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In AtoM 2.2 and 2.3, PREMIS rights can be made "actionable" - e.g. they can be used to restrict access to linked digital objects. When you do this, an administrator can add a public access statement that is shown in the place of the digital object's reference display copy:
More information: https://www.accesstomemory.org/en/docs/2.3/user-manual/add-edit-content/rights/#rights-digital-object
Other than that, using the existing fields ("Restrictions on access" in RAD; "Conditions governing access" in ISAD) to associate a note about access with the description is probably the best workaround.
Cheers,
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