The government archive inquiry "From Here to Eternity" presented on December 18, 2019, is now out for referral. We have just submitted our referral response.
In 2017, the government decided on a review of the archive sector and issued directives for a new archive inquiry. It had then been 16 years since the archive sector last received a thorough review. A government archive inquiry began its work in December 2017, led by Lars Ilshammar, Deputy National Librarian at the Royal Library. More about the inquiry and how it carried out its assignment can be read at the Archive Inquiry's website.
Two years later, on December 18, 2019, the archive inquiry presented its results, titled "From Here to Eternity. A long-term archive policy for administration and cultural heritage" (SOU 2019:58). The entire report is available here (672 pages, pdf, 5MB).
The report is now out for referral - and as a business archive with over 45 years of operation, we at the Centre for Business History have just submitted our referral response. You can read it below.
Statement on the archive investigation "From Here to Eternity"
2020-06-01
Dnr: Ku2019/02112/KL
Ministry of Culture
The report SOU 2019:58, From Here to Eternity.
Summary and introductory comments
The Centre for Business History (CfN) has been given the opportunity to comment on the report presented by the archives inquiry.
CfN has followed the inquiry's work, we have been visited by the inquiry members, submitted input and in addition reviewed input and consultation responses from other institutions. In this response we have chosen to reply to the parts that directly concern our operations, chapters 10 and 11 of the inquiry.
We largely share the conclusions of the inquiry and the proposals presented. In some cases we feel perspectives are missing, for example the fact that archive institutions receiving archives in the form of deposits are data processors and not data controllers. We question the idea of a special support for center formations.
In a few places, we express criticism of the National Archives' current working methods regarding private archives. Based on the input to the inquiry, the National Archives’ proposal for handling personal data in private archives, and the agency’s statement on the archive inquiry’s report, it appears that the National Archives lack fundamental insight into how the private archive sector works. We also want to highlight that private archival work in many cases is both a way to work with, develop and present cultural heritage and simultaneously a business, creating new jobs for archivists, as well as other professional groups. Under current conditions, the National Archives can sometimes distort competition primarily by offering archive storage at prices far below the market elsewhere.
In the memorandum we submitted as input to the inquiry in April 2019, we described our own activities. For the sake of that operational description, we attach the mentioned memorandum to this response (PM_arkivutredningen_190412_final.pdf).
Bromma, June 1, 2020
Alexander Husebye, CEO
Krister Hillerud, Deputy CEO
Comments on the inquiry’s proposals
10.5.1 State grants to the private archive sector (p. 385)
CfN views positively the inquiry’s proposal to allocate an additional 20 million SEK annually to the private archive sector. Regarding the support for center formations of 5 million SEK, we find it difficult to see the benefit of such a targeted intervention. It would be more reasonable to add these 5 million SEK to the proposed 20 million, so that state subsidies to the individual regional and national archive institutions can instead amount to an additional 25 million SEK compared to today.
In any case, we are convinced that the additional funds proposed for the private sector are a good way to create a basic security for more private archive institutions. All actors within the sector, both at regional and national levels, small and large, run their operations with tight financial margins. Every annual budget relies on depositing members and clients not withdrawing their material and on a steady inflow of consultancy assignments. Added to this is the fact that archive operations require premises that meet certain basic requirements in terms of size, condition, and equipment. This means that fixed costs can be relatively high, while revenues may be uncertain. In many cases, grants and public funding must also be reapplied for each year.
Other reflections related to chapter 10
The inquiry expresses that the sustainability of the model based on financing through membership fees and deposit fees is decreasing. We are well aware that conditions vary greatly depending on geography and the type of archives that the operation focuses on. From CfN's perspective, however, we cannot see that this claim is true. Over the last 25 years, the amount of deposited archives has tripled and we currently handle around 80,000 shelf meters. We have also been able to charge fees that allow the operation to be conducted under this model, without grants or subsidies [1]. The model relies on continuous work to demonstrate to member companies the value of having access to a historical archive. CfN works purposefully to give concepts such as history marketing relevant content that encourages companies to actively work with their history as a resource both externally and in their ongoing internal culture building. CfN’s guiding principle is that the history told should be truthful and verifiable in the archives. Moreover, we have on several occasions successfully assisted our client companies in legal matters through our knowledge of which documents in the archives may constitute important evidence. The advantage we see with our working model is that companies thus consciously decide to work with their cultural heritage. Through the often close cooperation we have with member companies, we also ensure continuous archive formation, with new archive material being added continuously, which differs from one-off efforts. In some cases, member companies face austerity measures, which naturally can impact their ability to pay CfN. Often, we can then agree on what we call “hibernation,” meaning a temporary discount can be given or that other efforts except archive storage are significantly reduced. Overall, we think the inquiry fails to address the dynamic that arises when companies themselves actively want to work with their history.
Furthermore, CfN wishes to highlight here as a shortcoming that the inquiry does not address the discrepancy that the National Archives receive private archive collections from companies that are active and financially sustainable. This means that the state’s contribution to the private archive sector is actually already higher than what appears in the figures reported in the archive inquiry on pages 372 and 376. The extent of this activity is difficult to overview and should be investigated further to clarify how public funds are used to subsidize services sold at underpriced rates on a market that has potential to develop further through free actors in healthy competition. Moreover, this creates additional jobs, especially for archivists.
CfN has in input to the inquiry proposed that ownerless business archives should primarily be stored at private business archives with grants from the public. This is so the archive collections are kept in an environment where they are handled by staff with the appropriate education and experience, but also in a context that is beneficial for research. We maintain this position, which we are convinced applies to the whole private sector – archive institutions focused on association archives are best suited to handle those types of archives, etc.
The archive inquiry notes on page 391 that close and trusting cooperation between the National Archives and the private sector is important. Crucial for achieving this is that the National Archives’ role is refined to that of an agency tasked with supporting and coordinating, but that its ability to act in a market-distorting way is eliminated.
10.5.2 Advice, acquisition, and promotion (p. 389)
CfN supports the proposal and wishes to stress the importance that the National Archives’ role is limited to the measures listed on page 390.
11.7.1 New archive law regarding the private sector (p. 428)
CfN believes it is good that private archives are also defined as part of the cultural heritage. We see the proposal both as recognition of the great importance of private archives and as confirmation of the working methods applied at private archive institutions characterized by commitment, seriousness, and professionalism.
We note that grants to private archive institutions will not entail other obligations than that archive collections should be reported to NAD and, otherwise, that the use of archives should be made accessible and promoted. CfN’s organizational model means that the parent company is a non-profit association of which the depositing companies are members. The association’s charter states that its purpose is:
…to take care of, store, preserve, process, and present documents, images, and objects from companies, organizations, and private individuals related to business life, and – unless the depositor decides otherwise – make the collections available to depositors and other interested parties.
This along with the fact that CfN has reported its archive holdings to NAD should mean these requirements are met. However, it is important for a continued trusting relationship between CfN and its member companies that no demands are imposed that deposited material must be open to research unless the respective archive owner has given permission. In some cases, companies wish the entire deposit procedure to be kept confidential; in these cases, too, it is crucial that we can meet our customers’ demands.
11.7.2 Private archive institutions’ handling of personal data (p. 432)
CfN supports the assessment the inquiry makes. However, we want to emphasize that it does not cover the business model involving archive deposits operated by several private archive institutions. Prior to the implementation of the EU General Data Protection Regulation, CfN commissioned Setterwalls law firm to examine any consequences the regulation might have. The result briefly concluded that the operation could continue to be conducted according to already established frameworks. Further, it was found that CfN, in deposit arrangements, is the data processor and the depositing company the data controller. This, in turn, led to the deposit agreements being supplemented with data processor agreements. This perspective, that many private institutions are merely data processors, is completely missing. Instead, the inquiry appears to assume that private archive institutions are data controllers. For CfN, this applies to archives received as gifts, but this is a relatively small part of the operations.
Thus, we share the inquiry’s assessment regarding personal data in archive collections owned by private institutions, but we consider the issue not fully explored regarding archives that constitute deposits.
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[1] The presentation in the inquiry on pages 366-367 does not give a fair picture of the proportion of state grants to CfN. The association’s wholly owned subsidiary, Centre for Business History CfN AB, in which all business operations are conducted, does not receive any state grants at all. The Centre for Business History association has in recent years received between 250,000 and 300,000 SEK annually in state support. This corresponds to 8% of the association's annual turnover, but on a group basis around 0.5%.
