Assessment for online access

We make selected material available online through a variety of platforms, including the Wellcome Collection website and third party platforms such as YouTube. We aim as far as possible to identify high-risk material prior to online publication by assessing all material due to be made available online. We will only make material available online if it is classed as open or if it can be redacted so that all sensitive information is removed from the online version.

In addition, we will only make open material under 10 years old available online where it is accompanied by permission from the body whose sensitive information features in the material (i.e. permission from the individual where personal data is concerned, or permission from an organisation where business sensitive information is concerned) or it has been made public as a result of steps deliberately taken by the individual or organisation.

This is because we recognise that material may acquire sensitivity if made available world-wide via online access, especially very recently created material. Most of the creators of (or individuals mentioned in) such material, especially our archive collections, have had no say in the placing of their personal information in the Wellcome Collection in this way and no reasonable expectation that it would be placed in the public domain within such a short period. Online access to such recent open material increases the risk that it may be processed in such a way as to cause damage or distress to the individuals and organisations concerned. This is particularly the case with born-digital materials or those subjected to Optical Character Recognition (OCR) technology that are searchable by keyword.

Our pre-online assessment procedure is supplemented by a takedown policy (see Appendix 9.4). The basis on which we are allowed to transfer personal data outside the European Economic Area by making it accessible online is explained in Appendix 9.2. Decisions to make material available online are also subject to copyright and licensing considerations.

Risk assessment for material without permission for online access

Risk assessment overview

The Risk Assessor should have good knowledge of the material content and basic information on key people represented in it (i.e. whether they are alive or dead, or whether their religious/political views or health problems are already well known), as well as familiarity with the cataloguing software.

We assess material already classed as open against the following criteria to judge the appropriate risk category (A Low, B Medium or C High):

• The age of the material

• Whether the material relates to living individuals, directly identifiable, or likely to be indirectly identifiable

• How the information is structured (e.g. arranged alphabetically by name) and whether it contains homogenous or mixed content

• The level of detail in the catalogue record description

• Whether the nature of the material would cause substantial damage or distress to individuals (or their close family members e.g. siblings, children)

• Whether the nature of the material would cause substantial damage to an organisation

• Whether the information was provided on the understanding that it would be kept confidential

• Whether the material is published or unpublished

The risk category determines the sample size to be examined.

Risk category	General nature of records	Sample to examine
A (Low)	Material is 100 years old or more No living individuals No risk of damage or distress to close family members of individuals mentioned Very low risk of damage to an organisation’s reputational or revenue Published	0%
B (Medium)	Material is 50-100 years old Some living individuals Little risk of damage or distress to individuals or their close family members Low risk of damage to an organisation’s reputational or revenue	Up to 100% depending on the nature and extent of the specific material
C (High)	Material is less than 50 years old Some living individuals Potential damage or distress to individuals or their close family members Potential damage to an organisation’s reputational or revenue	50-100% depending on the nature and extent of the specific material

The size of the sample for risk categories B and C is flexible to take into account the size and nature of the specific material e.g. we check 100% of category B material which comprises 2 files and is ambiguously catalogued, but may check only 75% of a category C series which comprises 20 files and is catalogued in detail.

If 5% or more of the material turns contains sensitive data, we will check additional samples from the same material:

Risk category	Initial sample size	Additional sample(s) to examine
B	Up to 50%	(1) Additional 25%* of material (2) If the additional 25% sample also contains sensitive material, examine remainder of material *If it is not feasible to separate out an additional 25% sample because the material contains too few files, we will simply check the remainder of the material
B	50% or more	Remainder of material
C	50% or more	Remainder of material

The criteria we use when identifying sensitive data is covered in detail in Section 3. We look for personal data, special category personal data, business sensitive information, data that could cause damage or distress to close family and cultural sensitivities.

For material deemed suitable for online access we consider the need for content warning statements prior to viewing. These are used to warn viewers about content they may find distressing or offensive. See Section X for more details. Community guidelines also may preclude us from disseminating certain content through third-party platforms.

The risk assessment workflow can be summarised in the following flowchart:

Fig.X Overview of risk assessment procedure/ to insert a graph here Fig3