AvoinGLAM’s response to the writing of Kimmo Levä, Director General of the Finnish National Gallery
Kimmo Levä, the new Director General of the Finnish National Gallery, wrote on 15 March in his blog post “Data is more important than the work” that the Finnish National Gallery is considering a change of direction away from open access to digital cultural heritage towards the monetization of collections data.
In his post, Levä posits that the costs of digitization, data management and open publishing jeopardize the maintenance of physical collections. If digital resources cannot be monetized, he suggests, the maintenance of physical collections will have to be compromised.
Today, we respond to Levä’s piece and report the reactions that it has evoked in the field of open cultural heritage. We wish to discuss this further with the National Gallery as well as with a wider audience.
Openness, democracy, inclusion
Open, reliable information supports democracy and increases inclusion in society. Open and high-quality digital cultural heritage materials are a source for creativity. They enable learning, research, journalism, innovation and civil society activities. The integration of knowledge and digital heritage across organizational and national borders is possible. Do we want to throw all this aside?
The Finnish National Gallery is a flagship of open cultural heritage
The National Gallery has been a forerunner internationally in making collections available to the public. In 2013, the National Gallery published its collections metadata — catalog information about artists, artwork titles, media and dates, etc. — in the public domain using the Creative Commons CC0 waiver. Finnish libraries, archives and museums taking part in the national aggregator Finna’s service have agreed to publish their collections metadata with the same CC0 waiver, in order to enable the open use of their data and to increase its impact. Europeana, the European cultural heritage aggregator, has the same policy.
In 2018, the National Gallery released the digital copies of works whose copyright protection has already expired by law under the CC0 waiver.
‘The FNG aspires to be among the very best museums in northern Europe, taking into consideration our audience needs and expectations. Opening up our collections data is one way of leading our customers towards even richer museum experiences, and of course the requirements of national and EU cultural policies very strongly pointed the way to a tenacious open-data policy.’ — Riitta Ojanperä, Director, Collections Management, National Gallery of Finland.
‘Hello world! The Finnish National Gallery opens up its collections’, Riitta Ojanperä, Mar 21, 2018.
AvoinGLAM has a long and warm history with FNG. They have been one of the first ones, and one of the biggest, to have collections data imported to Wikidata. Together with AvoinGLAM, they were going to host the 2020 HackFI co-creation event after a year of preparation, but the event was canceled only a day before due to covid on Friday the 13th of March 2020.
Public domain is common property
Until now, museums have been able to prevent or restrict the use of the images of the public domain works in their collections by invoking the rights of photographers and reprographic operators. An amendment to the Copyright Act that will be considered by the Finnish Parliament, based on an EU directive, is not going to support this kind of activity. The new law implements the will of the directive: what is in the public domain should remain in the public domain. Its free use must not be subject to new restrictions. The act applies in particular to the reproductions of works of fine art.
Relicensing images of public domain artworks with new licenses, as envisioned by Kimmo Levä, will not effectively prevent their reuse. A new license will not invalidate the existing, irrevocable CC0 waiver for the photograph, nor will it prevail over the statutory public domain status of the artwork, but it will cause confusion with the users. Above all, it turns the back of the institution on them.
The response in the international community of practitioners in Open GLAM, advocates of open access in galleries, libraries, archives and museums, has been lively:
The economic model of image licensing for museums is questionable
Douglas McCarthy, independent open access researcher and author, says, ‘Very few museums make a profit from image licensing: this has been revealed by Freedom of Information responses, case studies, empirical data and institutions’ own testimony. The conventional rights and reproduction business model no longer works for museums. The frequently repeated argument that open access museums can ‘afford’ open policies only because they charge admission fees is erroneous: almost half of the world’s open access museums and galleries do not charge entry fees.
On the opposite side, evidence from open access institutions shows that foregone revenue from image licensing is generally outweighed by greatly increased digital reach of museum collections online (most notably on Wikipedia), and open access raises brand visibility, which can bring new opportunities for revenue generation.’
‘If it’s difficult and/or expensive to get images of artworks from museums, people look for them elsewhere. Most museums lose more money than they make on image licensing. If it isn’t online, it doesn’t exist.’ — Merete Sanderhoff, Senior Adviser, SMK National Gallery of Denmark
‘Open access can never be bad news’, Merete Sanderhoff, 2017.
Open access has positive internal impacts within the institution
‘Open access is transformative inside museums. One year after the Cleveland Museum of Art’s open access launch, its chief digital information officer, Jane Alexander, noted the following impacts: increased updating of attribution, provenance and collections information; curators forging new connections with scholars; and resources being reallocated from responding to image requests to supporting digitisation. The vast majority of the museum’s online users who are looking for images now self-serve from its online collections, freeing up valuable staff time,’ Douglas McCarthy continues.
Text written by Douglas McCarthy, March 2022, and adapted from the article ‘The case for open access’ by Douglas McCarthy and Dr. Andrea Wallace, 2020.
Effie Kapsalis, Senior Digital Program Officer at the Smithsonian Institution, responds in similar terms: ‘Doing Open Access demonstrated to our leadership that good things happen when the larger Smithsonian works together and focuses on the whole. It is not a digital strategy. It did give me ammunition to say we need to get serious about it.’ More than 3.2 million digital collection images have been released for reuse in the Smithsonian Open Access program.
The benefits of the open ecosystem are greater than its parts
Andrew Lih, who advocates the Smithsonian Institution and the Metropolitan Museum to take advantage of Wikimedia projects, asks: ‘Are the income targets called for in the writing are the right measures? How does furthering the institution’s mission, quantitatively or qualitatively, factor into the equation?
Could the evidence and output that is currently available of the benefits of going open, have impacted FNG’s point-of-view, namely:
1. Better metrics about how open access materials have made an impact, both within the wiki ecosystem and downstream in places like Google, Apple Siri, Amazon, etc.
2. Case studies and stories related to secondary benefits of having open access out there. At places like the Smithsonian, Wiki edit-a-thons have inspired donations of artifacts and financial donations based on wiki/open work.
3. Forward-looking possibilities like AI and enrichment of the museum’s own metadata are possible through online collaboration.’
‘Open access in GLAMs has effects beyond single institutions. It creates an open ecosystem where cultural heritage that is separated in depots can be reunited in the digital realm,’ Larissa Borck, Curator/Digital Development at Sörmlands museum points out.
‘We don’t want to make it sound like open licensing is the whole strategy. It still takes work to promote reuse. Being open is the necessary component to make it even possible to begin with’, states Dominic Byrd-McDevitt, Data Fellow at Digital Public Library of America.
Karin Glasemann, responsible for digital access and development at Nationalmuseum in Sweden for the last 10 years, adds: ‘The more freely your collections move in the digital realm, the more people will be aware of it, the more money you can make with the museum’s actual service: to provide knowledge, education and entertainment around the collection.
The collection itself isn’t the museum’s asset or unique selling point, the people in the museum are, the knowledge they can provide and the community they can build.’
The Finnish government agenda aims to utilize and open up information comprehensively
Kimmo Levä writes that the time of open information is over.
We think that this view runs counter to the Finnish government’s information policy goals. Two days after the publication of the article, the Government approved a decision-in-principle emphasizing the comprehensive utilization and opening of data. The objectives of the decision-in-principle are in line with the EU’s data strategy.
The decision-in-principle states, inter alia:
‘Legislation and regulations oblige the opening of all publicly produced public administration information material, unless this is prevented by a valid reason (eg. information confidentiality, data protection, data security, intellectual property rights).’
‘Finland develops cross-sectoral cooperation networks and ecosystems for the utilization and opening of information and actively participates in their activities.’
Valtioneuvoston periaatepäätöksellä kohti kattavaa tiedon hyödyntämistä ja avaamista. Objective 1.2, subobjectives and objective 1.3, subobjectives.
It is difficult to find support for Levä’s view in the decision-in-principle. On the contrary, the time of open information is about to begin.
Towards new operating models
We should not underrate the resource challenges experienced by museums and other cultural heritage institutions. Is restricting the use of data and monetizing digital collections the best possible way to seek answers to these challenges, however?
Would an answer lie in museums’ digital consumer services, a possibility that Kimmo Levä also highlights, where the users experience something extra that they are willing to pay for? Besides these kinds of services, the actual collections data — both metadata and high-quality digital objects — could remain as openly available as legal and ethical considerations allow. So that the society at large would still benefit from it.
AvoinGLAM in discussion with the global Open GLAM and GLAM-wiki communities: Tuomas Nolvi, Maria Virtanen, Susanna Ånäs, and Tove Ørsted.
Further reading
Andrea Wallace: A Culture of Copyright: A scoping study on open access to digital cultural heritage collections in the UK. Towards a National Collection, February 23, 2022.
Dominic Byrd-McDevitt & John Dewees: Using DPLA and the Wikimedia Foundation to Increase Usage of Digitized Resources. Information Technology and Libraries, 41(1), 2022.
Karin Glasemann: Inside the Museum is Outside the Museum — Thoughts on Open Access and Organisational Culture, Medium, Mar 13, 2020.
Effie Kapsalis: The Impact of Open Access on Galleries, Libraries, Museums, & Archives, Smithsonian Emerging Leaders Development Program, April 27, 2016.
AvoinGLAM promotes Open Access to cultural heritage in Finland and works in collaboration globally. We are the initiators of the Finnish Hack4FI and the global Hack4OpenGLAM co-creation events.
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