Now more than a year into the revised NAGPRA regulations, practitioners are carefully considering how best to respond to the amendments, especially newly added components such as duty of care (§10.1[d]). Because associated records are not a defined category under the Act, however, practitioners have no guidance on how best to move beyond the return of Ancestors and cultural items to the long-term preservation and curation of the records that may remain once repatriation is complete. Since associated records play such a significant role in NAGPRA compliance, and since digitizing archaeological records has become commonplace in repositories across the country, we propose that curatorial facilities adopt a policy prior to digitizing records that contain information pertinent to NAGPRA. Considerations about Indigenous data sovereignty, privacy concerns, and sensitivity of certain themes or types of data should be factored into the decision-making process. This article provides a review of the relevant context and a step-by-step guide to creating a policy for your institution.
