Better the rudest work that tells a story or records a fact, than the richest without meaning.
John Ruskin Seven Lamps of Architecture (1849) ‘The Lamp of Memory’ sect. 7
Substitue “record” for “work”, and I think Ruskin himself could summarise the value that many historians, alumni, archivists and others place on the student records of former students of Ruskin College destroyed in the “Ruskin archive scandal” (see round-up of principal links to follow the story so far)
Perhaps the biggest divergence is the failure on both the part of the College and of the “stakeholders” (the historical research community, alumni and other concerned parties) is mutually to identify the College’s own records as being of archival value and then to identify a way in which to preserve these. The College seems to have fulfilled its business obligations to its alumni by digitising the core record (see JISC guidance) but not to have thought beyond this – or if it has, not to have communicated its decisions very well; the stakeholders have not made the case well enough in advance and in some cases to have confused what has been destroyed (student records but not the “Maccoll Seeger archives”/banners etc) sufficiently for their legitimate concerns to have been dismissed in a focus on the inaccuracies.
Whilst amazing things can be done to reconstruct shredded records (eg. the Stasi records) it seems fairly clear that many student records have been destroyed and are now irrecoverable – currently not clear exactly what/how much [I’m just formulating another FoI request to get clarity on this matter]. So what does this sorry episode teach us? I have some suggestions below.
Historians and other researchers
Get involved with the organisations and individuals whose records are your (or your successors’) sources. Contribute to – or create – documentation stategies (see the Olympics The Record as an example). Lobby for archives policies and resources to ensure the continued survival of records. For an organisation whose core business does not necessarily include maintaining an archive this may require deposit with an established record office. Participate in the development of sampling methodology where it is necessary to balance the preservation of some records against the massive resources required to preserve some records in their entirety (local government rate books being a case in point).
Subject/specialist networks and societies may be better placed to do this than individuals – but individuals will have a role to play too (and not just in signing petitions): be involved with the archive and libraries that you use frequently – participate in consultation on their revisions of acquisition policies, give them your feedback, join Friends and focus groups.
We think there is an interesting question, yes, as to whether the law is being consistently breached by many organisations and we welcome a national debate on this question. Personal abuse is not in the Ruskin style. By all means field robust arguments: that way, we all learn. [Ruskin College facebook response 24 October at 09:32]
I’m not sure there’s the need for a “national debate” actually. Educational organisations should take advantage of existing specialist sources of expertise rather than relying on general legal advice. For historic records and Data Protection it’s the Code of Practice – the link in full is http://www.nationalarchives.gov.uk/documents/information-management/dp-code-of-practice.pdf
Individual files, for example of student admissions (as the Ruskin situation seems to be), containing personal data collected by an organisation prior to the introduction of data protection legislation in the UK in 1984, are likely to be “category e” personal data under the current Act: recorded personal information that is not category a-d information (!) and is held by a public authority as defined by the FOI Acts. This category divides into two subcategories: relatively structured data, and unstructured data. The former is defined in the Code of Practice as “…data that is part of, or is intended to be part of, a set of information relating to individuals and that is structured by reference to individuals or by criteria relating to individuals but that does not have an internal structure or referencing system that would facilitate retrieval of specific information about particular individuals. An example would be a set of case files with a chronological arrangement of papers within each file and which was not otherwise indexed.” – student files are a perfect example of this.
The Code of Practice clearly lays out the way in which the DPA applies to these sorts of records, the exemptions, and the kind of access regime to enable historical research allowed by the DPA section 33 involving the records to take place. Get educated.
I think a better subject for “national debate” is organisations dealing with their records without reference to any policies, retention & disposal schedules and so on – for public authorities, this means acting directly against the advice in the FoI section 46 code of practice. Ruskin have clearly stated in response to my first FoI request that the College does not have a records management policy; at the time of writing (5/11/12) I am still awaiting the detailed retention guidance referred to in their “data protection policy”. The retrospective legal advice obtained from Eversheds (dated on the Ruskin website 21st October 2012, well after the preparations for the premises move during which the records destruction appears to have taken place) concerns the potential transfer of historic files to the Bishopsgate Institute rather than retention per se.
Records managers & archivists, including TNA and JISC
Still work to do on documentation and acquisition strategies, on communicating with the research community on the reasons and methodology for appraisal involving sampling (among other things), on encouraging the preservation of the national documentary heritage (the campaign for voluntary sector archives being a welcome recent example), and on promoting the availability of advice and guidance….