Overview
Introduction
When arranging and describing collections, processors will often encounter material that is sensitive or should be restricted in accordance with the Bentley Historical Library's guidelines.
This section explains the Bentley's approaches for dealing with these kinds of material.
Sensitive Information
When a processor uncovers sensitive information (see footnote 1) or information restricted according to the donor’s gift agreement, they must consider whether the material should be separated or retained with an appropriate restriction. In making these decisions, the processor’s goal is not to censor the record or sanitize the file for the benefit of the donor, but to protect individual privacy rights and personal data. While this is in part a legal concern, it is also a question of treating fairly the donor, individuals who have contact with the donor, and "innocent" third parties who are mentioned in archival records but who may be completely unaware that their name will appear in a publicly available document.
It is also important to note that all material—including restricted material—may be requested via a formal Freedom of Information Act (FOIA) request to the University of Michigan.
If sensitive data will be retained in a collection, there are a few strategies that can be employed:
Access restrictions: By employing appropriate access restrictions, the library can mitigate risk and protect the sensitive information of its donors. When in doubt about imposing restrictions, processors should err on restricting that material
Redaction: Redaction should only be employed when there is particularly sensitive information—such as social security numbers or bank account numbers—in a document that is 1.) of significant long-term value and 2.) would otherwise be made available in the near future if not for the presence of this sensitive information.
Footnote(s)
Footnote 1: Sensitive information can include—but is not limited to—social security numbers (often present in faculty curriculum vitae until the late 1990s), credit card numbers, passport numbers, driver's license and state identification numbers, tax identification numbers, protected health information (PHI), educational records protected by Family Educational Rights and Privacy Act (FERPA), etc. The University of Michigan Information and Technology Service's (ITS) Examples of Sensitive Data by U-M Role (public link) provides additional information about what kind of information is deemed "sensitive".