by the Access to nonpublic data policy, as well as specific policies covering some of the functions in question. Sharing information with other privileged users is not considered "distribution."
Release: Policy on Release of Data
It is the policy of the U.S. Department of Education that personally identifiable data collected in the server logs, or through records in the database via the CheckUser feature, or through other non-publicly-available methods, may be released by staff, 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 articles 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 U.S. Department of Education, APEC, their users or the public.
Except as described above, this 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 the Wiki should be minimal and should be used only internally to serve the well-being of the projects. Occasionally, however, the Department of Education or its contractors 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 we 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 U.S. Department of Education or its contractors cannot advise a user receiving such a notification regarding the law or an appropriate response to a subpoena. The Department of Education 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 a court-filed motion to quash or otherwise limit the subpoena as a result of action by a user or their lawyer is received, the U.S. Department of Education and its contractors will not disclose the requested information until they receive an order from the court to do so.
Registered users are not required to provide an email address. However, when an affected registered user does not provide an email address, we 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.