This position paper supports the consultation of the European Commission and underlines elements critical to executing the Europeana Strategy 2020-2025 and to realising the potential of digital cultural heritage for the recovery of Europe.  

We believe that work must be underpinned by a long term approach, that includes sustainable funding structures and which supports:  

• coordinated national digital strategies for the cultural heritage sector

• targets for data quality and quantity

• the adoption of standards to enable access, reuse and engagement - particularly in education, research and the creative sector

• capacity-building efforts across the cultural heritage sector 

• strong infrastructures that reflect the role of national aggregators and Europeana 

Our hope is for a new Recommendation that commits the Commission and the Member States to support the sector in realising the digital transformation for the full benefit of Europe, the cultural heritage sector and its citizens.

The 2011 Recommendation on the digitisation and online accessibility of cultural material and digital preservation provided an important policy instrument aimed at enhancing digitisation efforts among the Member States in a concerted way and has undoubtedly contributed to: 

• raising the  amount  of openly accessible digitised cultural heritage content; 

• supporting Europeana as a focal point for European collaboration and knowledge exchange in cutting-edge areas like metadata interoperability, linked data, copyright reform, end-user engagement and impact assessment;

• stirring the development of national and thematic aggregators that coordinate and amplify relevant developments in their respective countries and domains. 

As such, it should be seen as a major contribution to the leading position Europe has in the field of digital cultural heritage today. Indeed in some areas, resultant activity goes beyond what was originally foreseen, for example in the use of digital material in education.

Looking to the future we need to also acknowledge that some areas that the current Recommendation sought to address have not yet been adequately met.  

For example, at this point, the European copyright landscape remains unharmonised. However, proper implementation of the Copyright in the Digital Single Market Directive should correct this situation, addressing remaining challenges and meeting the goals on the availability of public domain works. We are hopeful that countries will contribute to harmonisation throughout the Directive’s transposition period ending June 2021.

Other areas still require ongoing focus and effort. Key issues include:

• Digitisation targets have not been met consistently across Member States. One consequence of this is an imbalance in the representativeness of the Europeana collections, with only a limited amount of objects accessible from some countries and not all citizens able to find their region or country adequately represented. 

• Only 10-20% of the estimated heritage holdings have in fact been digitised (ENUMERATE). As a result, only a fraction are available through the Europeana collections. This is insufficient for the creation of a strong digital public space.

A future Recommendation can and should recognise the outstanding issues in today’s digitisation and digital preservation landscape, as it focuses on shaping that landscape for today and for the future.

Addressing digital in a coherent way in this changed and complex landscape is a challenge shared across society and sectors. This is evidenced in the European Commission’s focus on supporting Europe’s ‘digital transformation’, as seen in its Digital Agenda and now its vision for a future Europe based on the twin pillars of a green and digital transition. 

What digital transformation means and requires necessarily varies from sector to sector and their respective challenges.

In the context of this paper, we can understand digital transformation as the act of adopting digital technology or digital thinking to significantly transform an organisation’s operation, or the reframing of the organisation to be inherently digital in its purpose, or both.

As stated in the Europeana Strategy 2020-2025, for the cultural heritage sector digital transformation is therefore not just about technology and assets or how cultural heritage institutions operate - it is about how they think and about people and skills.  

Consequently, key areas such as digitisation, digital preservation and digital access must be addressed in their wider context and not in isolation.  

For example, digitisation of cultural heritage assets is a complex process that spans all areas of operation, from collections management to logistics, from human resources management to marketing and communications, and also requires the digitisation of institutional processes and workflows. 

A coherent approach requires a fundamental understanding of the relationship we want to have with our audiences, of digital skills, and the ability to evaluate choices, including which platforms and information channels to use. It requires a new open culture of working and collaborating. 

If we consider that the immediate response to the COVID-19 crisis required staff in many institutions to take on - at speed -  digital responsibilities that they had never been trained for, we see the emerging need for cultural heritage institutions to be able to develop and build on that capacity. And we must acknowledge that not all institutions have been able to respond in the same way. The digital divide sits not only between large and small institutions but also within institutions and between European Member States. 

Importantly, if Europe’s broader ambitions are to be met, it also means developing policy that promotes a more equitable and democratic digital environment, where basic liberties and rights are protected online, where sovereignty of data is protected, where strong public institutions function in the public interest, and where people have a say in how their digital environment functions and are able to participate more fully in its creation and use.

While some countries have established a national strategy for digital cultural heritage, the majority of EU Member States have not, resulting in differing approaches to digital cultural heritage. For example, standardisation of data on a central level is supported by frameworks such as the Europeana Licensing Framework, however adoption of those standards is inconsistent across Member States. Equally, while the majority of EU Member States have established some form of national aggregation, a significant proportion have not, and not all aggregators are resourced appropriately. 

The European sector would be strengthened if all Member States were required to design and publish strategies, which:

1. are national, multi-annual and forward-looking on digitisation and digital preservation;
2. embrace the big challenges of our times: social and economic inequalities, rising nationalism, climate change, the impact of tourism overloads in cities and fragile areas, algorithmic and Artificial Intelligence (AI) biases and resultant injustices, deep fakes, and fake news;
3. promote the adoption of standards developed in cooperation with Europeana as integral to the strategy. This should include encouraging wider uptake of the Europeana Publishing Framework, the Europeana Licensing Framework, and standards such as the Resource Description Framework (RDF) and SPARQL endpoints which are necessary to interconnect to other systems using Linked Data and APIs;
4. support and develop the role of national aggregators as capacity-building hubs, digital services’ providers, requirements and standards-setting bodies in each Member State;
5. involve the educational, creative and research communities in setting the priorities for the digitisation agenda;
6. include and address born-digital content and adopt binding measures for digital preservation;
7. adopt a human-centric and ethical approach to AI, further developed at EU level for cultural heritage and based on the European Commission’s White paper on Artificial Intelligence - A European approach to excellence and trust; 
8. envisage DCHE biennial country reporting.

Developing and delivering an effective framework  for digital capacity-building across the cultural heritage sector will be a key element in addressing the digital divide. Such a framework should:

1. be delivered by Europeana in consultation with the Member States;
2. acknowledge that building digital capacity requires a multifaceted approach that encompasses digital skills at a range of levels, including copyright, ethics and privacy issues, and looks to a ‘softer’ skill set that includes culture and leadership; 
3. take into account the varied levels of competence across countries and institutions. A basic model of digital competence levels should be applied to assess the differing needs of cultural heritage institutions;
4. include curation and digital strategy development to fulfil the potential of digital collections and galvanise user engagement; 
5. be rolled out and benchmarked across the EU Member States.

Increasing access and user engagement is key to maximising the impact of digital cultural heritage in society. Success in this area requires:

1. strengthening the link between digital cultural heritage and the wider cultural and creative industries, in particular in domains such as education, academic publishing, data-driven journalism, design, games, and city marketing where the use of heritage collections has significant potential;
2. continued prominence of the availability and reusability of public domain works through further measures to increase the online accessibility of public domain material, including an ambitious transposition of Article 14, Copyright in the Digital Single Market Directive. 
3. continued work on and support for the Europeana Impact Framework to provide a robust methodology at institutional and sectoral level for the measurement and demonstration of the socio-cultural impact of digital cultural heritage;.
4. recognition that, while national aggregation remains essential, aggregating collections at the European level can provide key added value, for example by enabling diaspora communities to have a more comprehensive view on their heritage and for that heritage to be more widely shared;
5. support from all Member States for joint pan-European campaigns around major themes (migration, gender equality, sports, etc.) to be developed via the Europeana Initiative;
6. strengthening of citizen science and crowdsourcing to increase community engagement in digital collection selection and curation.

Building on their investment to date and strengthening the Europeana Initiative to ensure its future contribution to the sector requires the Commission and Member States to:

1. continue to support Europeana in playing a coordinating role in all areas of activity around digital transformation of the cultural heritage sector in the EU;
2. support new members, especially SMEs and cultural heritage institutions without substantial digital collections to join Europeana;
3. increase EU financial investment in the Europeana Initiative in order to effectively implement the Europeana Strategy 2020-2025;
4. consider establishing another ‘Comité des Sages’ to revisit the New Renaissance report in the context of the new socio-cultural and technological realities.