The 2018 GDPR Policy and Guidance document brought together thirty years of trial and error and working with communities.
"an impressive, human response to very dry legislation." (Email comment from child care archive colleague in Australia)
Processing Personal Data in Compliance with the General Data Protection Regulation and the Data Protection Act 2018, Policy and Guidance
3.5.2 The Archive approaches the minimisation of adverse impact on living individuals in two main ways. The first is the culture of the Archive itself, which is rooted in the principles and practice of planned environment therapy, and what Founding Trustee David Wills referred to as shared responsibility. It is characterised by an actively developed collegial relationship with researchers and other stakeholders, and in particular through close communication, engagement, consultation, involvement and participation of and with communities and individuals who are present directly and indirectly as data subjects in the collections. The resulting flow of information and understanding builds mutual trust and diminishes the potential for distress. It helps to ensure that The Archive is in touch with and made aware of issues and dynamics which can influence how data is better and more sensitively understood and processed by The Archive, and it helps to ensure that the necessary professional demands and boundaries of The Archive are trusted, understood and respected in turn. Given the sensitivities of much of the material in The Archive, and the very deep social, emotional and psychological vulnerabilities the collections evoke, contain and represent, this culture of mutual understanding, trust, knowledge and respect is an essential component in the task of mitigating data subject's distress and the potential for distress and damage for all involved, including The Archive itself.
3.5.3/8 The Archive understands the depths of vulnerabilities and traumatic experience that can be contained and represented in conventional and non-conventional archive materials, and understands that destruction and the prospect of destruction in itself can be a cause of serious distress.