7
Pekka Henttonen
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL
Abstract
Finnish appraisal has been characterized as proactive, democratic, and “semi-jenkinso-
nian”. The idea of proactive appraisal was adopted from Sweden in the 1930’s. The goal 
is to make decisions about retention at an early phase in records’ life span. Appraisal 
is “democratic” in the sense that it has strived to leave a complete picture of the Finn-
ish society in the archives. This has been reflected in sampling methods that have lost 
their popularity with the advance of digitalization. Appraisal is semi-jenkinsonian in 
the sense that decisions about permanent retention are made in co-operation with the 
agencies in the national and municipal administration. Since the 1980’s, records man-
agement plans have been a vital part of the appraisal processes. Current challenges of 
appraisal include the need to appraise ambient functions (like healthcare, or social wel-
fare) instead of records of individual agencies, among others.
Keywords: appraisal, sampling, disposal, archival history, Finland
SVILUPPO DELLA VALUTAZIONE D’ARCHIVIO FINLANDESE
Sintesi
La valutazione finlandese è stata caratterizzata come proattiva, democratica e “se-
mi-jenkinsoniana”. L’idea di una valutazione proattiva è stata adottata dalla Svezia 
negli anni ‘30. L’obiettivo è prendere decisioni sulla conservazione in una fase iniziale 
della vita dei record. La valutazione è “democratica”, nel senso che ha cercato di lasciare 
negli archivi un quadro completo della società finlandese. Ciò si è riflesso nei metodi di 
campionamento che hanno perso popolarità con l’avanzare della digitalizzazione. La 
valutazione è semi-jenkinsoniana, nel senso che le decisioni sulla conservazione per-
manente vengono prese in collaborazione con le agenzie dell’amministrazione statale 
e municipale. Dagli anni ‘80 i piani di gestione delle registrazioni sono stati una parte 
vitale dei processi di valutazione. Le attuali sfide della valutazione includono, tra le al-
tre cose, la necessità di valutare le funzioni ambientali (come l’assistenza sanitaria o il 
benessere sociale) anziché i registri delle singole agenzie. 
Parole chiave: valutazione, campionamento, smaltimento, storia d’archivio, Finlandia
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
8
RAZVOJ FINSKEGA ARHIVSKEGA VREDNOTENJA
Povzetek
Finsko vrednotenje je bilo označeno kot proaktivno, demokratično in »pol-jenkin-
sonsko«. Ideja o proaktivnem vrednotenju je bila prevzeta po švedskem modelu v tri-
desetih letih prejšnjega stoletja. Cilj je sprejeti odločitve o hrambi v zgodnji fazi življenj-
ske dobe zapisov. Vrednotenje je »demokratično« v smislu, da si je prizadevalo pustiti 
popolno sliko finske družbe v arhivih. To se je odrazilo v metodah vzorčenja, ki so z nap-
redovanjem digitalizacije izgubile svojo priljubljenost. Vrednotenje je označeno kot na-
pol jenkinsonsko v smislu, da se odločitve o trajni hrambi sprejemajo v sodelovanju z or-
gani v državni in občinski upravi. Od osemdesetih let prejšnjega stoletja so bili načrti za 
upravljanje dokumentov bistven del procesov vrednotenja. Trenutni izzivi vrednotenja 
med drugim vključujejo tudi potrebo po vrednotenju funkcij okolice (kot sta zdravstvo 
ali socialno varstvo) namesto evidenc posameznih agencij.
Ključne besede: vrednotenje, vzorčenje, odstranjevanje, arhivska zgodovina, Finska
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
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First formal decision about archival appraisal of public records took place in year 1866 
when Imperial Senate purged some of its records. First plans for appraisal were made 
in year 1883. The person behind this was head of the National Archives of Finland, State 
Archivist Reinhold Hausen (1850–1942) who was active also when some financial re-
cords were purged in year 1906. Hausen was not the first State Archivist to have inter-
est in appraisal (Lybeck, 2014, pp. 308–309), but he was progressive in his ideas. While 
Hausen in many ways was a typical archivist-paleographer of his era and interested in 
publication of medieval documents (Litzen, 2000) he also understood need to restrict 
flood of records to the National Archives and did not hesitate to take an active role in ap-
praisal. However, at Hausen’s time there was no legal mandate for the National Archives 
to make decisions about appraisal. The decisions were made formally by the Senate or 
one of its ministries and only prepared by the National Archives. Some records were de-
stroyed also without any authorization. (Lybeck, 2016b, pp. 159–175; Mäenpää, 1994.)
First Archives Act was enacted in year 1939. The purpose of the act was more to protect 
records than to limit their number. Therefore, it stated that records of government and 
municipal agencies could be destroyed only with permission of the National Archives. This 
gave the National Archives a decisive, but passive role in appraisal: it could not act on its 
own initiative and give orders about disposition of records. (Lybeck, 2016a, pp. 179.) 
Even before this in year 1936 a committee – with State Archivist K. V. Blomstedt as its 
sole member – had been given the task to consider issues of archival appraisal. Blom-
stedt visited Denmark and Sweden and brought to Finland idea of proactive appraisal. 
This has had lasting influence on Finnish appraisal practices. In Sweden proactive ap-
praisal had been defended by arguments from archival theory. It was argued that de-
stroying records in a fonds violated principle of provenance. Therefore, it was better to 
destroy records before they were annexed to the fonds – naturally, this was to happen 
without endangering the fonds as evidence of activities behind its creation. In Finland, 
Blomstedt did not resort to theoretical arguments. His grounds for proactive appraisal 
were purely practical: retrospective appraisal was time-consuming and labor-inten-
sive, unless there was a large number of similar records that could be purged at once. 
(Mäenpää, 1994.)
Blomstedt noted that making decisions about appraisal would be an overwhelming 
task for one person. Therefore, and again following Swedish example, Committee for 
Reduction of Archival Documents (Arkistoaineisten supistamiskomitea) was founded in 
year 1947. The committee was in existence until the year 1970. It was chaired by State 
Archivist. Other members included representatives from provincial administration, 
Evangelic-Lutheran Church, Postal and Telegraph Service, and Ministry of Justice. The 
committee consulted historians and other specialists in its work. In practice, it drafted 
proposals for appraisal which were then approved by the National Archives. Inclusion of 
researchers was successful, and the work of the committee was generally productive. 
(Mäenpää, 1994; Nuorteva & Happonen, 2016, pp. 237–241.) 
Thus, agencies were involved in the appraisal process. Besides proactive approach, this 
has been a characteristic of Finnish appraisal since. Therefore, Finnish appraisal has been 
described as “semi-jenkinsonian” (Voutilainen et al., 2020). In the beginning involving 
agencies was not easy. Agencies were unfamiliar with the concept of appraisal and with 
needs of researchers. Therefore, when the committee asked agencies to suggest re-
cords that might be destroyed, the agencies were often unable to identify any or they 
found only few records belonging to this group. Sometimes they suggested purging 
such records that are generally considered to have permanent value. (Mäenpää, 1994.)
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
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Proactive appraisal was formulated for the first time in instructions for municipal agen-
cies in year 1941. The instructions stated that records with limited retention time should 
be put in series of their own and the retention time should be noted in the archival 
inventory so that these records could be later easily separated from others. (Lybeck, 
2016a, pp. 202.) It was customary to take disposal actions on series level. It was also 
suggested that registry office might mark retention times on files when they are cre-
ated (Blomstedt, 1947, pp. 7–8). This practice was never recommended by the National 
Archives, but nevertheless, it was the practice that was followed occasionally, at least in 
the archives of one of provincial governments (T. Voutilainen, personal communication, 
29 November 2021). 
The National Archives of Finland had adopted early in the 20th century a records’ classifi-
cation scheme from Sweden. The scheme was very simple. The records were divided in 
main series according to their form regardless of subject matter; “Registry books”, “Lists 
and Inventories”, “Minutes”, “Incoming letters”, “Outgoing letters”, “Financial Records”, 
etc. Every main series was identified by a capital letter and subseries by one or more 
minuscules. Thus, for instance, the series for registry books – this was main series (A) in 
scheme’s Finnish version which differed from the Swedish in some details – was usually 
divided into two sub-series: registry books in matters that were initiated by govern-
ment agencies (Aa) and registry books for other matters (Ab). This “ABC-scheme” was 
created by Swedish State Archivist Emil Hildebrand in year 1903. Internally it was ap-
plied in the National Archives of Finland to a fonds in year 1911 (Lybeck, 2016b), but the 
National Archives began to promulgate its wider use in state and municipal agencies 
only in the 1940’s. (Orrman, 2019a.) 
ABC-scheme was in effect a simple indexing language. Its disadvantage was that it did 
not reveal anything about the functions of an agency or subject matters that the agency 
dealt with. On the positive side, this made the scheme generally applicable: regardless 
of their functions all government and municipal organizations had registries, they sent 
and received letters, kept track of financial transactions, etc. The scheme brought across 
fonds welcome uniformity, and therefore, it was favored in the National Archives in 
comparison to functional classifications. (About discussion, see e.g. Haila, 2018; Jääskel-
äinen, 2000.) The ABC-scheme dominated knowledge organization in Finnish archives 
and records management until functional classifications gradually replaced it in last 
decades of the 20th century. ABC-scheme was still the model to be followed when the 
National Archives gave instructions to municipal archives in year 1979 (Orrman, 2019a).
Instructions for municipal authorities (1941) stated that records whose “permanent re-
tention appears to be clearly unnecessary” should be put in a series of their own, if possi-
ble (Valtionarkisto, 1941, pp. 9). Government agencies were instructed to take care that 
it is possible to purge larger sets of records “according to a pre-existing plan” instead of 
individual documents one by one (Virastotyö tehokkaaksi III, 1948, pp. 50). It was said 
that registry classification scheme should be such that one class in a registry should con-
tain only records with identical retention time (Arkistolaitos, 1995, pp. 12; Asiakirjojen 
käsittely ja säilytys, 1984, pp. 27). At least one agency, Provincial government in Mikkeli, 
purged records by their registry class, but it is not known how widespread this practice 
was (T. Voutilainen, personal communication, 29 November 2021).
ABC Scheme was applied mainly to records of permanent value, but sometimes ephem-
eral series were included in it. An example of inclusion of ephemeral series can be found 
in instructions for the Finnish Defence Forces (1974). The instructions stated that main 
series J was to be divided into three sub-series according to retention time of records; Ja 
was for records to be purged after one year, Jb after three years, and Jc after ten years. 
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
11
These sub-series had further subdivisions. For instance, “General orders for the garri-
son” was one of the series to be purged after three years, sub-sub-series Jbd. (Puolus-
tusvoimain arkistokaava ja kirjelmäryhmitys, 1974). 
In short, although the idea of proactive appraisal was adopted in the 1930’s full reali-
zation of the idea took decades. For a long time, there was often need for retrospective 
disposal actions. Despite guidance and archival education, agencies did not have inter-
est in making proposals about records’ disposal to the National Archives. Only when 
there was no storage space left they simply suggested most space consuming records 
to be purged without consideration for needs of record keeping. (Haila, 2018, pp. 33) 
From the 1950’s the Committee for Reduction of Archival Documents prepared dispo-
sition plans whose purpose was to reduce number of records to be preserved. (Lybeck, 
2016a, pp. 181). First decision about retention times for ephemeral records is from year 
1951 (Haila, 2018, pp. 9). 
Experiments in sampling
One has tried in Finland to get in archives a representative picture of the society instead 
of documenting only exceptional events and elites (Lybeck, 2000). To attain representa-
tiveness records sampling has been a popular in Finnish appraisal. Many of the sampling 
methods are adaptions of common statistical methods. For instance, both random sam-
pling and systematic sampling method have been used in Finland (Leppänen, 1995; for 
sampling methods, see Coessens & Heirman, 2020). Only a sample of records has been 
preserved in cases in which the records are voluminous, or mostly identical, and their 
information content is limited or rarely unique (Leppänen, 1999). 
Sampling or – to be more exact, how a sampling method is applied – is not without 
weaknesses. For instance, in year 1990 the National Archives decided that records from 
debt recovery proceedings would be preserved permanently only if they were dated 
in a year ending with zero. When economic crisis hit Finland hard in the beginning of 
the 1990’s, this decision meant that information from this catastrophic period would be 
incomplete. The appraisal decision was quickly modified, but some of the records had 
already been destroyed (M. Leppänen, personal communication, 27 May 2006).
Sometimes decisions about permanent preservation have been unclear and open for 
multiple interpretations. The National Archives has in some cases stated that records from 
every fifth year are to be preserved permanently but left undefined what “every fifth 
year” means. Administrative processes often span multiple years. Some agencies took the 
year when an administrative process began as the starting point, others the ending year. 
Thus, the result was inconsistent, and the files preserved disparate. Naturally, this is an 
outcome from inadequate instructions and insufficient guidance, not a fault of the sam-
pling method (T. Voutilainen, personal communication, 29 November 2021). 
Most interesting sampling methods are those that have been devised particularly for 
records sampling. Birthday sampling is perhaps typical for Nordic countries. It has been 
applied to voluminous medical records, among others (Vallenius, 2021). In birthday 
sampling records of persons born on specific days of month are preserved; in Finland, 
these days are 8th, 18th, and 28th. In other Nordic countries the days are different, but 
the principle is same. The idea is that preserving information about same persons in dif-
ferent fonds gives researchers most versatile view on the life of individuals and allows 
usage of this information in various combinations. (Leppänen, 1995; Orrman, 2019b; 
Orrman, 2019c). It also enables following some persons’ life span from cradle to grave 
(Vallenius, 2021). 
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Other sampling experiments have included type fonds and Mini-Finland. A “type fonds“ 
is preserved more completely than other similar fonds, that is, fonds from agencies hav-
ing the same function. Thus, it is a type fonds is an example of a fonds that has not gone 
through the appraisal process. Often type fonds belong to agencies in “mini-Finland.” 
Mini-Finland was a set of areas that the National Archives compiled in the 1950’s togeth-
er with the Central Office for Statistics. The idea was that one would preserve more re-
cords from these areas, and thus, have a representative sample of the whole country 
(Leppänen, 1995; Orrman, 2019b, 2019c).
Today sampling is largely forgotten as a method for appraisal. Yearly accrual became 
too large which forced to abandon the concept of type fonds in the 1980’s. Mini-Finland 
was challenged by changing administrative structures and borders. Birthday sampling 
was also a disappointment. Birthday sampling did not serve medical research like it was 
hoped. For instance, it is not useful in tracking hereditary diseases (Vallenius, 2021). 
However, the most important reason for the disfavor of sampling methods is that in 
digital environment they do not bring significant savings in storage space. On the oth-
er hand, it must be noted that the need to minimize preservation of personal data has 
again revitalized interest in archival sampling (T. Voutilainen, personal communication, 
29 November 2021). 
EMERGENCE OF RECORDS MANAGEMENT PLANS
Next significant step in Finnish appraisal was paradigm change in the 1970’s. At that time 
attention shifted from archives as historical accumulations of records to information 
management in government and municipal agencies. Interest in information manage-
ment had risen already in the 1940’s and 1950’s, but now creation of a fonds became the 
focus of archival thinking and practices. In modern terms this might be seen as develop-
ment of records management, but at what point Finnish records management is born 
is debatable and depends on what is understood by the concept. Practice of keeping 
registries had always kept archives in close contact with daily work in organizations. In 
addition, proactive appraisal may be seen as “records management” of a kind. (Lybeck, 
2016a, pp. 176, pp. 217–218.) On the other hand, if records management means looking 
records solely from organizational perspective by a profession that it is distinct from the 
archivists, Finnish public sector organizations may still lack records management.
Already in the 1960’s it had become increasingly clear that expanding administration 
required more flexible approaches. Quantity, quality, and content of records was sim-
ply too diversified to be managed by the now old-fashioned ABC-schema. Although 
the National Archives was still satisfied with it, the schema did not serve agencies 
in their work. Thus, a gap was forming between archives and work practices in the 
agencies. At the same time, appraisal had to be intensified. In the 1970’s about one 
third of records was preserved permanently. This was too much. The new goal was 
now to preserve 15–20 % of records. This required more stringent disposal measures 
 (Haila, 2018, pp. 39). 
It seems evident that one of the problems was that the National Archives operated 
blind-folded. The 1941 instructions for municipal agencies stated that 
“…all records belonging to the municipal archives are to be preserved if the le-
gislation does not state otherwise. Records that are unnecessary may be ne-
vertheless purged with the permission, or following the instructions… of the Na-
tional Archives” (Valtionarkisto, 1941). 
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
13
From this one may conclude that the National Archives could not have the big picture of 
records in municipal agencies. It was notified of the existence of records only when one 
wanted to purge them. Secondly, the National Archives could not act without initiative of 
an agency. In this situation setting national goals for appraisal must have been challenging.
There were different ideas about what should be done. The situation was problematic 
for many reasons. A breakthrough was idea that archivist should be able to proactive-
ly and systematically steer how a fonds is formed in the work of an agency (Lampela, 
2016, pp. 21). The older Archives Act of 1939 had excluded registration and filing from 
the domain of archives management, but as a sign of the new approach they became 
under its control in year 1981 in the new Archives Act (Orrman, 2015). 
A new tool for planning records’ life span had appeared in the middle of the 1970’s in the 
courses of the National Archives (Haila, 2018, pp. 45). The new Archives Art (1981) made 
this new tool mandatory for every government and municipal agency. The act stipulated 
that every government and municipal agency must have a Records Management Plan (ark-
istonmuodostussuunnitelma, literally “Archives Creation Plan”). Similar plans (in Swedish 
arkivbildningsplan) had existed in Sweden since the 1960’s, but unlike in Sweden, in Fin-
land agencies were now obliged by law to maintain such a plan (Lybeck, 2006, pp. 79). 
In a Records Management Plan all the records created by the agency are grouped by 
function in which they are created or received. The plan indicates the retention times, 
whether the records are registered, and lists places where they are stored first short 
time and then for longer periods. The plan also shows the arrangement of records and 
their series in the physical fonds if the retention time warrants such a location; most re-
cords do not need it. Thus, from the plan one gets comprehensively information about 
records’ context, management, and archival organization (Lampela, 2016, pp. 32). 
Records Management Plans are still a requirement stipulated in the Archives Act. They 
are significant for number of reasons. Firstly, although it is possible to apply the plans 
retrospectively, they are about records that are to be created or received in the adminis-
tration. Thus, they made proactive appraisal the norm to be followed. 
Secondly, Records Management Plans integrate records continuum (Valtonen, 2005, pp. 
49). The plans ideally serve different stakeholders, although in practice keeping them 
up to date has been difficult and they have been underutilized in agencies (Lampela, 
2016, pp. 32–33; Lybeck, 2000):
1. For administration, the plans are a guidebook to be followed in its daily work. 
2. The plans serve content-based information retrieval because in them records with 
similar content and function are grouped together. 
3. For records management, the plans enable efficient planning and steering of records 
processes and record life span.
4. For the National Archives the plans are disposition proposals. The National Archives 
accepts the plans and uses them to select part of the records that is to be later pre-
served in its custody permanently. 
5. The plans also collect from the agencies information that can be used in archival de-
scriptions.
In the core of the plans is a functional classification in which all record types were listed. 
Retention time is defined by combination of functional classification and record type: 
for instance, an incoming letter in function A may have a different retention time from 
other records created in the same function and from incoming letters in function B. This 
allows making finely tuned decisions about what information is to be preserved.
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
14
APPRAISAL IN ELECTRONIC RECORDS MANAGEMENT SYSTEMS
Figure 1: Managing records’ life span in SÄHKE1
Thus, Finnish archival thinking was geared towards proactive and function-based records 
management already in the 1980’s before digitalization. By the turn of this century Finn-
ish government was taking further actions to develop public sector information manage-
ment. The National Archives was given the task to develop long term preservation of elec-
tronic records. This eventually led to development of functional requirements for Finnish 
electronic records management systems. Evaluation of electronic records management 
systems in year 2002 had revealed that systems in use were not adequate for manage-
ment of electronic records. They were built on software from foreign vendors, and conse-
quently, often lacked or did not fully support special characteristics of Finnish recordkeep-
ing; proactive appraisal, Records Management Plans, and keeping registries. Therefore, 
in 2005 the National Archives published its own specification for functional requirements 
(SÄHKE1) in which these national features were considered (Pohjola & Happonen, 2014). 
In SÄHKE1 compatible systems a record stored in the system gets its retention time and 
other critical metadata values from the system’s Records Management Plan (see Fig. 1). 
The values determining retention time are based on the record’s functional class and type. 
In the second version of SÄHKE (2008) Records Management Plan was separated to a 
system of its own. The idea was that this new information system (called “Information 
Control System”) would take care of management processes and interact with other in-
formation systems via application programming interfaces (APIs). The Information Con-
trol System would automate records management processes across the organization 
and be a general source of metadata. Unfortunately, this vision has had only limited 
success outside electronic records management systems. 
FINNISH THEORY OF APPRAISAL – OR LACK OF IT 
Public theoretical discussion has been practically non-existent. Finnish approach to ar-
chival appraisal has been described as pragmatic. There has not been a “grand theory” 
that would guide decisions about appraisal. It has been argued that this is actually a 
strength, because it safeguards appraisal from bias: a flaw in the grand theory would be 
reflected in all decisions that are based on it, but decisions made from purely pragmatic 
point of view are sometimes good and sometimes bad (Lybeck, 2000). 
In “Appraisal 2000” -project the National Archives examined its tradition critically, codified, 
and refined principles of appraisal for the first time while it also tried to enhance quality 
DEVELOPMENT OF FINNISH ARCHIVAL APPRAISAL PEKKA HENTTONEN
15
of appraisal by applying new principles. Instead of creating a “grand theory” the goal was 
to create “a balanced view that takes different perspectives and approaches into account.” 
(Lybeck, 2000). Appraisal of the National Archives was described as “practical, down to earth 
approach that is proactive and founded upon co-operation with the agencies” (Repo–Le-
hikoinen, 2001). The result was for the first time (2008) a document describing appraisal 
policy and a manual for those who drafted appraisal decisions in the National Archives. 
Finnish appraisal tradition is clearly a compilation of influences from many sources. Schel-
lenberg’s value theory has been very influential in Finland (Lybeck, 2000). Sweden and 
Germany were important models for appraisal in the 1920’s and in the 1930’s, although it 
is difficult to point out ideas and practices that came from a particular country. Term seu-
lonta (separating important from non-important) is probably of German origin (Sichtung). 
Idea of importance of administrative hierarchy was probably adopted from Germany. Fur-
thermore, principle of preserving a copy of sent letters in archives follows a German mod-
el. On the other hand, interest in sampling methods has Swedish origin and Sweden has 
altogether had bigger influence in Finnish appraisal than Germany (Lybeck, 1998). 
The appraisal policy documents have been revised twice since, in years 2012 and 2020. 
Macro-appraisal is perhaps now more clearly than ever starting point for appraisal pro-
cess, although macro-appraisal was included already in the 2008 versions of policy doc-
uments (Arkistolaitos, 2008a; Arkistolaitos, 2008b). After macro-appraisal – evaluation 
of functions and actors – focus is shifts to content of the records, to form in which the 
information is to be preserved (born digital information is now preserved digitally as a 
rule) and costs of preservation (Kansallisarkisto, 2020). 
CURRENT CHALLENGES OF APPRAISAL
Finnish appraisal is currently challenged in three ways, at least. The first challenge 
comes from legislation. The current Archives Act (1994) is outdated and conflicts with 
more recent legislation and with the General Data Protection Regulation of the Europe-
an Union. Therefore, the Archives Act will be renewed in years to come. At this point also 
appraisal process in public administration and the role of the National Archives may be 
re-examined. A new requirement is that long-term preservation must have legal basis 
and, hence, the new law must be written to support decisions about appraisal. Until 
now grounds for long term preservation have been in the discretion of the National Ar-
chives (Tiedonhallinnan lainsäädännön kehittämislinjaukset, 2017, pp. 141).
Second change is a consequence of the digitalization. Before digitalization appraisal 
and accessioning of records were more in the domain of recordkeeping professionals. In 
past when representatives of the National Archives discussed disposal with an agency, 
they were usually confronted with its records manager or archivist. In digital environ-
ment appraisal process has become more complex. Privacy issues must be considered 
in a new way. Because of technological questions disposal may be complicated and 
expensive. Data may have value as “new oil.” In short, there are more stakeholders to 
appraisal. Therefore, when an archivist from the National Archives today meets people 
from an agency there is often a spectrum of professionals to negotiate with; besides 
recordkeeping professionals, there are other information professionals, managers, 
ICT-professionals, and lawyers.
Thirdly, digitalization challenges traditional agency-based paradigm of Finnish archival 
appraisal. From the point of view regulations, appraisal still takes place either organi-
sation by organisation (e.g., police department by police department), or at its best, by 
appraising similar organisations at one stroke (making decisions that apply to all the 
police departments). 
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16
However, one should be able to appraise ambient functions. In any field of the modern 
networked society there are today multiple actors in interaction. Therefore, ideally one 
could appraise fields like “social welfare” or “health care” as a whole: to have first the 
big picture of actors, interrelated functions, information flows, and systems, and only 
then make decisions about what is important enough to be preserved. Generally, this is 
not possible. Agencies make and renew their Records Management Plans independent-
ly and sometimes in separation from others working in the same field. The plans come 
to the National Archives for approval at different times one by one. Thus, appraisal de-
cisions are piecemeal. The National Archives combats this fragmentation by encourag-
ing co-operation and branches of administration to making joint disposal proposals for 
their sector (for instance, National Courts Administration on behalf of all the courts) but 
currently this is not required in the legislation.
Fourthly, shared information systems are problematic. Agencies may have a legal obli-
gation to deliver their data to a shared information system, but in legislation no-one has 
been given responsibility to preserve this information. Data in a shared system may also 
duplicate data in the agency (T. Voutilainen, personal communication, 29 November 2021)
Finally, the National Archives still needs the initiative of an agency: appraisal process 
starts when an agency sends its Records Management Plan to the National Archives for 
approval. The National Archives would like to have a more active role, but also this re-
quires changes in the legislation. 
In summary, current situation requires corrective legislative actions, and, in addition, 
new methods that allow appraisal transcending organisational borders. The current Ar-
chives Act (1994) will be renewed in years to come. Hopefully, it will be a step forward.
REFERENCES
Arkistolaitos. (1995). Kirjaaminen valtion virastoissa ja laitoksissa [Registration in govern-
mental and municipal agencies]. Arkistolaitos. 
Arkistolaitos. (2008a). Arkistolaitoksen seulontapolitiikka 2008–2010 [Appraisal policy of 
the National Archives Service 2008–2010]. AL/15199/07.01.01.03.00/2008. 
Arkistolaitos. (2008b). Arkistolaitoksen seulontastrategia 2008–2010 [Appraisal strategy of 
the National Archives Service 2008–2010]. AL/15199/07.01.01.03.00/2008.
Asiakirjojen käsittely ja säilytys [Handling and management of records]. (1984). Helsinki: 
Valtiovarainministeriö. Järjestelyosasto. 
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