Direct Advocacy and Public Policy Consultations

The DPC Board has adopted a set of principles for the DPC's engagement with public policy and direct advocacy.  It lays out in clear terms the values of the coalition and how and when the Coalition will intervene in public policy matters. 

The full text of the policy is available to download [PDF 332KB].

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DPC Response to EU Science Information Policy Consultation

The DPC has responded to a consultation from the EC regarding science information policy, noting that the impacts sought from improved access to scientific information are only viable where sufficient attention is paid to preservation. 

Preservation has a particular importance for scientific information because meaningful innovation is necessarily responsive previous generations of research. In that sense, preservation of appropriate research outputs is essential to all sciences, especially for unrepeatable experiments or unique moments of discovery. Aspirations about access to information are meaningless without commensurate actions that to ensure preservation. We welcome all actions that will encourage a dialogue between and within member states to ensure the preservation of scientific information and we call on the EU to engage in that dialogue as a matter of urgency, using existing examples of best practice to help build capacity.

Read the original consultation from the EC

See the full text of the DPC response.

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DPC Response to Legal Deposit Consultation

DPC Response to Second Consultation on Legal Deposit (December 2010)

The DPC has responded to the second phase of consultation on Electronic Legal Deposit noting the essential relationship between preservation and access. We note and welcome the proposal that extend legal deposit to include charged content as well as content to which access is restricted. This will create the conditions where a more rounded and more valuable national archive can be created.

Experience in digital preservation shows that normalization and adherence to standards in the creation of digital resources are advantageous to long term access. Therefore we have some questions pertaining to the practicality of provisions regarding deposit of materials, in particular those regulations that leave the medium and quality of electronic deposits at the discretion of publishers, and those regulations that pertain to adapting content for preservation. If poorly implemented, these provisions could have the inadvertent result of making preservation intractable or excessively complicated.

We recognise that recommendations from the DPC are best focussed on those topics where we can offer specialist commentary. Therefore it is not our intention to provide a detailed scrutiny of each element of these regulations. However it is our view that preservation is only sensible within the context of access, and that preservation should be configured around the impact that comes with access. Therefore we have commented on a small number of access issues that we believe have a bearing on the case for preservation.

In January 2010 the Department for Culture Media and Sport (DCMS) consulted on draft regulations for the legal deposit of ‘free of charge’ electronic publications – the ‘free web’.  This consultation was intended to be the first part of a two part process and the DPC responded arguing inter alia that the second phase of proposals be presented without delay as arguably the ‘paid web’ includes material of lasting value and that until regulations were introduced this element of our collected digital memory would be at risk. 

 In September DCMS published a paper for the second phase of the consultation process.  The regulations discussed this time apply to a much broader range of material including publications for which there is a charge, publications which are subject to access restrictions and material compiled by queries from databases.  It excludes sound and film recordings and unpublished material.

Details of this consultation are available online at: http://www.culture.gov.uk/images/publications/Cons-non-print-legal-deposit-2011.pdf 

The draft regulations to which the consultation applies are online at: http://www.culture.gov.uk/images/publications/draft-regulations-legaldeposit-nonprint-publications.pdf

Full text of the DPC response is available here. [pdf, 340KB]

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DPC Response to Public Records Review

The DPC has responded to the consultation on the Public records review, welcoming the explicit statement that digitized and ‘born digital’ materials constitute a public record, noting and supporting the focus on informational content and the consequent need for ‘technology proofing’ and the management of formats.  The DPC has offered its assistance in identifying and resolving issues that may arise.

Research shows that clear advice about the preservation of digital materials is both in high demand and can be difficult to procure, so we note the new role for the Keepr of the Public Record to advise and inspect archives.  The DPC has offered its help in two ways: to assist the Keeper in the production of specialist advice notes; and to support the Keeper in the wider dissemination of advice to a diverse audience that is hungry for solutions.

 'This represents an opportunity to build capacity for digital preservation in a diverse range of authorities' explained William Kilbride, Executive Director of the DPC.

Full text of the DPC response to the consultation.

Full text of the consultation

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DPC Response to Review of Exceptions

The DPC has published its response to the recent Intellectual Property Office consultation on exceptions to copyright law with a detailed discussion of how these proposals impact on digital preservation. 

In summary, the DPC warmly welcomes the proposal to permit multiple copies to be created for preservation purposes. It notes and welcomes the proposal to broaden the types of content that can qualify for this exception and welcomes the proposal that extends this exception to a wider range of institutions.

The DPC seeks a number of clarifications to ensure that perfectly reasonable preservation actions are not inadvertently inhibited. For example the Coalition want to ensure that institutions are not prevented from collaborative preservation and is concerned that attempting to restrict preservation copying to an institution’s permanent collection may interfere with perfectly laudable and reasonable rescue and appraisal efforts.

The original consultation is online here from the Intellectual Property Office.

See the full text of our response here. [PDF 430KB]

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DPC Response to First Consultation on Legal Deposit (March 2010)

The DPC has published its response to the recent consultation from the Department for Culture Media and Sport on 'UK Online Publications'. 

The DPC has welcomed the progress which has been made by the Legal Deposit Advisory Panel on recommendations for collecting digital material and is eager that the momentum recently achieved is maintained so that continuing progress can be made. It warmly welcomes the proposal for regulation-based harvesting and calls for early implementation of this proposal, offering the assistance of the DPC in capacity building for staff and tools which this will necessitate. 

There is a range of opinions within the DPC's membership regarding the access provisions within the Proposals. The position of the DPC itself, however, remains clear that future access to the harvested materials at any level will be impossible without the safeguards that rigorous attention to preservation provides.

The original consultation document is online at: http://www.culture.gov.uk/reference_library/consultations/6506.aspx

Click here to read the DPC's full response [pdf, 385kb].

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National Heritage Science Strategy

National Heritage Science Strategy Consultation

The House of Lords Science and Technology Committee inquiry on Science and Heritage called for the production of a new National Heritage Science Strategy, a task that is now being taken forward by the National Heritage Science Strategy Steering Group.  Work has progressed in four packages: at the time of writing 3 reports have been released for consultation and a fourth document - the strategy iteslf is in development.

The DPC has responded to this consultation observing that digital resources constitute a heritage which is worthy of preservation, and that developments in heritage science in relation to digital heritage will be better served where they are aligned with existing and forthcoming initiatives.

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DPC Response to Digital Britain: The Interim Report

DPC promotes long term access in Digital Britain.

Full DPC Response to Digital Britain: The Interim Report (March 2009)

Introduction

  1. The Digital Preservation Coalition (DPC) is a not-for profit membership organisation whose primary objective is to raise awareness of the importance of the preservation of digital material and the attendant strategic, cultural and technological issues. It acts as an enabling and agenda-setting body within the digital preservation world and works to meet this objective through a number of high level goals. Its vision is to make our digital memory accessible tomorrow.
  2. The Digital Preservation Coalition welcomes the opportunity to comment on the Digital Britain Interim Report.  We seek opportunities to work more closely with the Digital Britain team in refining and delivering the digital strategy that their Interim Report delineates.
  3. We support the broad conclusions of the Interim Report in identifying the essential architecture of the government’s digital strategy.  In particular we note the considerable contribution that production and re-use of digital content makes to the British economy. We are encouraged in our response by the Government’s previously stated view that the contribution of the creative industries to the UK economy must move from the margins to the mainstream of economic policy.
  4. In summary, our response is to call for greater clarity and consideration of digital legacy, especially where this pertains to content.  This can be achieved through greater collaboration between the producers of content and those memory institutions – principally but not exclusively data services, archives, museums and libraries – charged with curating and preserving this generation’s digital legacy.
  5. It is our contention that appropriate consideration of the long-term of digital content will deliver long-term competitive advantage into the UK economy.
  6. We seek opportunities for knowledge transfer between those who already have skills in the long term curation and preservation of digital content (such as the DPC membership) and the creative industries producing new content.

Digital networks

1. We note and welcome attention paid to the development of a new generation of network infrastructure for the UK.  The extension and embedding of high capacity networks for home and business are as essential to the development of the economy.

2. The value of high quality digital content will increase as access to it becomes easier. The transformation of network capacity implies a concomitant growth in the consumption creation and re-use of digital content.  This presents an opportunity and challenge for the long-term.

3. The proliferation of new content suppliers means that the UK will need to be more sophisticated and more widely skilled in the curation and preservation of digital content if it is to have a lasting impact on the economy.  So, in parallel with the expansion of the network, the UK requires to build capacity for preservation and curation of digital content.

4. This can in part be achieved through refinement and planned investment in the skills and resources required to preserve digital content. We believe that this represents an opportunity for knowledge transfer from DPC members to the creators of digital content.

5. We note that paradigm shifts in broadcasting have historically been moments of unplanned loss of content.  We call for broadcasters to examine the risks to content in their planning for migration to new platforms.

Digital Content

6. We note and welcome the attention paid to issues surrounding digital content, especially the discussions about the creation of digital content.

7. We note, in the words of the Blue Ribbon Task force on Sustainable Digital Preservation and Access , that ‘access to data tomorrow requires decisions concerning preservation today’ (2008, 1).

8. Experience shows that preservation and curation of digital content is facilitated by early intervention.  Dependable access can to some extent be built in at the point of creation, while digital archaeology is expensive and impractical on the large scale.  In short digital legacy planning ought to become business as usual.

9. We believe that there is an opportunity for meaningful knowledge transfer between DPC members and the creators of content to enhance the durability of their content.

10. The effective exploitation of intellectual property happens over decades not years.  Consequently, we believe the report’s ambitions to provide greater clarity for intellectual property management needs to be positioned in a framework where the content remains fit for purpose over decades.

11. While the DPC has no particular view on the detail of the intellectual property issues in the report, it is keen to ensure that intellectual property laws do not act as a barrier to appropriate preservation activities.

12. Consideration must be given to the rights, responsibilities and legal protections of those engaged in the long term preservation of our digital heritage.

13. We note and welcome the discussion of new business models for digital content. This underlines the importance of effective exploitation of legacy content to create revenue streams. This is facilitated by more careful consideration of long-term access.

14. While we want businesses to thrive, we call for more effective planning to support preservation and access to digital resources from businesses that fail.

Universal Connectivity

15. We note and welcome the aspiration that everyone in the UK should be able to participate in the digital economy.  We note again the implication for content creation and distribution and what this means for ensuring a cultural legacy (see point 8-10).

Equipping everyone to benefit

16. We note and welcome the concern with digital skills articulated in the Interim Report.

17. We note that digital preservation is a relatively new discipline.  Better long-term planning and exploitation of digital content will best be achieved by investing in people, specifically by ensuring that the right parts of the workforce have access to appropriate training and career paths.

18. The UK has made a significant contribution in the development of digital preservation and curation. This contribution provides a competitive advantage for the creative industries and cultural heritage sector, and creates an opportunity for knowledge transfer between DPC members and content creators.

References
Blue Ribbon Task force on Sustainable Digital Preservation and Access (2008) Sustaining the Digital Investment: Issues and Challenges of Economically Sustainable Digital Preservation (Interim Report)

William Kilbride, Executive Director of the Digital Preservation Coalition
March 2009

PDF of Full DPC Response to Digital Britain: The Interim Report (March 2009) (70KB)

More information and the full Digital Britain: The Interim Report can be found at: http://www.culture.gov.uk/what_we_do/broadcasting/5631.aspx

The Digital Britain discussion site: http://www.digitalbritainforum.org.uk/

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