To meet the requirements of Brazilian law, FGV is required to identify all people who use its data communication infrastructure to access the internet, whether they are its students, professors, employees or visitors. The principle of user identification, as instituted by FGV, is supported by the constitutional veto on anonymity enshrined at the end of article 5, IV, which establishes that “the expression of thought is free, but anonymity is forbidden.”

With respect to users’ privacy, this is one of the principles of internet use in Brazil and it is expressly protected by the Internet Civil Framework Law (Law 12,965 of April 23, 2014). Article 7 of this law states that among other rights, users have the inviolable right to their privacy and private life. They are assured of protection and compensation for material or emotional harm arising from the violation of this right. They also have the inviolable right to the confidentiality of their communications on the internet, except in the case of court orders, thereby strongly reinforcing users’ privacy on the internet.

Article 3 of the law also establishes, as a principle of internet use, protection for users’ personal details, such as their name, address, phone number, photos and any other data or metadata that could identify them. In addition, reinforcing protection for internet users’ records, personal data and private communications, article 10 explicitly states that the “storage and disclosure of internet application connection and access records governed by this Law, as well as private data and the content of private communications, must preserve the privacy, private life, honor and image of the parties directly or indirectly involved.”

Another notable point in the Internet Civil Framework Law is the requirement for internet providers to store connection records. Article 13 of the law states that “in the provision of internet connections, the respective autonomous system administrator must keep confidential connection records, in a controlled and secure environment, for one (1) year, in accordance with the rules.”

Thus, aware that internet access is essential to the exercise of citizenship, and knowing of internet users’ inviolable right to privacy and private life, FGV clarifies that its policy on the privacy of students’ data and the confidentiality of their information fully complies with the provisions of the Internet Civil Framework Law.

Accordingly, FGV does not have, and never will have, the following objectives:

• To store any of students’ personal details passing through FGV’s infrastructure during their internet access sessions.
• To analyze individual internet usage through FGV’s infrastructure.
• To share our students’ internet usage profiles with any person or institution, except when obliged to by a court order.
• To monitor students’ internet use, except to guarantee that FGV’s computing environment is following Brazilian laws and, if necessary, to take measures to tackle abuse.