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Audits and Evaluations

Audit of the Deaccessioning of Private Collections

Risk Management

Criteria: The approach to managing the deaccessioning of private collections risks is well communicated, and understood by management.

There is currently no risk management framework in place for activities relative to deaccessioning.

Our assessment of the adequacy of the risk management approach was based on the expectation that the following elements would be in place:

- There is a documented and well-understood risk assessment approach for the deaccessioning function;
- Risks relative to the deaccessioning process have been identified and mitigating measures have been developed;
- Mitigating strategies are implemented, well understood and communicated.

The Analogue Preservation Branch has developed a Risk Management Framework for the collections under its custody. The framework defines the various agents of deterioration, the risk level for each agent and the mitigating measures in place. The Branch has also defined the preservation issues relative to analogue holdings. However, these documents concern the preservation of analogue holdings currently in the custody of the Branch and have a limited impact on SCEB acquisition activities. Although, in cases where the ability to preserve the collection is doubtful, archivists may consult with the responsible collection managers prior to acquisition.

Managers of the SCEB have indicated that there is currently no Risk Management Framework for managing the acquisition function or the resulting deaccessioning activities. The prevalent opinion is that the risks related to deaccessioning are very small. The penultimate risk of destroying a collection that should have been kept is considered almost nil. Given the archival culture, if there is any doubt about destroying a collection, the collection will be kept. In addition, the current approval process for deaccessioning described in the previous section provides effective mitigating measures.

However, management acknowledges the need to better identify the risks relative to acquisition and deaccessioning as demonstrated in the Project Charter for the MII 4 in which the most relevant risks have been identified.

There is a need to formalize the deaccessioning process to ensure that it is conducted in accordance with the terms and conditions agreed to with the donor as required in the Act.

The Act stipulates that "disposition is subject to the terms and conditions under which the publication or record has been acquired or obtained." Following the collection appraisal and negotiation phase, the archivist and the donor agreed on arrangements to acquire, dispose of, and/or transfer the collection or parts of it. Until now, those arrangements were not part of the Deed of Gift signed between LAC and the donor. There was no consistency in the way the arrangements were recorded. In many cases they were contained in letters to the donor or collection agreements signed between LAC and the donor. However, they were sometimes limited to verbal agreements. Recognizing the limitations of these arrangements, the SCEB staff indicated that in all cases of deaccessioning they communicate with donors to obtain their agreement with the proposed disposition procedures.

While this situation may not have caused serious problems to date, the proposed projects under MII 4 will increase the risk of disposing of a collection without knowing the exact terms and conditions agreed to with the donor. The scope of the MII 4 initiative "…includes all measures necessary to support the design and implementation of a reappraisal program, from the articulation of policy strategies and the developments of new protocols for disposal, return to donors/creators and long term loans. This MII encompasses all unprocessed and permanent LAC holdings."2

The ability to determine accurately the terms and conditions agreed upon at the time of acquisition may be difficult for those acquisitions completed several years ago. Therefore, the reappraisal of the permanent collection and the resulting deaccessioning actions may not always be compliant with the terms and conditions as required by the Act.

The Excess Inventory Reduction Project has helped crystallize this issue and the section responsible for Political Archives in SCEB has implemented some mitigating measures. To demonstrate that a reasonable effort was made to contact the donor, the staff members of Political Archives developed a number of instruments, checklist, detailed procedures and template letters to ensure that permission is granted by the donors or their successors prior to any disposition action taking place.

The current Deed of Gift states clearly that LAC was "to have and to hold the material" of the collection with no clause relative to disposal. This problem has been recognized and SCEB is in the process of developing a new Deed of Gift, which specifies clearly the arrangements between LAC and the donor regarding, amongst other things, conditions relative to disposal. There is no set implementation date for this new contract document.

In our opinion, there is a need to bring rigour to the deaccessioning process to clearly define the circumstances under which it will be undertaken and the procedures to be followed, particularly in cases of material acquired in the distant past.


3. Ensure that deaccessioning of archival material is conducted in compliance with the terms and conditions agreed to or renegotiated with the donors, and that future terms and conditions are consistently documented.

Management response:

LAC's acquisition sector agrees with this recommendation, and that greater clarity be obtained in the dealings with donors. It is worth noting that the existing Deed of Gift covers specifically material retained by LAC, if need be legal advice will be sought to cover conditions for return/disposal of material.

2 Modernization Innovation Initiative #4 Project Charter

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