Application of the principle of transparency in processing of European national libraries patrons' personal data

The purpose of this paper is to examine the relationship between the legal obligation of European libraries to ensure the transparent personal data processing and respect for user privacy. This paper will examine how libraries use privacy notices on websites to communicate with patrons about the processing of personal data and in what manner have libraries been guided by applicable transparency guidelines.

The method used is the analysis of privacy policies and other privacy documents found on the websites of national libraries. The analysis sample includes documents of 45 European national libraries, 28 out of those being national libraries of European Union (EU) Member States. The elements for this analysis are derived from the mandatory elements of the General Data Protection Regulation and the recommendations of the WP29/EDPB Transparency Guidelines.

The findings suggest that European national libraries largely adhere to EU data protection standards. In total, 60% libraries use a separate privacy page, and 53% of the EU Member State national libraries websites managed to comply with publishing all necessary data protection information in a way recommended by the Guidelines, compared to 47% of non-Member State national libraries.

The research contributes to the understanding of the importance of the principle of transparency and its operationalization.