GDPR and US archives?

[Barb Morley]

Hi there,

 

I’m curious about the implications for US archives of the EU’s General Data Protection Regulations defining proper handling and protection of EU personal data. We don’t do mass data collecting, tracking, or processing of personal information and the regulations are clearly targeting these activities, but do archives have practices that might be in conflict with the regulations?

 

At first blush I’m thinking about our ‘permanent’ FMP database of research requests including contact information and research interests, we have security cameras (with signs and verbal warning that they’re in use), and we publish documents and identify individuals in images in public portals. These might be small potatoes but, are they potatoes?

 

Thanks!

Barb

[Hand, Sarit]

Hi,

 

Am working on researching this.

 

I just found this https://interparestrust.com/2017/06/13/how-does-the-eu-gdpr-affect-archives/ which is really referencing this white paper https://interparestrust.org/assets/public/dissemination/Archivar2_2017_Taylor.pdf

I have not finished reading it yet, scroll down, it is translated.  I do know that our vendor for digital preservation has already taken steps to manage this issue; they happen to be UK-based.  Am still researching and since we are a corporate archive will be working with our legal team.

 

Please keep posting any information regarding this.

Thanks

 

Cheers,

Sarit Hand Digital Archivist AP Corporate Archives sh...@ap.org www.ap.org		200 Liberty Street New York, NY 10281 T 212.621.7035 F 212.621.1723

 

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[Jenny Swadosh]

Please share findings!

I am especially interested in terms of universities and colleges that are "Google Schools." Institutional e-mail accounts, document sharing, calendars, etc. all running off of Google products.

Also archiving social media.

Thanks,

Jenny

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Jenny Swadosh

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[Marie Lascu]

Yes, I second the request to share your findings! Thank you!

Best,

Marie

[Hand, Sarit]

I am hoping everyone on this list will share info!

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Jenny Swadosh

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[David Kay, MLS]

Hi everyone,

Thanks for bringing this to our attention. . . i did a little reading on this from Sarit's links, but I need more time to mull and evaluate.  I did read through Recital 156 about processing personal data, and there are a few new terms that could be a good starting point for understanding how the EU GDPR is looking to protect personally identifiable information.  It may not affect our institutions yet, but these are issues that Google, Facebook, Amazon, Apple, Microsoft, etc,. are going to begin redefining soon.

The terms that struck me are:

Data Minimisation
Data Portability
Limitation of Processing 
Data Protection Guarantee
Privileged Purposes
Pseudonymisation 
Anonymisation

I'm particularly interested in this idea of "the principle of data minimsation", especially since they are allowing for PII data to be used for "archiving purposes," but with respect for the right to be forgotten.

http://www.privacy-regulation.eu/en/recital-156-GDPR.htm

I guess it remains to be seen if there is a "right to be forgotten" in this country. . . .  

Anyone else want to chime or help us define those terms and understand these restrictions?  It goes into effect tomorrow.

dk

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Jenny Swadosh

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