At what point, I wonder, do the derogations and dispensations granted to archives to process personal data and special category personal data under the 'archiving purposes in the public interest' and/or the 'historical research purposes in the public interest' provisions of GDPR (Article 89; Recital 156; Recital 158; Recital 160) begin to fade away?
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In their responses to "Frequently Asked Questions" in the 'Archives Closure Strategy_External_v3' document circulated on January 7, 2026, Dave Roberts and Mike Staines of the Mulberry Bush noted that "The archive is big! The 500 plus of collections...", and Dave spoke in an email on March 30th of "almost 600 collections".
The latest spreadsheet showing where collections have been rehomed lists only 116. There may have been some compression or archives shy of publicising that they have taken a collection, but on its face this suggests there may be as many as 400 or more collections not accounted for.
The spreadsheet itself is a basic step in meeting their undertaking in the 'Archives Closure Strategy' circulated on January 7th to "share via our website and on request a list of what has gone where, based on the current archive catalogue."; or, in even more detail, in the version of the 'Strategy' updated on February 26th and circulated on March 13th:
We will share via our website, or other suitable platform, a 'map’ or ‘signposting list’ of what has gone where, based on the current archive catalogue. An academic historian has started work on this. We hope that this can be an open, collaborative ongoing project, to which things can be added in the future by a community. We plan to discuss where and how this is hosted with other organisations and stakeholders.
With an academic historian working on it, and ongoing collaboration to develop a community, this indicates that something more than a simple spreadsheet is in mind.
In my chapter on 'Is a Sustainable Centre for the History and Heritage of Therapeutic Environments Possible?" (here), published on February 11th, I tried to imagine a virtual project something along these lines, and what it would entail:
It might be possible to maintain some coherence and integrity through virtual means, if the resources were there and there were people employed to develop the possibilities of a virtual ecosystem, tied to the dispersed and distributed diaspora of the collections. That would be to create an all-new ecosystem, which would be fascinating and pioneering, if done well and with vision, and could be immensely impactful, if done well and with vision and was sustainable.
Whatever the Mulberry Bush has in mind - and it would be interesting to see it more fleshed out - it will involve a lot of creative work, and resources.
A key of success will be granularity of information. A researcher trying to piece things together will need to know more than the bare fact of where an archive collection has gone. They will need to know what is (or was) in the collection. Marjorie Franklin has gone to the British Psychoanalytical Society, for example, but what is in Marjorie Franklin? And when the British Psychoanalytical Society's catalogue is finally completed, will it be detailed and available online, in a way which can help the researcher connect the dots to the information they need, and to associated collections, once held together, now held elsewhere? Or will it be included in a central online database maintained by the Mulberry Bush Organisation, alone or in partnership with others?
Multiply this question by 116 collections - or 500 or "almost 600".
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As it stands, 14 of the 116 collections listed on the spreadsheet - about 13% - have no other home, and so will be going into "MB storage until a way forward found."
It's "MB storage" because that is where the Mulberry Bush archives have gone, and can be included in the Mulberry Bush's membership plan with the National Conservation Service in its storage facilities in Gloucestershire: in a commercial-with-a-charity-twist partnership between the National Conservation Service and Restore, a company which provides "mission critical services that protect and manage valuable data, information, and assets".
The NCS storage facilities started life as steel hangers on the former American Air Force base at Upper Heyford which, in the 1970s, "were encased in over 600mm (2 feet) of a special recipe super-hardened concrete using granite shipped from Cornwall [because] [t]he base was used for nuclear armed F1-11 fighter bombers." Temperature and humidity are impeccably maintained, the archives and the facilities expertly looked after. It is where the Planned Environment Therapy Trust Archive and Study Centre collections would have gone, had they not been transferred to the Mulberry Bush Organisation at the end of 2018 instead [as described here].
Not only that, but this swathe of extra secure storage hangars "on an already secure air field site, has a double perimeter, razor-wire fence around it and a watch-tower at its heart" (ref). There is a guard at the front gate, and when I visited in 2018 I had to park and wait for confirmation that I was expected, before I got permission to proceed through the base. It's an exciting place to be. To add to the sense of security, there was an active police training centre on the way. The NCS staff were fantastic.
The storage will cost money, however, and it is not exactly cheap. Nor is it inexpensive to retrieve material to work on or make available. The MB3 Archive staff were made redundant at the end of May. So who will carry out the complex task of finding a "way forward"? If no way is found "forward" quickly, how long will the Mulberry Bush be prepared to bear the cost and the responsibility for collections it has no other investment in? What will happen to those collections then?
