Data retention guidelines

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Information

The community consultation for the Data Retention Guidelines has closed as of 14 February 2014. We thank the community members who have participated in this discussion since the opening of the consultation on 09 January 2014 and have helped make the Guidelines better as a result. Although we are closing the community consultation, we welcome community members to continue the discussion. The Guidelines are intended to evolve and expand over time. You can read more about the consultation on the Wikimedia blog. Mpaulson (WMF) (talk) 23:57, 14 February 2014 (UTC)

Introduction

Data is important. It is one of the ways we can learn and grow as an organization and a movement, and how we can help make the projects better for those who use them to create, learn, and share. At the same time, we are committed to keeping your private data "for the shortest possible time that is consistent with the maintenance, understanding, and improvement of the Wikimedia Sites, and our obligations under applicable U.S. law" (quote from the Wikimedia Foundation Privacy Policy).

This document helps explain how we fulfill this commitment, by describing our guidelines for data retention, system design, and ongoing auditing and maintenance. These guidelines are meant to be a living document — they will be updated over time to reflect current retention practices.

To what data do these guidelines apply?

These guidelines apply to all non-public data we collect from Wikimedia Sites covered by the Privacy Policy.

How long do we retain non-public data?

Unless otherwise indicated, we retain the following types of data for no more than the following periods of time:

Data type Origin Examples Maximum Retention Period
Personal information Collected automatically from a user
  • IP addresses of site visitors (operational data)
  • IP addresses of A/B test subjects (analytical data)
  • Identifying user-agent information of site visitors
After at most 90 days, it will be deleted, aggregated, or anonymized
Account settings
  • Email address
Until user deletes/changes the account setting.
Non-personal information associated with a user account* Collected automatically from a user Indefinitely
Provided by a user
  • Logs of terms entered into the site's search box, or terms within prefilled links to the search engine that have been followed by user navigation
After at most 90 days, it will be deleted, aggregated, or anonymized
Non-personal information not associated with a user account* Collected automatically from various users Indefinitely
Articles browsed by readers Collected automatically from a reader
  • A list of articles visited by readers
After at most 90 days, if retained at all, then only in aggregate form
(*) For the purposes of this table, "user account" means username, user ID, or IP address; "reader" means visitor to a Wikimedia project.

Definitions

For the purposes of these guidelines:

  • "Personal information" means information you provide us or information we collect from you that could be used to personally identify you. To be clear, while we do not necessarily collect all of the following types of information, we consider at least the following to be "personal information" if it is otherwise nonpublic and can be used to identify you:
(a) your real name, address, phone number, email address, password, identification number on your government-issued identification, IP address, user-agent information, and your credit card number;
(b) when associated with one of the items in subsection (a), any sensitive data such as date of birth, gender, sexual orientation, racial or ethnic origins, marital or familial status, medical conditions or disabilities, political affiliation, and religion; or
(c) any of the items in subsections (a) or (b) when associated with your user account.
  • Some examples of "public information" would include: (a) your IP address, if you edit without logging in; (b) your gender, if it is disclosed under your user profile; (c) any personal information you disclose publicly on the Wikimedia Sites, such as your real name or age. Some examples of types of information that are considered to be "nonpublic information" include: (a) your IP address, if you edit while logged in; (b) your email address, if you provided one to us during a registration (but didn’t post it publicly); and (c) your location information, if you have not posted it publicly. The types of information that are considered "nonpublic" as opposed to "public" are more fully explained in our Privacy Policy.
  • Data is "anonymized" when (1) information that can be used to identify a specific user has been removed or otherwise been changed so that it can no longer be used to identify the user directly, and (2) best efforts have been made to remove, or otherwise make non-re-identifying, information that could be used to re-identify the user.
Examples of identifying information that could be removed in order to anonymize data would include:
  • Real names, addresses, phone numbers, email addresses, password, identification number on government-issued ID, IP address, user-agent string, credit card number, unique device identifiers
Examples of changes that could be made to data so that it no longer directly identifies the user:
  • Encrypting or removing/masking the most specific portion of IP addresses
  • Sanitizing user-agent strings
  • Data is "aggregated" when the data associated with a specific user has been combined with data from others to show general trends or values without identifying specific users.
An example of how data can be aggregated includes:
  • Using ranges rather than specific numbers, such as recording that there are "between 1 and 10 editors in language X in country Y" rather than recording that there are 4 editors.

While we make our best effort to anonymize or aggregate information to the point that an individual cannot be identified, we cannot completely eliminate the risk of re-identification. For more info about re-identification, please see the FAQ section of the Privacy Policy.

Terms that are not defined in this document have the same meaning given to them in the Privacy Policy.

Exceptions to these guidelines

If we make exceptions to these guidelines, we will notify the community by describing the exception on this page.

  • Data may be retained in system backups for longer periods of time, not to exceed 5 years.
  • Information (including personal information) collected through participation in a survey or other research conducted by the Wikimedia Foundation will be retained indefinitely or until we receive a request from the participant to be removed from our research database.

Audits for existing systems

These guidelines are based on practices that the Foundation has generally followed for many years, particularly the 90-day rule for IP addresses and similar personal information in our server logs. However, our older systems may not always comply with these new guidelines, particularly for personal information other than IP addresses. As a result, once these guidelines are adopted, WMF’s technology teams plan to audit our existing systems and bring them into compliance. Because of the size and scope of these systems, this audit will necessarily occur in a gradual fashion.

Design of new systems

In order to support these data retention periods and our overall privacy policy, new tools and systems implemented by the Foundation will be designed with privacy in mind. This will include:

  • inclusion of these data retention guidelines as requirements during the design process;
  • legal consultation during the design and development process; and
  • inclusion of privacy considerations in the code review process.

Ongoing handling of new information

Despite our best efforts in designing and deploying new systems, we may occasionally record personal information in a way that does not comply with these guidelines. When we discover such an oversight, we will promptly comply with the guidelines by deleting, aggregating, or anonymizing the information as appropriate.

Contact us

If you think that these guidelines have potentially been breached, or if you have questions or comments about compliance with the guidelines, please contact us at privacy at wikimedia.org.

Privacy-related pages

Privacy policy · FAQ · Glossary of key terms · Subpoena FAQ · Access to nonpublic information · Confidentiality agreement · Data retention guidelines · Donor policy