name, email, campus ID, etc. • Persistent pseudonymous identi fi ers (PPIs) • 24601, No. 6, 007, 8675309, 7 of 9, Eleven… • You know who (some of) those are, right? Yeah. Given a PPI, The Content Vendor can likely figure out who Dr. Owl is too. Behavioral tracking and web bugs are all it takes! • SeamlessAccess calls PPIs “anonymous.” This is flat wrong. • Non-PII/PPI metadata: “entitlement metadata” • “This person is tenured faculty in the Ornithology department with courtesy appointments in Philosophy, Religion, and Folklore.” • Given enough of this, and/or combining it with web-bug and behavioral data, The Content Vendor can absolutely reidentify Dr. Owl. First let’s ask what patron metadata even is there? Well, there’s standard P-I-I, like name and email address and campus identi fi ers. Then there’s what I’m calling persistent pseudonymous identi fi ers, like a number that’s consistently used over time to identify a given patron without using their actual name. So like, 2-4-6-0-1, Number Six, the immortal double-oh seven, and so on . You know who at least some of those numbers are, right? Yeah, so this isn’t really privacy protecting. Given a persistent pseudonymous identi fi er, The Content Vendor can easily use behavioral tracking and web bugs to tie that identi fi er to Dr. Owl. SeamlessAccess calls these identi fi ers “anonymous” and I am really angry about that because words mean things and PPIs are not anonymous. Deidenti fi ed, yeah. Anonymous, absolutely not . Anyway, so. Third kind of metadata is often called entitlement metadata, and it’s not about your identity, it’s a list of campus groups you belong to. So for Dr. Owl that might look like, they’re faculty, they’re tenured, they’re in the Ornithology department, and they’ve got courtesy appointments elsewhere. If Dr. Owl is the only tenured faculty member with this speci fi c collection of appointments — well, they’ve basically been immediately reidenti fi ed. They’re not anonymous to The Content Vendor at all.