PRIVACY_NOTICE.md

PRIVACY_NOTICE

Purpose

This benchmark package may include or reference document images, cropped images, transcriptions, and metadata used solely for OCR evaluation and benchmarking.

Privacy rule for inclusion

Documents containing personal data may be included in the benchmark only if at least one of the following is true:

1. the document has been effectively anonymized so that the relevant person is no longer identified or identifiable in the benchmark asset made available; or
2. there is a clear and documented legal basis for public disclosure and redistribution of the relevant benchmark asset.

If neither condition is met, the document must not be redistributed as part of the public benchmark package.

Minimum review before publication

Before a document is included in the benchmark package, Dharma-AI should confirm and record:

• source URL and source organization;
• document type and context of publication;
• whether the source document is publicly accessible;
• whether the benchmark asset reproduces personal data;
• whether the personal data include any higher-risk categories;
• whether anonymization has been performed and validated; and
• the final release decision in SOURCES_LEGAL.md.

Examples of personal data to review

The review should look for, at minimum:

• names linked to identifiable persons;
• CPF, RG, OAB, passport, or similar identifiers;
• signatures;
• addresses, e-mails, phone numbers;
• photographs or biometrics;
• financial or employment information;
• medical or other specially protected information; and
• combinations of fields that make re-identification reasonably possible.

Anonymization standard

Anonymization should be applied to the benchmark asset actually released, not only to internal copies. Depending on the case, this may require:

• redaction or masking in the image/PDF;
• removal of identifying metadata;
• exclusion of specific pages or regions; or
• release of transcription-only or metadata-only variants.

If effective anonymization cannot be achieved without undermining legal or privacy requirements, the item should not be publicly redistributed.

Public official documents

Even where a source document is publicly accessible or may qualify as an official act for copyright purposes, that does not automatically eliminate privacy review. Public availability alone is not a blanket authorization to redistribute benchmark-ready copies in a machine-readable package.

Redistribution fallback

Where there is uncertainty about privacy or redistribution rights, the default fallback is:

• publish the benchmark framework, metrics, and metadata;
• retain only links, hashes, or identifiers for the underlying source; and
• withhold the original image/PDF/transcription from the public package.

Contact and review

Questions about whether a source may be included should be escalated to legal review before publication.