Privacy Policy (Draft)
Whiteside Family Association
1.	Privacy.  The Whiteside Family Association (WFA) gives high priority to supporting the privacy of living persons.  We support privacy by limiting the collection, storage, and access to personal data, especially sensitive personal data.
2.	Personal Data.  Personal data is any data that is identifiable to a specific living person, by any reasonable means including use of other, public data.  The WFA is primarily concerned with personal data that is stored electronically.  We are most concerned about the privacy of sensitive personal data, such as might be used for identity theft, health condition determination, racial determination, etc.
3.	Uses of Personal Data.  The WFA collects and stores minimal personal data for the purpose of helping our members research their (deceased) ancestors (i.e. genealogy).  Such use includes helping members find common ancestors.  We will retain personal data only as long as it is useful for these purposes.
4.	Members Data.  For paying members, the WFA collects and stores personal data for contacting them, plus indications of their genealogy research interests.  When a member registers, we will clearly state the purpose(s) for which collected personal data will be used.  We will also ask for informed consent to these uses of personal data, preferably by explicit (opt-in) consent.
5.	Data Handling.  The WFA will handle all personal data with high data protection by design and by default, preferably by data anonymization or encryption.  We do not process personal data for purposes other than data retrieval, collecting statistics, and finding similarities between persons.
6.	Personal Data Copies.  The WFA will provide upon request a copy of all the personal data stored about a living person.  Requests are accepted by email, and data copies are provided by email.
7.	Personal Data Erasure.  The WFA will erase (delete) upon request all the personal data stored about a living person.  Requests are accepted by email, and confirmations are provided by email.
8.	Sensitive Data Breach Notification.  The WFA will report any detected sensitive data release without authorization, to the person and to an authority within 72 hours. 

Notes
The above uses of “will” are areas where new WFA privacy procedures seem to be needed.
In refining this privacy policy and associated procedures, we need to consider all the categories of personal data stored by the WFA for living persons.  We do not need to consider privacy for deceased persons, including all our deceased ancestors.  The categories of personal data now stored on the WFA website include:
1.	Member registration information, for current and former WFA members.
2.	DNA test results submitted to the WFA, and comparisons of these results.  How much of this DNA data is identifiable to a specific person, by any reasonable means?
3.	Genealogy data collected by Don Whiteside that lists persons still living.  What data items are sensitive personal data?  I assume a person’s name and date of birth are sensitive personal data.
4.	Genealogy data submitted to the WFA by members and friends, which may list persons still living.  How should we screen previously and newly submitted data for sensitive personal data on living persons?
In addition to personal data stored on the WFA, we should consider what personal data is stored by WFA officers and used in support of WFA business.