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Digital Archives: Who Keeps Them and Who Pays?

Response on behalf of PADI Working Group to the study commissioned by the United Kingdom's National Preservation Office, August 1997.

We welcome the opportunity to comment on the proposed model and it's good to see this issue taking on major importance worldwide. We would also like to establish contact between Preserving Access to Digital Information (PADI) and the Digital Archiving Working Group to share our combined experience and expertise. In Australia there has been much activity in recent years first in isolating the issues and then working out practical means to implement a reliable archiving strategy. Who controls and who pays are certainly critical and it's useful to focus debate on these elementary considerations initially. The study invited comments on specific aspects of the model but we have also prepared comments against each of the headings in the Operating Model as these seemed to us to contain key issues which merited further debate. Comments below are grouped under each of the headings of the Operating Model.


Distributed Archive

There are a number of issues which need clarification here. Does the model assume all digital data? It is widely acknowledged that many of the boundaries which exist for print blur in the digital environment, and the PADI Working Group was consciously created with cross sectoral membership in recognition of that. However in practice some distinctions remain as different strategies tend to be appropriate for, say spatial data, or for electronic records originating as part of the business records of an agency as opposed to digital publications which may be created by a much wider range of authors and in a wider range of formats.

On what basis would responsibilities be allocated? We assume there would need to be more evidence than interest shown by the parties taking on responsibility for archiving. What powers would NODA be expected to have? Would it play a role in certifying the archives (as in the RLG/CPA Report model)? Would NODA also be expected to have the power to remove responsibility for archiving from an agency if performance proved to be unsatisfactory? Is it anticipated that there will be formal monitoring of performance? In Australia, we are still working on the assumption of a distributed model though it is not yet formally in place. The PADI Working Group has surveyed some stakeholders and we are identifying and communicating with key players, through PADI and also through the work of the National Library of Australia (NLA), for example through Preserving and Accessing Networked Documentary Resources in Australia (PANDORA) and also other NLA initiatives. A meeting at the NLA this October will focus on a national strategy to preserve physical format digital publications and will bring together representatives from State and National libraries and publishers.

Extension of Legal Deposit Legislation

We agree with this in principle. It also reflects the approach in Australia in which the Australian Council of Libraries and Information Services (ACLIS) and the NLA have made submissions to the Copyright Law Review Committee (CLRC) making a strong case for the extension of legal deposit to include digital publications. The NLA is also pursuing other alternatives, pending legal deposit legislation, such as voluntary deposit. Given the apparently broad definition of digital data in the proposed model, it would be useful to clarify what digital objects are included here as there is much digital data which is not "published".

Specialist Agencies

We agree that there needs to be a more sophisticated model than for print and one which needs to accommodate varying levels of participation, which is what this seems to be advocating. Do we assume that each of these specialist agencies will develop different strategies according to the medium/subject they archive? Will it be the responsibility of each agency to develop their own preservation paths? Would NODA be expected to play a role in accrediting these strategies?

Permanent Retention

We agree that it is important to ensure a commitment to keeping material for longer than current use alone dictates but forever is a major undertaking and may lead to a more restricted approach to selection than might otherwise occur, because of the resource implications of such a commitment. In Australia, the NLA Statement of Principles for the Preservation of and Long-Term Access to Australian Digital Objects was that Access to digital objects should be preserved only for as long as they are judged to have continuing value and significance. This assumes that professional judgement will need to be applied, balancing costs and benefits as well as the anticipated needs and interests of future generations. This does introduce a more complex approach than a blanket permanent retention but we believe that one of the advantages of attaching this responsibility to cultural institutions like libraries and archives is that they have well developed concepts of permanent retention and of managing long-term accessibility even if material does not necessarily need to be retained permanently.

Selectivity

We agree that it is important to establish guidelines on selection criteria and these need to be public documents. This is especially important in a digital environment where the implications of not selecting for archiving will generally be more severe than for paper. It may be of interest to look at the NLA's Selection Committee on Online Australian Publications (SCOAP) guidelines which illustrate the attempt to retain similar principles for selecting digital publications as for print while at the same time acknowledging the important differences. National Archives of Australia [formerly Australian Archives] have also done much work in this area and How Long Should Records Be Kept? an extract from their publication Keeping Electronic Records, provides advice to agencies in appraising their records.

Standard Formats for Preservation

The statement As far as possible store in standard formats does not seem to take account of the speed of change in this area. For example, even where standards do exist (such as HTML) there are varying generations, not all of which can be easily read by the same browsers. There are also an increasing number of documents which combine a number of formats (including embedded software) as well as a wide array of standards, or at least de facto standards. While appealing, the suggestion that dependence on hardware and software can be substantially reduced in this way seems to over simplify the magnitude of the problem. To quote Jeff Rothenberg, The information revolution derives its momentum precisely from the attraction of new capabilities ('Ensuring the longevity of digital documents', Scientific American, vol. 272, no. 1, January 1995, pp. 24-29). Defining long term standards for digital documents may become feasible when information science rests on a more formal foundation, but such standards do not yet offer a solution. It should be noted here that the option Rothenberg does offer, of emulating the operating systems of obsolescent hardware and software is not one which is being actively considered in Australia. Both the PADI Working group and the NLA are promoting and exploring migration as a more feasible means of moving from one platform to another but the general point about standards still applies. It does still make sense to encourage the use of standards where they exist and also to raise awareness of the inherent difficulties (and perhaps impossibility) of maintaining access to digital objects originating in non standard formats. However it needs to be recognised that there will still be significant challenges to be overcome in maintaining the multiplicity of digital documents over time, even when they do adhere to standards at any one time. There should also be an acknowledgment of the dynamic nature of many digital documents, raising issues associated with authenticity.

Look and feel issues. We respect the look and feel concerns of publishers and users but we have not to date found a solution to this in Australia. While it would generally be desirable to retain the look and feel of documents, which in some cases form a crucial part of them, the reality is that in many cases it may not be feasible. While we can envisage putting the resources into a very few items of great worth, we also recognise that it will correlate to page by page - even fibre by fibre - treatment of traditional book materials and this simply will not be possible for depository libraries to unequivocally commit to. It may be a more feasible prospect for some specialist agencies.

Restricted Access to Electronic Publications

A standard retention time is administratively appealing but is likely to encounter significant practical problems. The reality is that commercial publications will vary markedly in the length of time they are considered to be commercially viable so in practice it tends to be negotiation with the publisher on a case by case basis - which of course adds much to the workload but it is difficult to see how this can be avoided. There are also other reasons, apart from commercial ones, why access might need to be restricted for a defined period of time. To give two examples, certain electronic records and some oral history interviews may have restricted access periods placed on them for a whole range of reasons, none of which has anything to do with allowing commercial exploitation. A standard retention time would be impossible in these cases as, depending on the reason, the restriction on access may vary from a few weeks to several decades.

Public Funding

It is not clear how the statement that Users should not be required to pay at the point of access relates to the standard retention time referred to above. This is surely not advocating that depository libraries make documents deposited via legal deposit freely available immediately? For networked publications especially this would impose severe economic penalties on the publisher. The model does not at this stage adequately address the relationship between legal deposit libraries and copyright owners.

Who Should be Responsible for Archiving Digital Materials?

The NLA Statement of Principles refers to creators having an initial, and in some cases a continuing, role in preserving access to them. This is intended to convey the complexities of a digital environment in which a whole range of responsibilities need to emerge and intersect. These responsibilities are likely to shift over time. If this question is asking only about the long term then it is unlikely that there will be more than a few agencies with the necessary infrastructure and ongoing resources to make such a commitment. Depository libraries seem the logical choice to play a role in preserving "published" digital documents. Larger academic institutions who also create digital documents should also play a role in ensuring their investment in creating those important resources is maintained for future scholars. The specialist agencies already referred to are also likely to play an important role. The NLA is working on the assumption that the National and State libraries who have responsibility for the collection and preservation of Australian publications, will take responsibility for developing a national model for the archiving of electronic publications, and for playing a significant role in the maintenance of electronic archives. In fact many of the issues raised in your paper are also being actively discussed by the committee overseeing the PANDORA project.

How Should this be Paid For?

Publicly funded institutions would be preferable, provided there was acknowledgment that there would need to be additional funding provided for this purpose. It could not reasonably be expected to be absorbed with other roles. We assume there will continue to be an information provider role for libraries as well as an information keeping role and there will inevitably be tensions between these roles unless appropriate funding is provided. The idea of top slicing research grants for research to cover the archiving costs of data arising from the research is a good one, especially as it is preferable to plan for these costs at the start. However there is as yet little empirical data on exactly what costs are required. At the NLA, we are anticipating the PANDORA project will shed light on the costs associated with archiving a selection of networked publications.

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