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Archiving the Covid-19 pandemic

Issues to consider: Personal data and sensitive content

You must be aware of any personal data you collect. In law, personal data includes:

  • Any information that could identify someone, such as a name, address, telephone number or email address
  • Any information that could be combined to identify a person, for example a job title or health history with a location

Personal data laws only apply to people who are currently alive. However in the context of the pandemic, it's sensible and respectful that you treat people who have recently died in the same way. Consider that identifying them will also mean their families are identifiable.

Closure Periods

Records containing personal data should have a closure period, unless you have permission to share them from the person concerned. Remember, that may not be the donor of the record, and more than one person's personal data might be included in a single item.

The National Archives advises a closure period that assumes a lifetime of 100 years. This can be graduated down from the age or assumed age of the individual in the record. For example, you might have a twenty-year old photograph of a named person who looks about 70 years old, meaning if still alive they would be about 90 years old currently. This may therefore have to be closed to public access in a further ten years.

Other sensitive data

Some data is still sensitive, even if it's not protected as personal data. This might include accounts of events which were distressing for the people involved, or other people's opinions that show them in an unflattering light.

Photographs of someone are not, on their own, personal data but they would be if they are named or have other identifying features on them.

Data protection law does not prevent the taking and publication of photos. However, it is always best practice to:

  • Seek permission from the subjects of photographs wherever you can
  • Avoid publishing photographs where the subjects are still likely to be under the age of 18 without explicit permission
  • Think about other possibilities - descriptions of other people's behaviour for instance