Table of Contents
1 Purpose, Scope, and Applicability
2 General Statement on Data Sharing and Privacy
5 How ACCESS Uses Collected Information
7 With Whom ACCESS Shares Information
January 10, 2023
1 Purpose, Scope, and Applicability
ACCESS, on behalf of the National Science Foundation (NSF), operates a set of central infrastructure services, which serves to federate many Resource Provider sites.
This policy pertains to information gathered through the ACCESS services—including, but not limited to, the ACCESS portals, the ACCESS ticket system, ACCESS allocation services, Resource Provider resource usage reported back to the ACCESS accounting system, information related to members of the Computational Science Support Network (CSSN), and to other data collected by ACCESS in the course of meeting its program objectives.
Resource Provider sites and ACCESS partners may gather information by means other than the ACCESS infrastructure, and such information does not fall under this policy unless it is shared by partners with ACCESS. ACCESS may also share information with partners (as described in this document), but such information, once shared, no longer falls under this policy.
2 General Statement on Data Sharing and Privacy
The ACCESS program and most ACCESS-allocated resources are associated with public institutions and funded by a federal agency. As such, data collected by ACCESS and Resource Providers about the use of ACCESS infrastructure and ACCESS-allocated resources are presumed public and sharable, with some exceptions and with appropriate safeguards for user information. Due to integration of ACCESS services with a variety of Resource Providers and other partners, users should be aware that the privacy of usage data is limited as a practical matter. Foremost, ACCESS limits the amount of personally identifiable information that it requires of users. We require enough information to uniquely identify an individual and ensure the security of the infrastructure. Users are further encouraged to provide only publicly available contact information (work affiliation, email address, and phone number) instead of personal contact information. (Note, however, that falsifying user profile information violates ACCESS’s Acceptable Use Policy.) To the extent possible, ACCESS avoids collecting information that could be used for legal or financial harm. We optionally request, and encourage users to provide, a range of demographic information that helps ACCESS communicate the impact of the infrastructure to NSF and other stakeholders.
ACCESS does not sell user information to third parties. However, information collected by ACCESS may be shared publicly or with authorized third parties for open academic studies about the infrastructure, how it is used, its user community, and the impacts of the federal investment. The remainder of this document defines and clarifies this general policy statement with respect to key data sets collected within the ACCESS environment.
Personally Identifiable Information (PII): Information that might be used to uniquely identify an individual. The Personally Identifiable Information collected by ACCESS includes name, institutional affiliation, email address, and phone number.
Principal Investigator (PI): An ACCESS user who has received access to ACCESS-allocated resources as the lead on a request submitted and granted through the ACCESS allocations process. A PI may grant access to ACCESS-allocated resources to other users, whose usage will be charged to the PI’s allocation(s).
ACCESS: When used unqualified, this term refers to the common infrastructure operated by the various ACCESS Service Tracks, distinct from the infrastructure provided by ACCESS Resource Providers.
Resource Providers: Resource Providers are organizations independently funded to provide cyberinfrastructure services to the ACCESS community.
ACCESS-Allocated Resources: Resources provided by Resource Providers to the ACCESS Community and with access managed via the ACCESS allocations process.
ACCESS Community: The set of authorized users of ACCESS. The community includes users who may directly use an ACCESS-allocated resource, users who may use ACCESS-allocated resources through an ACCESS partner (e.g., through a science gateway interface), and users of any ACCESS services.
ACCESS Partners: Organizations that collaborate with ACCESS but are not governed under its policies. Examples include science gateways, peer programs such as the Open Science Grid (OSG), Resource Providers, and Globus.
Authorized Third Parties: In the context of this policy, persons or organizations who may be granted access to information that otherwise would not be shared under this policy. Authorization may be granted on legal grounds, such as through Freedom of Information Act (FOIA) requests, or as part of academic research studies approved by an Institutional Review Board (IRB).
4 Information ACCESS Collects
ACCESS collects and stores a wide range of data about users and their use of XSEDE services and ACCESS-allocated resources.
- User Profiles. User profiles contain Personally Identifiable Information (e.g., name, institutional affiliation, email address, and phone number) to establish the unique identity of individuals and maintain the ability to communicate with users.
- Access and Allocation Requests. ACCESS collects a range of information for the purposes of establishing eligibility and reviewing requests for access to various ACCESS resources..
- Usage Information. Information about access to and use of ACCESS services and ACCESS-allocated resources (e.g., system logs, resource accounting data) by individuals from the ACCESS community are recorded in order to measure resource use, improve operations, provide reports to stakeholders, and understand the value of the services and resources.
- Survey and Evaluation Data. ACCESS conducts regular surveys of the ACCESS community to assess and improve specific services and evaluate the overall success of the program. There are different ways of accessing ACCESS services and ACCESS-allocated resources, each of which involve different disclosure of personal information and different data sharing approaches. Details follow for each type of access.
4.1 User Profiles
Access to most ACCESS services as well as access to ACCESS-allocated resources requires a user to register for an ACCESS user account in the ACCESS User Portal. Information collected at registration includes name, affiliation(s), title, phone numbers, and email address.
4.2 Access and Allocation Requests
As part of submitting a request for access to ACCESS-allocated resources, the requester must voluntarily submit various information and documents in support of the request. Access to non-allocated resources and services (e.g., training courses) may also require users to provide additional registration information beyond that required to register for an ACCESS user account.
User information collected is mostly a subset of the information collected for an ACCESS user account. Users may choose not to supply elements of the requested information, but access to those resources and services may be restricted as a result.
4.3 Usage Information for ACCESS Services
Most ACCESS services have logging, monitoring, and/or instrumentation to track individual usage of these resources and services. Data collected by these service features is subject to this policy.
Data from anonymous use of the public ACCESS website and other services. ACCESS maintains public websites and other services, all or part of which allow for anonymous, public access. When one uses such services anonymously, ACCESS collects the information sent by the client (typically a web browser) and through the use of various technologies such as cookies. This information typically includes the user’s Internet address, type of web browser, operating system and, if the user was directed to an ACCESS website from another website, the address of that website.
Data from authenticated access to ACCESS portals and other services. ACCESS portals and other ACCESS services, including but not limited to training courses, ticket systems, user forums, and ACCESS allocation services require user authentication. When one uses these and other ACCESS services, ACCESS collects information about the user and logged by the service related to usage. This information typically includes the user’s Internet address, service capacity utilized, time and date of usage and so on.
User help requests. To support ACCESS users in achieving their objectives, ACCESS operates a ticket system for managing and tracking user help requests. ACCESS collects information about the user and their issue, which is logged in the ticket system. This information typically includes the user’s ACCESS username or email address, time and date of request, description of the issue, and exchanges between the user and ACCESS or Resource Provider support staff.
4.4 Usage Information for ACCESS-Allocated Resources
Most ACCESS-allocated resources have logging, monitoring, and accounting features or other instrumentation to track individual usage of these resources. ACCESS collects a subset of these usage data for allocations, accounting, and reporting purposes. Data collected by ACCESS via these service features is subject to this policy.
In the course of conducting allocated projects on ACCESS-allocated resources, users may place research data on those resources, either as part of submitting a computational job or through the use of data storage facilities. Aside from possible Resource Provider–reported aggregate accounting or monitoring data about the use of storage, ACCESS does not collect or read users’ research data.
4.5 Survey and Evaluation Data
ACCESS conducts a range of surveys to assess the program’s performance, plan for and evaluate the success of ACCESS events and services, gather feedback from the user community, and gather information from ACCESS staff about the working environment. These surveys are regularly analyzed, summarized, and reported on by ACCESS. The raw response data is governed by Institutional Review Board (IRB) protocols for human subject research and non-anonymized data is not shared. Data collected under IRB protocol are clearly marked as such, and require respondent review and consent of IRB-approved invitation letter prior to participation.
4.6 Data from Accessing ACCESS Through Partners
ACCESS services and ACCESS-allocated resources may be accessed through a number of partners, including Globus services, Science Gateways and peer grids (e.g., OSG). Users of these partner entities entrust certain information to the operators of these services. The protection of information collected by the operators is subject to their data privacy and protection rules and is solely the responsibility of those operators. When a user accesses ACCESS services or ACCESS-allocated resources via a partnering service, ACCESS may obtain personal information or attributes about the user from that entity, but only if that entity has the right to share the user information with ACCESS. Such data reported to ACCESS is subject to this policy.
4.7 GDPR Requests
GDPR requests should be submitted to the ACCESS ticketing system: https://support.access-ci.org/open-a-ticket with “GDPR Request” in the subject line. These requests will be evaluated by ACCESS.
5 How ACCESS Uses Collected Information
ACCESS uses the information it collects for the following purposes across the organization:
- To administer and manage ACCESS services and support Resource Providers in managing their resources.
- To communicate with users regarding ACCESS services.
- To provide the information and services that users request.
- To provide personalized content when users visit ACCESS websites or services.
- To improve ACCESS websites and services.
- To better market ACCESS products and services to the ACCESS community.
- To understand the value and impact of ACCESS services and ACCESS-allocated resources.
- To produce reports for NSF and other funding or advisory bodies.
- For any other purpose, which we disclose to users in a specific privacy notice.
6 Information ACCESS Shares
ACCESS shares some of the information it collects as part of demonstrating the stewardship of federal funds and to help assess the impact of the integrated cyberinfrastructure.
6.1 ACCESS User Profile
Profile information users set on the ACCESS User Portal—information beyond that required to create a portal account—is opt-in only. If one chooses to share certain fields in their registry privacy settings, these may be shared publicly if the user shares his/her public profile link.
6.2 Information about ACCESS Usage
For accounting and reporting purposes, ACCESS collects information about how its users utilize ACCESS services and ACCESS-allocated resources. Usage information about ACCESS-allocated resources is collected initially by individual Resource Providers and may also be stored by those providers.
Users should be aware that the privacy of these data is limited as a practical matter. These data are available to other members of the project to which the utilization is charged and, depending on the specific resource, may also be viewed or inferred by other users of that resource.
ACCESS routinely shares this usage information, typically in aggregate form but potentially unfiltered, with funding agencies and researchers. It is noted here that usage data is publicly available via the XDMoD portal.
6.3 Information about Allocation Awards
The existence of an award and basic information about the principal investigator (PI) and project (e.g., the size and duration of the award, on which resources the award is made, and the project abstract) are made public.
6.4 Information about Allocation Requests and Reviews
Information included in allocation requests is treated as private communications between the submitters and the ACCESS staff and committees that evaluate the proposals. This includes information about whether or not a proposal has been submitted for evaluation, identities of reviewers, and any reviewer comments associated with the request.
Data from allocation requests may be utilized by ACCESS staff or authorized third parties to study the allocations process and perform correlation with usage patterns and scientific success/productivity either for purposes of ACCESS or for reports to sponsors. In such cases, results will be anonymized and/or aggregated before being made public.
6.5 Information from a Partner
To assist in reporting to NSF, appropriate operation of services, and troubleshooting of services, ACCESS Operations requires Resource Providers (RP) to share coarse network data with ACCESS Operations. This includes aggregate and/or de-identified network data and utilization from that RP to other ACCESS sites. Also, the RP grants consent for the release of this relevant data from Internet2 to be shared with ACCESS Operations of network traffic to/from the RP.
If a partner (e.g., gateway operator, Resource Provider, PI, or campus champion) releases data to ACCESS, they must specify if it has privacy constraints and thus falls under this policy. All other data received is assumed public and may be used at the discretion of ACCESS.
7 With Whom ACCESS Shares Information
ACCESS does not sell user information; however, ACCESS does share some information publicly. As a project supported by a federal agency, most usage data about ACCESS services and for ACCESS-allocated resources is made public via the XDMoD Portal, though users can limit the amount of profile information that may be shared publicly.
ACCESS shares identifiable information with ACCESS Resource Providers to resolve system issues, perform accounting on ACCESS allocations, and resolve security incidents. ACCESS may also share some identifiable information as part of publicly available usage data describing allocations and use of ACCESS services or ACCESS-allocated resources.
7.1 Information Shared with Resource Providers
ACCESS routinely makes information about its users and their usage available to participating Resource Providers for purposes of securing, maintaining, and administering ACCESS-allocated resources. Information shared in this manner will then fall under the privacy policies of the Resource Provider sites rather than this policy. While this information is shared without obligation, it is expected these sites will treat such information for operational purposes in a manner generally in alignment with this policy.
7.2 Institutional Review Board Approval
ACCESS may permit access by a third party to non-anonymized data that is otherwise deemed private or confidential in this policy for research purposes. Such permission shall be contingent on approval from the third party’s Institutional Review Board. In such cases, results will be anonymized and/or aggregated before being made public.
7.3 Legal Requests
The ACCESS project office is associated with a public institution and funded by a federal agency. Therefore, ACCESS is subject to Freedom of Information Act (FOIA) requests and must respond to these as well as any other legitimate legal and regulatory requests.
8 Acceptance of This Policy
ACCESS will cooperate with partners in audits and investigations in the event of suspected breaches of this policy.