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.