34 Survey Results: Survey Questions and Responses 36. Please enter any comments you have regarding privacy policies. N=13 All library staff are required to complete university-wide training on FERPA. The precise form of information/consent/opt-in varies by the project and the information collected. IRB approval has been sought and granted for project-based data collection. Any data that we are gathering about student use of the library’s resources, spaces, services, etc., is used for non-research purposes and within the library only. Consult as necessary with general counsel and other administrative offices in the university depending on the nature of the project or initiative. IRB approval gained if needed not always needed for internal review purposes. Google analytics is running on our sites students don’t have the opt-in/opt-out option for those analytics. Our public services staff are trained on patron privacy and confidentiality. Not at the moment, but we are taking all of these options into consideration. On the advise of our APIR data analytics is for process improvement, not research subject to IRB restrictions. The Libraries does not have learning analytics initiatives. The library protects the privacy of its users. Library employees have no expectation of privacy in using library resources/collections or systems. The university level privacy policy will supersede any library or departmental level privacy policies developed. We consult with IR, the IRB, internal library legal experts, and the university’s general counsel when we are beginning a new assessment/learning analytics endeavor. Our process for seeking advice/counsel depends on the scope of the study. We don’t additionally inform students for general data collection beyond the university’s disclosure policies. However, for many studies involving more detailed and specific data (e.g., performance on assignments) we obtained signed consent. We inform students about some learning analytics initiatives, particularly those that involve identifiers. These projects provide the option to opt out. These projects are subjected to IRB review. Other data is simply analyzed without identifiers. We only consult and obtain approval from IRB if we intend to publish or present the results of our learning analytics to individuals outside our organization. If the data collection is solely for organizational development purposes, we do not seek IRB approval, however we still make every effort to adhere to IRB participants’ privacy protection protocols. PROCEDURES 37. Does your library have any internal staff documents or guidelines that inform your learning analytics initiatives? N=44 Yes 11 25% No 33 75% If yes, please briefly describe the contents of the document. N=9 Definition of performance indicators, process for reporting data and trends