feedback analysis removal and disposal policy May 2023.pdf

Submission Analysis – NLNZ Removal and Disposal Policy
Purpose
1.
The purpose of this paper is to:
•
summarise the feedback received on the National Library’s draft Removal and Disposal
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Policy (Policy) public engagement process; and
•
outline key themes and recommended changes for further consideration.
Summary of process and numbers
2.
Public feedback on the Policy was received between 3 April 2023 and 12 May 2023. Feedback
was received via an online form, verbally through meetings and discussions, and via email:
a.
There were 12 group discussions:
i.
3 with invitations to research community – PHANZA, NZHA, NOHANZ, Stout Research
Centre
ii.
1 with Library sector, via LIANZA webinar
iii.
1 with Book Guardians Aotearoa
iv.
2 with specific libraries who requested a detailed conversation
v.
1 with music community interest groups and individuals
vi.
1 with an engaged member of the public, on request
vii.
3 with Minister and NLNZ Advisory Groups
o
Library and Information Advisory Commission
o
Guardians Kaitiaki of the Alexander Turnbull Library
o
Kōmiti Māori.
b.
There was written feedback from 14 individuals and 9 organisations or interest groups.
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c.
Verbal feedback was received from several discussions with stakeholders and individuals.
Main themes
Inconsistent understanding of National Library role and the purpose of different collections.
3.
This was expressed in many ways – sometimes through confusion or genuine surprise,
sometimes through anger or frustration, and sometimes much more articulately and with depth
of understanding by library sector colleagues.
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Concepts like library of last resort and general reference library for New Zealand came up
repeatedly. Neither of these concepts have been a driving force in strategy, policy or decision
making for over 20 years, however they are still prevalent in how a number of stakeholders saw
the National Library’s role and the purpose of collections. Sometimes those concepts have been
expanded from their original purpose too. For example:
•
the library of last resort was an Alexander Turnbull Library concept, prevalent through the
1970s –90s and applied to NZ and Pacific material only. However, there are some
stakeholders who see that as the role of the “entire” National Library.
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•  A general reference library for NZ has also not been a concept held or acted on for decades,
rather the general collections have been developed around priorities for the library system
and not been developed to be comprehensive.
Response
4.  Ongoing  engagement  with  reinforced  key  messages:  The  purposes  of  the  collections  are
articulated  in  the  Policy;  however,  the  responses  received,  and  similar  recent  feedback  and
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experiences over recent years, do point to the need for ongoing wider, regular engagement with
stakeholders and the public on the National Library’s collections and purposes.

5.  Consideration  should  be  given  to  limiting  the  scope  of  the  Policy  to  general  collections  and
copies only (see further below).

6.  The definition of the purpose of the general collection could be looked at again to ensure it is
clear and able to be better understood. .
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Concern/questioning about the inclusion of Alexander Turnbull Library collections in scope
7.  The National Library Act contains specific provisions relating to the Alexander Turnbull Library
(ATL) collections (e.g. sections 9(3), 9(4)(b), and 11(2)), which don’t easily fit with the scope of a
removal/disposal policy that would cover the ATL collections as well as the general collections.
THE

It was intended that this Policy could cover the very rare occasions where there could be an ATL
removal (generally related to where something should not have been in the ATL collections in
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the first place or for some other legal requirement).
However, inclusion of the ATL collections within the draft Policy causes some confusion, and
raises a potential issue the Policy could be seen as inconsistent with the Act.
Response
8.  It  is  recommended  that  the  ATL  collections  be  removed  from  scope  of  the  Policy.  This  will
provide  clarity  to  stakeholders  and  ensure  there  is  no  confusion  about  the  status  of  the  ATL
INFORMATION
collections.

This would mean that any proposal to remove or dispose of documents from the ATL collections
would go through a separate process.
Strong interest in collection management decision making
9.  There was significant interest in the analysis and processes that sit behind implementation of
Principles 3:

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Before a recommendation is made for removal, an assessment will be made about the impact on
the ongoing information and cultural needs of New Zealander.

10.  I thought this engagement was encouraging. All good professional collection management
decision making considers a range of, often competing, variables. A transparent process
(principles 13 and 14) for removal and disposal is an opportunity to highlight the considerations
of librarians. Many sector leaders I spoke to also understood this opportunity.

11.  However, tensions with principle 3 remain: some stakeholders understood that decision making
sits within the framing of policy principles, collection purposes, and organisational purposes at
an aggregated level – so that not all needs can always be accounted for. Others saw it as

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mechanism to ensure very specific information needs were able met. Where these tensions
exist, they will need to be clearly communicated as part of implementation of the Policy.
Response
12.  Consider the final wording of this principle within the potential real examples that may exist for
removal and disposal in the next 5 years. It will be one of the main principles that form the basis
of  interaction  between  librarians  (who  need  to  feel  confident  in  making  decisions  within  the
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frame)  and  researchers/stakeholders  (who  need  to  feel  confident  they  have  a  real  basis  for
genuine engagement).

Strong support for Policy overall, especially transparency and participatory intentions.
13.  Principles 12-14 (process principles) outline the Library’s intention to be transparent about its
intention to remove/dispose of documents, and to ensure that there’s an opportunity for
participation in the process for relevant parties [this is paraphrased].
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14.  There was very strong support for these principles and the process/precedent that this will
have.

15.  I repeatedly asked the question: what does transparency look like for you? Discussion tended
THE
toward referring to the ‘intention to remove/dispose’ page on the website, which outlines areas
of collections that are intended to be considered for removal and provides interested parties
(through mailing lists or in some other form) with the opportunity to outline that they are an
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interested party [and what their interest/position is].
Response
16. Consider the forward plan for intention to remove/dispose as part of the Policy implementation
documentation.
Drawing on lessons/experiences of OPC removal decisions and process
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17.  Much discussion, and some feedback, centred around the experiences of the recent disposal
project of items from the overseas published collections (OPC). Some discussion was used as an
attempt to relitigate that decision of removal, which has already been made under appropriate
process. Going forward, any decision on removal of any additional items from the general
collections (including OPC items) items will follow this new Policy.

18.  There was some discussion about size and scale of removal could impact the intentions behind
the transparency (principle 12) and participation (principles 13 and 14) process principles in the
pPolicy. For example, a significant engagement exercise on 1 or 2 items or a normal engagement
ACT
on very complex or a large number of items.

Response
19.  Consider whether there could be a principle that supports good engagement/participation that
relates  to  size  and  scale  being  commensurate  with  the  engagement  required/wanted,  or
whether that sits within the process documentation of implementing the Policy.

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In-confidence
Summary of feedback for specific sections of the Policy

Policy section
Summary of substantive feedback
Specific example from feedback received
Response from Library
Scope
Questioning of the validity of Alexander Turnbull Library  The notion that items may be removed from ATL collections under any circumstances
Change: Remove Alexander Turnbull Library collections
collections being in scope of this policy given the
was confusing to [our organisation] because it seems to be contrary to statements
from scope of the Policy.
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mandate outlined in the National Library Act 2003
made in governmental legislation and other National Library documentation.
The circumstances for potential removal from ATL
which states their requirement to be maintained in
collections are limited so it would be preferable not to
perpetuity (s9(3)) and to be continued to be owned by
include them in a policy intended for wider operational
the Crown (s11(2))
purposes.
Circumstances for Removal:  Items no
Questioning of the reasoning for purpose for which they  Concern at the perceived breadth of this explanation. How will NLNZ ensure their
Comment: The removal of ATL from scope will assist with
longer fulfil the purpose for which they were  were collected and the relationship between collections  collection policies account for the changing information needs of different groups at
addressing this concern. The Policy will cover the general
collected and have not taken on a
policy and removal and disposal policy
different stages of life?
collections only, which are intended for current
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subsequent purpose that aligns with the
Can NLNZ ensure that actions taken under this policy won’t adversely impact on the
information need and support of library system. However
collections policy
ability of information needs of NZ’ers in the future to be understood and met?
it may be a duplicate of circumstance below so consider
whether this one is needed.
Circumstances for Removal: Items in the
We question what the term ‘current information needs’ means in this context.
Change: the definition of the general collections to
general collections do not align with the
We would hope that material that has any research value would be retained and could  ensure the purpose of that collection is clear
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National Library’s collections policy
possibly be transferred to the ATL collection. Researchers often refer to what many

would see as ‘outdated’ material to explore the views of people of the past.
Removal Principle 2
Strong support for this principle
We welcome the acknowledgement of the role of New Zealand law and recommend
Comment:   The Library notes the range of legislation
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Removal of collection items must be
that the removal and disposal of collection items must be consistent with a mutually
that could be relevant; however, referring to some
consistent with New Zealand law
agreed understanding of New Zealand copyright legislation.
legislation in a non-exhaustive list can raise issues in
itself. The preference is to keep this principle broad and
general.

No change to principle
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Removal Principle 3:  Before a
Most debate related to this principle. Overall very
Removal principle 3 (p7) is of critical importance for the research communities. The
Comment: The removal of the research collections of the
recommendation is made for removal, an
strong support for it being there however a high
question is just how ongoing informational and cultural needs are determined by
Alexander Turnbull Library from scope should go some
assessment will be made about the impact
number of questions about how this will be determined  library staff.
way to clarifying the intent of this principle.
on the ongoing information and cultural
and communicated.
This is difficult for all custodial institutions, and especially for those such as the
As a principles-based policy, the specific of the concepts
needs of New Zealanders
National Library with national responsibilities.
like these are manifest in their implementation. Each
removal and disposal must outline how it has addressed

Unlike public library ‘weeding’, which is a routine exercise, removal of stock from such
collections should involve expert disciplinary advice and wide user consultation, with
these concepts.
proper item by item consideration.
No Change to principle
In a library purporting to hold research collections it is inappropriate to place undue

ACT
weight on the ages of items and the number of times they have recently been issued.

How does the National Library identify and define “current information needs of New
Zealanders” given the cosmopolitan and diverse population New Zealand has become
Removal Principle 4:
No specific comment, but general support through the
N/A
No Change to principle
Removal recommendations will take into
discussions with interested parties.
consideration the relationship items have
with other items in the collections

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In-confidence
Policy section
Summary of substantive feedback
Specific example from feedback received
Response from Library
Removal Principle 5:
No specific comment, but general support through the
N/A
No change to principle
Removal recommendations will take into
discussions with interested parties.
consideration the relationship items have
with other items in the collections
Removal Principle 6:
Little written feedback on this principle however there
Cost implications should be re-worded. Cost of maintaining and storing items should
Comment: Cost is a consideration in all collection
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The cost of maintaining and storing items is
were lots of discussion in the engagement hui.
not be a consideration for removal.
management decision making – acquisition, storage,
not the primary driver for removal decisions.  While a small number thought cost shouldn’t be

packaging, environmental conditions, access, removal.
considered at all, most wanted to understand the role
The implementation templates are to ensure how cost
Paraphrased: How does the Library ensure that storage cost does not become the
of cost as not a primary driver, rather a secondary
has been considered with a removal decision.
primary driver?
consideration.

No change to principle
Disposal Principle 7:
Little feedback in this principle. One stakeholder
International law plays a significant role in copyright. We therefore recommend that
Comment:  The Library notes the range of legislation that
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Disposal of items must be consistent with
requested more specific mention legislation.
point two and point seven should be extended to include adherence to relevant
could be relevant; however, referring to some legislation
New Zealand law
international copyright laws and treaties, including but not limited to the Berne
in a non-exhaustive list can raise issues in itself. The

Convention for the Protection of Literary and Artistic Works and Trade-Related Aspects  preference is to keep this principle broad and general.
of Intellectual Property Rights

THE
No change to principle
Disposal Principle 8:
Little specific feedback on this principle. There was
Very careful consideration should be given to modes of disposal for material removed
Comment:  Noted.
The National Librarian can consider a wide
general acknowledgement of the breadth of options
from collections. How this is handled is likely to have significant bearing on the

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range of potential disposal options, including  available and the one chosen has the potential to
National Library’s standing and public reputation.
No change to principle
impact the Library’s reputation.
transfer, sale, donation and destruction
Disposal Principle 9:
General feedback that this was an important principle.
Disposal principle 3 (p7) is of considerable importance, especially in the case of
Comment:  Noted.
Where a range of viable options are
holdings which the National Library may wish to relinquish but are either rare or

available, disposal actions that enable
singular in New Zealand.
No change to principle
ongoing public access will be prioritised
Disposal Principle 9: this is important. Sending books overseas for digitization doesn’t
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ensure ongoing public access - see Google Books. This is without even taking into
account digital divide issues.
Disposal Principle 10:
No substantive feedback on this principle. Most cost
N/A
No change to principle
The costs of potential disposal actions will be  conversation took place in relation to removal, under
understood and considered and may
principle 6.
influence disposal decisions
Disposal Principle 11:
No substantive feedback on this principle
N/A
No change to principle
If transfer to another party was agreed as

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part of the removal decision, no other
disposal actions will be considered.

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In-confidence
Policy section
Summary of substantive feedback
Specific example from feedback received
Response from Library
Process Principle 12:
There was substantial discussion and feedback on this
Ensuring that removal and disposal proposals are much more transparent, and open
Comment:  Agree on the value of a transparent process,
The process for making removal and disposal  principle.
for genuine consultation, would be a significant move forward.
for ensuring good participation/feedback and to support
decisions, and the outcome of these
Strong support for the principle itself with most
Much of the current public criticism of the National Library arises from a perception of
with trust in Library collection management decision
decisions, is transparent
discussion focussed on what transparency looks like
unilateral decisions influenced not by users but by the Library’s administering
making.
from different perspectives and how that might be
department.

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enacted.
[Paraphrased from several discussions]: Recommend publicising a plan or intent
No change to principle, however Change to the
document that outlines classes of collections to be considered for removal and
implementation processes and templates to ensure
disposal that enables interested parties to register their interest in
there’s appropriate indicators to plans for removal and
participating/providing feedback.
disposal activities, where plans and intention exists.
We believe that the policy’s commitment to transparency in decision making will be

welcomed by the creative industries we represent. However, we recommend that the
policy elucidate in detail on the procedural precautions that will be taken to ensure
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Process Principle 13:
Significant feedback and discussion on these two
We particularly endorse points 13 and 14 that there is open dialogue with relevant
Comment:  It is encouraging to see the overall support
The National Library builds or maintains
principles, primarily agreeing with their purpose but
institutions, community groups and individuals
for these principles.
relationships with people who have
seeking clarification on detail and how the Library will:
Such decisions, relating to public assets, should involve wider consultation than
Much of the feedback emphasised the need to get
significant connections to collection items

principally the library profession and members of the GLAM community.
engagement right, to empower participation and for the
THE
being considered for removal and disposal
-
Build and maintain the necessary relationships
With respect to point fourteen, we recommend that the policy provides greater detail
Library to consider a range of views and make a decision.
-
Respond or integrate feedback into decision making  on the process for identifying relevant groups and individuals to ensure that decisions
Most of the comment related to how the purpose of
Process Principle 14:
-
Ensure balance of perspectives are considered
align with the policy, and that the policy should contain a commitment to inclusive
these principles would be implemented.
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The National Library seeks advice from
where a variety of views exist.
treatment of authors and publishers.
Due to the range of circumstances around removal and
relevant groups and individuals to ensure
My concern is that although it specifically states the National Library seek advice from
disposal it is not good policy to code that process into
decisions align with the Removal and
relevant groups and individuals, it doesn't empower the library to ignore advice from
policy. However the documentation must include how
Disposal Policy
irrelevant groups and individual
these principles have been considered for removal and

disposal decisions.

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No change to principle
Principle 15:
No substantive feedback on this principle
N/A
No change to principle
Appropriate tikanga will be followed

when making and implementing
removal and disposal decisions
Principle 16:
No substantive feedback on this principle
N/A
No change to principle
A record of items considered for removal

from collections, and any supporting
ACT
disposal action taken, will be made and
kept
Principle 17:
No substantive feedback on this principle
N/A
No change to principle
A summary of engagement activities and

outcomes will be provided to the person
making final removal or disposal decisions.

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