On behalf of the delegates of the 31 member countries of the International Holocaust Remembrance Alliance (IHRA), among them 24 members of the European Union, I would like to express my deep concern with the European Commission’s proposal for a General Data Protection Regulation.
Ensuring open access to and the protection of Holocaust-era archival materials are at the heart of IHRA’s mission and are central to the commitments of 46 countries to the Stockholm Declaration on the Holocaust of 2000.
Although IHRA supports the European Commission’s efforts to ensure uniform protection of personal data online and offline to benefit citizens and business, IHRA believes that the provisions of the newly-created “right to oblivion” may have devastating effects on historiography in general and commemoration in particular. The current form of the proposed General Data Protection Regulation risks making it very difficult, if not impossible, to undertake research on individual victims, perpetrators and bystanders in the Holocaust and to use archival materials in Holocaust education and remembrance.
IHRA is concerned that the European Commission’s initiative could lead to the closing of archives or the destruction of personal information on Nazi victims and perpetrators, without which education, remembrance and research on the Holocaust will not be possible. It is a moral duty to preserve these authentic records for future generations.
As such, IHRA believes that the proposed regulation should contain only general provisions that acknowledge the need to balance the fundamental right to privacy and the protection of personal data with other legitimate public or national interests. It is of the utmost importance to Holocaust remembrance that the “right to be forgotten” should not entail the anonymization or destruction of Holocaust-era archival material.
IHRA is seeking high-level consultations with officials in Brussels to address this issue.