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2025 - November and December - page 33

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Issue number 404
ISSN 2632-7171
Publication date 1st November 2025
Transcription Industry News
magazine
“Never Again” Meets “Right to be Forgotten”:
Archives, Accountability and the Legacy of Privacy
The recent BBC report on
Weleda’s investigation into its
alleged links to Nazi-era human
experimentation reminded me
of the vital role archives play in
confronting uncomfortable truths.
A key area where archives ask
for the support of Naomi Korn
Associates is how to balance the
need to preserve historical records
with modern data protection laws
like the GDPR?
The Irony of Protection
There’s a deep irony here: laws born
from the horrors of the 20th century
designed to protect individuals from
state overreach could, if misapplied,
be used to erase the very records
that could contain evidence of that
history. This is why archivists and
data protection officers must work
together to balance protection and
preservation.
GDPR and the Paradox of Privacy
GDPR enshrines the right to
privacy and, notably, the “right to be
forgotten.” But data protection law
provides exemptions for archiving
in the public interest, scientific or
historical research and statistical
purposes provided appropriate
safeguards are in place. Archiving is
one of the few areas where the law
recognises that some data must be
retained, even if it includes personal
or sensitive information, because
its historical value outweighs the
privacy implications.
Transparency Through Access
Weleda’s decision to grant full access
to its archives for independent
research is commendable.
Corporate archives understand
that transparency is not just a legal
obligation, it can be a moral one and
important for the future of their
business.
Further Help
We understand the immense
pressure that comes with ensuring
compliance and navigating the
complexities of data protection
regulations. That’s why Naomi
Korn Associates has created a
dedicated help desk to provide you
with the support you need. Further
information can be found here.
Want to learn more?
Visit our training webpage to find
courses that will provide practical
skills and confidence in managing
personal data within your archive,
museum or library collection or
contact us at info@naomikorn.com
now for further information and to
join the 2026 waitlist.
Unlock More of Your Collections
Apart from copyright, the digitisation
and publication of important
collection items such as letters,
diaries and oral histories by archival
and museum services can present
challenges in balancing access with
data protection and privacy rights.
The UK General Data Protection
Regulation and associated legislation,
such as the Data Use and Access
Act 2025, recognise the importance
of archives and the materials they
contain. There are various ways
to ensure compliance with these
laws, while still achieving the aims
of an archival or museum service.
One effective way to enable access,
while safeguarding privacy, is
through redaction. By redacting
personal data, institutions can
protect individual privacy, meet legal
obligations and open up collections
that might otherwise remain closed.
Redaction is not about limiting
access - it’s about enabling it
responsibly. Many collection items
can contain personal data that, if
shared without care, could breach
data protection laws or cause harm
or distress. Personal data can include
names, addresses, medical details
and sensitive content related to
race, religion or political beliefs.
Redaction of personal data ensures
that materials can be accessed
while protecting the privacy of data
subjects.
There are providers who offer fast,
intelligent processing of personal
data that can help archival and
museum services make valuable
materials available. This is a practical
solution that empowers archival
and museum services to share more,
not less. Naomi Korn Associates has
also launched a service specifically
tailored for the heritage sector,
enabling the redaction of personal
data so that materials can be
accessed while protecting the
privacy of data subjects. If your
organisation is looking to make more
of its collections accessible, while
staying compliant, this redaction
software could be one part of your
digitisation strategy. Please contact
info@naomikorn.com for more
information.
Jess Pembroke
Director of Information Law Services,
Naomi Korn Associates
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