Laura Giles is the Academic and Library Specialist at the University of Hull.
Last November, I was asked to speak at the DPC Ram Jam about our approach at the University of Hull to the section C of the Rapid Assessment Model, which focuses on the Legal Basis.
Speakers who had undertaken multiple RAM assessments and who had moved their organisation from level 2 – Basic to level 3 – Managed in a section were asked to talk a little about their journey. What had changed, what steps had they taken and what might their plans be to move their organisation to the holy grail, level 4 – Optimized?
I said yes, but at first I felt a bit of a fraud. In practical terms what had actually changed in the time between our two most recent RAM assessments? Not much! Ultimately the main reason we regraded ourselves from Basic to Managed was less to do with any big changes to the way our team operates or our level of legal expertise – no one in the team had qualified as a lawyer in their spare time - and more to do with the fact we had come to recognise that our context is key. For the type of service that we are, there is a level at which it is appropriate for us to use our judgement as informed by our archival education and experience then a further level at which it is completely appropriate to look outside the immediate team for guidance. The ability to delegate outwards and upwards is part of our framework of operations
As an archives team, we sit as part of a partnership with our Council colleagues within the Hull History Centre as well as within the University Library and also within the wider university. At every one of those levels are people or guidance we can look to, either for legal advice or for a level of authority we can’t meet within the archives team.
We are a small team. We are comfortable operating with legal templates for standard, repeatable archival procedures such as deposit, accession, access provision etc. That would seat us comfortably within RAM at a Basic level. It’s really the fact that we can also now acknowledge the wider frameworks that we sit in that we believe has bumped us to Managed in our own estimation.
In terms of relevant tools that link in with our own assessment of our legal capabilities and responsibilities, part of our digital archives infrastructure is Hyrax which allows us to restrict or embargo public access to digital material where that should be legally protected – whether that is to protect personal data or copyright. Ensuring access protections is part of the cataloguing and ingest workflow where we are obligated to share protected material (e.g. for FOI), we are able to use Hyrax to give single use links etc.
We also use siteimprove to ensure that we meet our accessibility responsibilities. The university has a subscription which use to monitor how well our various websites can be accessed by people with different needs such as specific learning differences or visual impairments. The monitoring helps us fix broken links. Address illegible text and identify photos and videos without a label or text alternative. We then use this to produce accessibility statements which are accessible on our sites and help us to ensure that we are compliant with digital accessibility guidelines.
Regarding what is next for us legally speaking, I would say that we don’t have plans to progress beyond Managed to Optimised for the Legal Basis section. Within our small team we don’t have the resource or expertise to develop to be more proactive in monitoring and mitigating legal risk and within the wider University landscape, as valued as we are, I think we figure quite minimally in their legal concerns so it doesn’t feel realistic that we would be able to engage in “inputting into the legal and digital processes that create regulation”.
Part of the RAM process is figuring out what levels feel comfortable for your own service. It’s useful to benchmark against other services but you shouldn’t beat yourself up if you have different levels of ambition – the contexts our services operate in can be poles apart. The important thing is to establish what your own priorities to develop are and where you are happy to conserve energy by embracing the level you currently sit at.
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