24 September 2025
“Never Again” Meets “Right to be Forgotten”: Archives, Accountability and the Legacy of Privacy
By Jess Pembroke, Director of Information Law Services
The recent BBC report on Weleda’s investigation into its alleged links to Nazi-era human experimentation reminded me of the vital role archives play in confronting uncomfortable truths. A key area archives ask for our support on is how to balance the need to preserve historical records with modern data protection laws like the GDPR?[1]
The Irony of Protection
There’s a deep irony here: laws born from the horrors of the 20th century designed to protect individuals from state overreach could, if misapplied, be used to erase the very records that could contain evidence of that history. This is why archivists and data protection officers must work together to balance protection and preservation.
GDPR and the Paradox of Privacy
GDPR enshrines the right to privacy and, notably, the “right to be forgotten.” But data protection law provides exemptions for archiving in the public interest, scientific or historical research, and statistical purposes provided appropriate safeguards are in place. Archiving is one of the few areas where the law recognises that some data must be retained, even if it includes personal or sensitive information, because its historical value outweighs the privacy implications .
Transparency Through Access
Weleda’s decision to grant full access to its archives for independent research is commendable. Corporate archives understand that transparency is not just a legal obligation, it can be a moral one and import for the future of their business.
Further Help
We understand the immense pressure that comes with ensuring compliance and navigating the complexities of data protection regulations. That’s why we’ve created a dedicated help desk to provide you with the support you need. For more information, click here or contact us!
Want to learn more?
Join our training course to gain practical skills and confidence in managing personal data within your archive, museum or library collection – contact us at info@naomikorn.com now for further information and to join the 2026 waitlist!
To learn more about the course, please visit the webpage , and check out your chance to complete your full Data Protection Intermediate Certificate in just three days in October: https://www.eventbrite.co.uk/e/intermediate-certificate-in-data-protection-tickets-1321193016879