Corresponding authors: Laurence Livermore (
Academic editor:
There have been few, if any, open data and information management policies openly published from natural science collections. This paper contextualises the rationale for publishing the Open Information and Exceptions Policy of the Natural History Museum, London and provides the policy itself. The policy outlines how the Natural History Museum puts the principle of 'open by default' into practice; and includes sections on purpose and scope, relationship to relevant legislation (which always takes precedence over the policy), the categories of possible exceptions to open information release, what happens when exceptions are declared, relations to UK government information security classifications and definition of terms.
The European Research Infrastructure DiSSCo (Distributed System of Scientific Collections -
The Natural History Museum is a key partner in DiSSCo, both from the European Research Infrastructure perspective and its work in promoting and establishing the DiSSCo UK node and network of UK collections (
While there are other examples of collections policies available online (e.g.
The Natural History Museum is an exempt charity*
The examples of information types provided under each exemption are not exhaustive and may themselves be subject to case-by-case nuances.
The sections below are Version 2.1 of the Policy, which is updated periodically - this version was approved by the Trustees of the Natural History Museum in November 2023.
The Natural History Museum aims to make information openly accessible whenever possible and appropriate. This underpins our vision of a future where people and planet thrive and our mission to create advocates for the planet; and reflects our responsibilities as a public body and our roles as a public custodian of collections of global origin and as a scientific research organisation.
The Open Information and Exceptions Policy applies to all Museum Information whether generated under the Trustees of the Natural History Museum or the Natural History Museum Trading Company – for example, data, documents, images, video, sound recordings – created and held in the course of Museum activities, whether for scientific, public engagement, development or administrative purposes.
The Open Information and Exceptions Policy translates the principle of ‘open by default’ into practice by setting out what this means for the Museum and identifying the exceptional circumstances under which Museum Information will be withheld from viewing or access by the public. This is achieved by:
Connecting the policy to relevant legislation and best practice; Setting out the categories of exceptions to data release and how to consider whether they are applicable.
The scope of the Exceptions outlined in this policy is limited to access to Museum Information. When making information accessible, it is good practice to state the terms of, or any restrictions on, re-use (e.g. a copyright statement or any licence that is being applied).Re-use (sharing, repurposing, republishing) of information is subject to copyright or other intellectual property rights considerations, as well as the
The Museum’s Technology Solutions Team is committed to ensuring that underlying technology will enable the Open by Default principle to be realised, providing that there is no applicable Open Information Exception.
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Part of the Museum’s core legal duty under the
When a request for information is received under these pieces of legislation, any internal exceptions will be taken into account when considering the response. However, only specific FOI exemptions or EIR exceptions can be used to withhold information from release. It should be noted that some FOI exemptions can remain in place for a long period of time, for example,
Potential FOI exemptions that may be considered on a case-by-case basis have been listed for each exception below, to illustrate the overlap.
Below are the Museum's list of permitted exceptions to making information available under the ‘open by default’ principle.
i. Institutional profile and brand value;
ii. Commercial value;
iii. Research competitiveness;
iv. Third party rights;
v. Sensitive collection information;
vi. Donor or funder conditions;
vii. Confidential information;
viii. Legal or regulatory compliance.
To be used for Information which would have either:
a negative impact on the Museum’s brand or any aspect of its reputation (corporate, scientific, educational etc.); a more positive impact if publication is delayed (time limited exception/embargo).
Before Information is enabled for public access, the information owner must consider the potential impact of its release.
If the information owner is unsure, the Press Office and, if appropriate, the Science Directorate or the Registry should be consulted.
To be used for information which represents a potential source of revenue to the Museum. This should be a positive assertion of value, not a precautionary measure. NHM will actively identify and protect the knowledge assets and Intellectual property it generates for commercial value.
Images of specimens taken for collection management purposes will generally
To be used for unpublished data generated by NHM scientists which, if released immediately, would negatively impact the Museum’s research competitiveness and ability to attract external funding.
It should be noted that any embargoes resulting from this exception apply internally as well as externally, to anyone beyond the Principal Investigator and to any named individuals. Research competitiveness embargoes should be time limited.
To be used for information where rights are owned wholly or partly by one or more third parties.
Before any such information is to be enabled for public access, the project lead or information owner should ensure that agreements and contracts are checked for rights and conditions and apply this exception as appropriate.
Please be aware that copyright laws can restrict/prevent the sharing of Information assets with the public as well as their re-use. Notwithstanding this, Public Records which are open to public inspection in pursuance of the Public Records Act 1958, may be copied and a copy may be supplied to any person, by or with the authority of any officer appointed under that Act, without infringement of copyright.
Data subject to third party rights cannot be re-licensed and may only be shared with the permission of the third party. Data obtained from third parties should be received wherever possible in line with the Museum’s open by default policy.
To be used for information relating to sensitive or valuable collections which is not suitable to be made known to the public or would compromise collection or personnel security.
Before information is enabled for public access, the information owner must consider its sensitivity.
Generally, data of this nature should be actively excluded from release (e.g. removed from datasets before publication). Sensitive datasets shared with collaborators should be accompanied by a confidentiality agreement that prohibits re-sharing with any parties not explicitly permitted as part of the agreement.
Where information may be sensitive, the decision whether to apply this exception should be subject to a balanced view of benefits (e.g. the information may be of benefit to conservationists) and risks (e.g. it may be used by poachers), taking into account what related information is already in the public domain.
To be used for information relating to donations or projects where specific conditions have been stipulated regarding sharing and use of the collection and data derivatives.
Before information is enabled for public access, the information owner must ensure that donation/funding conditions have been checked and apply this exception as appropriate (including any restriction on donor or funder personal information).
Where explicit conditions regarding sharing and use exist and rights ownership is retained by the Museum, the information should be released to the fullest extent permitted with reference to relevant regulations and internal policies.
In general, this exception is only likely to apply where it overlaps with other exceptions under this policy, such as temporary embargoes or commercial value – the majority of our donors and funders prefer that information is made open or, in many cases, have policies that insist on this (e.g. most research grants).
To be used for confidential personal or corporate information, including relating to companies working with the Museum.
Before information is enabled for public access, the information owner must consider its confidential nature.
Personal information that is made public via published profiles on the NHM website is not covered by this policy as it is the personal choice of staff whether to publish it.
To be used for information which must be managed in accordance with legal or regulatory requirements.
As stated above, relevant legislation always takes precedence over this policy. In addition to the legislation listed above, this may also include, for example: Access and Benefit Sharing, Traditional Knowledge Agreements, CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) status, relevant law in other countries/jurisdictions, incomplete acquisitions or data associated with items no longer held by the Museum.
Before information is enabled for public access, the information owner must be confident that no legal or regulatory conditions will be breached by its release, by checking relevant documentation and/or consulting stakeholders.
If Information is considered to fall within any of these exceptions, one or more of four basic actions will occur:
No release (e.g. for sensitive/confidential information); Time-delayed release (i.e. embargo, with an agreed time limit and process for review for extension or subsequent release); Release without licence for re-use (‘All Rights Reserved’). It should be noted that information released or otherwise published without an associated licence permitting its re-use, may still be legally reproduced by third parties to the extent that the re-use is legally permitted under a relevant copyright exception; Release with conditions:
a) Release under a relevant licence from the Museum;
b) Release with third party conditions;
c) Release according to legal/regulatory conditions.
Within all of these actions, consideration should be given to the granularity and types of information being released – for example, rather than applying an exception to a whole dataset, certain fields or items might be redacted under this policy for later release or no release, enabling the rest of the information to be made available.
When an exception is declared, a record of the decision-making should be retained within the business area.
The Museum follows the Government Security Classifications policy for its information assets. The policy applies to all information that the Museum collects, stores, processes, generates or shares to deliver services and conduct business, including information received from or exchanged with external partners. All Museum staff have a duty to respect the confidentiality and integrity of any Museum information and data that they access and are personally accountable for safeguarding assets according to their classification.
All routine business, operations and services should be treated as OFFICIAL. This information does not have to be explicitly marked, but all staff have a duty of care to ensure that it is handled and shared responsibly and only accessed by authorised individuals for legitimate business reasons.
As per the Museum’s Information Assurance Framework, OFFICIAL-SENSITIVE (formerly PROTECT) should be applied to information assets:
a) containing confidential personal information, or
b) designated as ‘Museum sensitive’, that is, containing information that the Museum would not wish to be made known to the public, at least without a controlled release process.
This should be marked in the header (of documents) and file name and, if held in SharePoint or Exchange, should be labelled using the Microsoft Office 365 Security labels.
The OFFICIAL-SENSITIVE marking indicates that particular care should be taken when handling a document and it should only be shared, securely, on a ‘need-to-know’ basis. The marking does not automatically exempt the document from release under FOI, but will be taken into consideration if a request for it is received.
For practical purposes, information covered by most of the Open Information exceptions should be treated as OFFICIAL, so no marking up is required.
However, the OFFICIAL-SENSITIVE classification will generally apply to documents covered by the following exceptions:
Institutional profile and brand value; Confidential information;
and potentially:
Sensitive collections information; Legal or regulatory compliance.
Wherever possible, the OFFICIAL-SENSITIVE classification should also be marked up in the metadata of relevant assets in the CMS and MAM. For the other exceptions, it is possible that related documentation, for example, contracts or agreements, should be considered and marked as OFFICIAL-SENSITIVE, but the information itself (e.g. images or datasets) can be managed as OFFICIAL.
For further advice on Government Security Classifications, contact the Records Manager.
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The authors would like to thank the members of the Museum's Information Management Group for providing feedback on this policy and supporting its publication.
Author contributions are documented using the Contributor Roles Taxonomy (CRediT
No conflict of interest to declare
Disclaimer: This article is (co-)authored by any of the Editors-in-Chief, Managing Editors or their deputies in this journal.
See UK Government Guidance on Exempt charities (CC23):- What it means to be an 'exempt' charity and how exempt charities are regulated.