100-15
ONLINE PRIVACY POLICY

POLICY & PROCEDURE

Subject:

ONLINE PRIVACY POLICY

Index: Administration

Number: 100-15

Effective Date

9/30/2009

Supersedes

N/A

Page

1 of 6

Staff Contact

Preeti Shridhar

Approved By

Denis Law

1.0 PURPOSE:

This policy addresses the collection, use and security of and access to information that may be obtained through use of the City’s website, rentonwa.gov.

2.0 ORGANIZATIONS AFFECTED:

All departments/divisions, city officials, citizens and businesses.

3.0 REFERENCES:

City of Seattle Online Privacy and Security Policy

WA State Department of Transportation Web Privacy Notice

4.0 POLICY:

This policy addresses the collection, use and security of and access to information that may be obtained through use of the City’s website rentonwa.gov.

5.0 DEFINITIONS:

5.1    “User” or “Visitor” refers to individuals accessing the website via the internet.

5.2    “Internet Protocol Address” is a numerical identifier assigned either to the user internet service provider or directly to their computer.

5.3    “Personal information" is information about a natural person that is readily identifiable to that specific individual. Personal information includes such things as an individual's name, address, and phone number. A domain name or Internet Protocol Address is not considered personal information.

5.4    "Cookies" are simple text files stored on the computer by the web browser.

5.5    “Applets” are tools downloaded to the computer to work with the software installed.

6.0 PROCEDURES:

6.1     Information collected when browsing the City’s website

Information is automatically collected and stored when a user visits the City’s website to browse, read pages, or download information from the web server. The type of information collected includes the following:

a.    The Internet Protocol Address and domain name used.

b.    The type of browser and operating system used.

c.    The date and time the site was visited.

d.    The web pages or services accessed at the site.

e.    The website visited prior to coming to the City’s website.

Information is collected for statistical purposes and to help the City understand how people are using our services and manage the site. The City analyzes the information to determine how the website is being used, and to improve the site’s usefulness to the public. The City's website uses software programs to create summary statistics used for such purposes as assessing what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.

For site security purposes and to ensure this service remains available to all users, the City's website employs software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Except for authorized law enforcement investigations and the security purposes mentioned elsewhere in this policy, no other attempts are made to identify individual users or their usage habits. Raw data logs are used for no other purposes and are scheduled for regular destruction in accordance with public records retention schedules.

6.2    Type of information collected if volunteered.

If, when visiting the website the user participates in a survey, sends an e-mail, participates in a City-hosted mailing list or web-based discussion, or performs some other transaction online, the following additional information will be collected:

a.    The e-mail address and contents of the e-mail for those who communicate with the City via email or who participate in a City- hosted mailing list or web-based discussion.

b.    Information volunteered in response to a survey.

c.    Information volunteered through an online form for any other purpose.

d.    Information volunteered by participating in an online transaction with the City.

The information collected is not limited to text characters and may include audio, video, and graphic information formats sent to the City.

The e-mail address is used to respond to the user. It is the City's Policy to not use the e-mail address or to send unsolicited e-mail unless the user specifically elects to receive it. Online discussion lists or "threads" are maintained and controlled in accordance with the City's Electronic Mailing List Policy. Survey information is used for the purpose identified by the survey. Information from other online forms is used only for conducting City business related to the online form.

Information provided for a transaction is used only for the purpose of completing and recording the transaction. Information requested will be no more specific than if a visitor were engaging in the transaction by other means, including by telephone or in person while visiting a City facility. In all cases, the City strives to collect the minimum information necessary to comply with applicable law or provide the service requested.

The City does not sell, rent, or otherwise distribute visitors’ information, including electronic mail addresses, to any outside company or organization, unless legally required to do so. This applies to information that may be collected on the City's site and on that of any third party with whom the City contracts to provide internet-related services.

6.3    Option to provide personal information online.

No personal information is collected unless it is voluntarily provided by the user by sending the City an e-mail, participating in a survey, completing an online form, or engaging in an online transaction. Users may choose not to contact the City by e-mail, participate in a survey, provide personal information using an online form, or engage in an electronic transaction. The user’s choice to not participate in these activities will not impair their ability to browse, read, or download general information provided on the City of Renton’s website.

If personal information is requested on the website or volunteered by the user, state law and the federal Privacy Act of 1974 may protect it. However, this information is treated like any other information provided to the City, and may be subject to public inspection and copying if not protected by federal or state law.

Users are cautioned that the collection of personal information requested from or volunteered by children online or by e-mail will be treated the same as information given by an adult, and may be subject to public access.

6.4     Public Access to Information

In the State Of Washington, Public Disclosure laws exist to ensure that government is open and that the public has a right to access appropriate records and information possessed by City government (the Public Records Act or "PRA" RCW 42.56.070). At the same time, there are exceptions to the public's right to access public records that serve various needs including the privacy of individuals. Both state and federal laws provide exceptions. The PRA requires the disclosure of all public records unless a particular record (or particular information contained in a record) is specifically exempt under the PRA or other applicable law. For example, there is no categorical exemption for residential telephone numbers, residential addresses, or personal e-mail addresses. However, the PRA does not require the disclosure of "credit card numbers, debit card numbers, electronic check numbers, card expiration dates, or bank or other financial account numbers supplied to [the City] for the purpose of electronic transfer of funds, except when disclosure is expressly required by law."

The PRA does not authorize the City to give, sell, or provide access to lists of individuals to entities seeking to use the lists for commercial purposes. City practice is to require those who request lists of individuals to sign an affidavit stating that they do not have a commercial purpose (such as contacting those on the list to propose a commercial transaction). However, the City cannot guarantee that a requester will not, despite signing such an affidavit, contact individuals on the list for a commercial purpose.

In the event of a conflict between this Privacy Notice and the Public Records Act or other law governing the disclosure of records, the Public Records Act or other applicable law will prevail.

6.5    Non-Disclosure of Certain Information:

The City of Renton may require the user to provide certain personal information in order to complete a specific transaction. The information is required in order to provide the user with specific services. The user may choose not to provide this information, but if they choose not to provide it the City will be unable to provide these services, and the transaction in question will have to be completed either in person or by mail.

Although information collected at this site may be subject to public inspection, members of the general public do not have a right to inspect the user’s credit card numbers, debit card numbers, electronic check numbers, card expiration dates, or bank or other financial account numbers that are supplied to an agency for the purpose of electronic transfer of funds, except when disclosure is expressly required by law. RCW 42.56.210(1).

6.6    Review and Correction of Personally Identifiable Information

A user can review any of their own personally identifiable information that is collected by contacting the City of Renton. The user can then recommend any changes and corrections to the personally identifiable information by submitting a request that credibly shows the inaccuracy. The City will take reasonable steps to verify the user’s identity before granting access or making corrections.

6.7    Use of Cookies and Applets

The City's policy is to limit the use of cookies. However, some of the applications the City builds and purchases use cookies to confirm the integrity of online transactions. Cookies used in this manner do not contain personally identifiable information.

Applets are tools downloaded to the computer to work with the software installed. Applets are intended to enhance the browsing experience by enabling the user to view information in a unique manner or enable access to information that the computer would otherwise be unable to access without the applet. The City does not currently use applets. If the decision is made to utilize applets users of the City's website will not be required to use them.

6.8    Security

The City has taken several steps to safeguard the integrity of its data and prevent unauthorized access to information it maintains, including, but not limited to, authentication, monitoring, auditing, and encryption. Security measures have been integrated into the design, implementation, and day-to-day practices of the entire operating environment as part of its continuing commitment to risk management. These measures are designed and intended to prevent corruption of data, block unknown or unauthorized access to our systems and information, and provide reasonable protection of private information in the City’s possession.

Unauthorized attempts to upload information or change information on this service are strictly prohibited and may be punishable under the state Computer Trespass law and federal statutes including the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.

6.9    Electronic Commerce

The number of options to do business with the City over the internet including making electronic payments for goods and services continue to increase. Such transactions are allowed only under tightly controlled circumstances where there are appropriate technological and other safeguards in place to protect financial and other sensitive data.

The provision of this information shall not be construed in any way as giving business, legal, or other advice, or warranting as fail-proof the security of information provided via the City's website.

6.10    Avoiding Internet Fraud

It is the City's policy never to request confidential personal or financial information from our customers for purposes other than City-related business. Any e-mails purportedly from the City requesting confidential information not in connection with City business should be reported to the City’s webmaster at webmaster@rentonwa.gov.

6.11    Links to Other Websites

The City's website contains many links to other websites. These include links to websites operated by other government agencies, nonprofit organizations, and private businesses. This policy will not apply on sites that are not the City’s website. When a user links to another website, they are subject to the privacy policy of that new site. Visitors linking to another site are encouraged to examine the privacy policy of that site.

6.12    Disclaimer

Neither the City, nor any department, officer, or employee of the City warrants the accuracy, reliability, or timeliness of any information published on this website, nor endorses any content, viewpoints, products, or services linked from this website, and shall not be held liable for any losses caused by reliance on the accuracy, reliability or timeliness of such information. Portions of such information may be incorrect or not current. Any person or entity that relies on any information obtained from this website does so at their own risk.