Legal:Data retention guidelines

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	Data collected by MediaWiki about a user account's activity (e.g., date and time that a user verifies their email address) Data collected by EventLogging and associated with their user ID (e.g., whether an account was created on mobile, A/B test data for Getting Started)	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
	Provided by a user	Language	Until user deletes/changes the account setting.
Non-personal information not associated with a user account*	Collected automatically from various users	Counts of how many times certain events have occurred (e.g. successful HTTPS requests)	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 for educational, development, or other related purposes, unless otherwise indicated in the privacy policy or statement of such survey or research. Such information may be retained in raw, aggregated, or anonymized form until we receive a request from the participant to be removed from our research database.
• In rare cases, we, or particular users with certain administrative rights as described in our Privacy Policy, may need to retain your personal information, including your IP address and user agent information, for as long as reasonably necessary (which may be longer than the period described in the table above) to:

• enforce or investigate potential violations of our Terms of Use, this Privacy Policy, or any Foundation or user community-based policies;
• investigate and defend ourselves against legal threats or actions;
• help protect against vandalism and abuse, fight harassment of other users, and generally try to minimize disruptive behavior on the Wikimedia Sites;
• prevent imminent and serious bodily harm or death to a person, or to protect our organization, employees, contractors, users, or the public; or
• detect, prevent, or otherwise assess and address potential spam, malware, fraud, abuse, unlawful activity, and security or technical concerns.

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 privacywikimedia.org.

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• Privacy policy
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