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docs: adds ADR 9. Personally Identifying Information #106

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77 changes: 77 additions & 0 deletions docs/decisions/0009_pii.rst
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9. Personally-identifying information (PII)
###########################################

Status
******

Accepted

Context
*******

The vast majority of event data processed by Aspects is anonymized to protect user privacy. Most events have an "actor",
and that actor is uniquely identified by an anonymous user ID.

But some of the community's analytics use cases call for the use of Personally Identifying Information (PII) that is
stored in Open edX. For example, to identify and intercede with learners that are struggling in a course, we need to see
the contact details for that learner. Or if we want to use use demographic data in recruitment campaigns to improve the
diversity of a student group, we need access to user profile fields like country, state, gender, and age group.

Storing and displaying PII must be done with care, so this document describes the steps needed to protect this data and
help institutions to use it responsibly.

Decision
********

**Opt-out of Aspects PII**

Operators can opt-out of storing and showing PII data from Open edX in Aspects.

If PII is enabled, Aspects will construct learner-specific dashboards, charts, and datasources.

Access to all event data in Aspects is restricted to users with a "staff" or "instructor" role on the course, and the
learner dashboards will also respect these restrictions.

**Removing PII after opting out**

If operators choose to opt-out of Aspects PII after deployment, they are responsible for removing the relevant PII
data, datasources, dashboards, and charts.

**Aspects supports user retirement**

Aspects will integrate with the user retirement pipeline (if it is enabled on the LMS) allowing users to retire their
user accounts and have their PII automatically removed from Aspects.

However, the retired user's event data will not be removed from Aspects, as they remain anonymized.

Consequences
************

#. Operators must opt-out of storing PII in Aspects by disabling the `ASPECTS_ENABLE_PII` configuration flag.
#. Operators who deploy Aspects with PII enabled then opt-out of storing PII can remove any PII from Aspects by clearing
the `EVENT_SINK_PII_MODELS` tables in Clickhouse.
#. Aspects will use the standard Open edX annotations for code that references PII.
#. User retirement events in the LMS will trigger removal of PII for retired users.
#. How-to documentation will be created for operators to manage PII.

Rejected Alternatives
*********************

**Don't use PII in Aspects**

Following the Open edX policy of storing and sharing the minimum personal data necessary, Aspects Instructor and
Operator dashboards do not use PII.

However the community use cases were too compelling to ignore, and so we were not able to keep PII out of Aspects.

**Opt-in to PII in Aspects**

Aspects v1 requirements include supporting learner-specific charts which are broadly popular among the community.
Additionally, Aspects is specifically designed to support small- to medium-sized Open edX deployments, and these are the
most likely to have higher individual learner interaction than large deployments with MOOCs do.

References
**********

- `OEP-30: PII Markup and Auditing <https://open-edx-proposals.readthedocs.io/en/latest/architectural-decisions/oep-0030-arch-pii-markup-and-auditing.html/>`_
- `Enabling the User Retirement Feature <https://edx.readthedocs.io/projects/edx-installing-configuring-and-running/en/latest/configuration/user_retire/index.html/>`_