Archives and GDPR

Not another GDPR training event I hear you say!  But this one was different; it focused purely on the archive activities of an organisation (not the operational side) and the relevant exemptions for that activity, then how archives were actually putting it into practise in reality.

The main presentation was thanks to The National Archives with Susan Healy and Kevin Mulley giving a whistlestop guide through articles, recitals and safeguards….  The key term was “Archiving Purposes in the Public Interest” helpfully abbreviated to the cheerful sounding “APIPI”

They aimed to reassure pointing out that:

  • archives were not the main “target” of GDPR
  • it is an evolution not a revolution
  • many of the requirements are already embedded in our ethical practise
  • The ICO Commissioner was once an archivist herself and therefore understands!
  • And TNA has produced a helpful guide available here to help.

The importance of documenting your decisions rang through the day, repeated by every speaker and to think in GDPR terminology to articulate your thoughts.

It was slightly bizarre to discover that special category data is actually simpler to handle than standard personal data in archiving terms as there is an explicit provision for APIPI in the articles.  Very strange!

The actual usefulness of GDPR was also noted as a way to show the importance of cataloguing in order to be compliant about making it easier for a data subject to find out what data you have about them.

It was fantastic to hear from Stefanie Davidson from the West Yorkshire Archives Service about how she has handled GDPR in a real life (extremely complicated) situation and her tips and also her remaining questions.  It is also reassuring to hear that even someone who clearly knows so much about the subject is still amending and developing her paperwork and guidance documents.  She made GDPR entertaining – which everyone would agree is quite a challenge….

We also heard from James Courthold from the British Library about the problems with GDPR and oral history.  His major take home message was “don’t use consent as your lawful basis!”  He also recommended planning time and budget into your project for DP issues including initial assessments and sensitivity reviews after your recordings.

The day left me thinking about how many of my archives do cover living people (or assumed to be living if less than 100 years old and I don’t know otherwise) and the need for more documentation from those donors.  Some popular archive material relating to the 1984/5 strike will need to be re-evaluated not just for the donor’s personal data but for the personal data relating to other living people which may be contained within the files.

Thanks to the North East Archives Partnership and The National Archives for providing this event free of charge.

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