The Library Copyright Alliance includes ACRL, ALA, and ARL. It is dated July 25, 2012.
The Library Copyright Alliance expresses appreciation to Member States for your thoughtful discussions regarding limitations and exceptions for these three broad areas that affect the daily
work of libraries: VIP, libraries, and education.
We strongly oppose language in the proposed text for Article D of SCCR/23/7 regarding the provision of aggregated data to rightsholders. It would invite publishers to second-guess the
procedures of libraries as authorized entities, to challenge the quality and quantity of the records kept or the appropriateness of transactions, and to threaten litigation when they see an increase.
These record keeping and reporting activities involve significant costs better spent on the provision of services, and compliance may impose such a burden that many libraries will decide
not to provide services to print disabled patrons. There is no evidence that authorized entities anywhere that exceptions exist have abused those exceptions. So there is no justification for the
added administrative burden.
Furthermore, with current technology, there’s no such thing as anonymous aggregate data. Several major privacy breaches occurred because people were able to reverse engineer the
aggregated data to figure out personally identifiable information. This provision, therefore, threatens the privacy of the visually impaired.
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