The IP SIG meeting in Portland is going to consider the possibility of getting 
together and working on a fair use best practices for museum collections, along 
the lines of what the documentary film makers have done: 
http://www.centerforsocialmedia.org/rock/backgrounddocs/bestpractices.pdf. 
Other "industry groups" have banded together as well: there's safety in numbers 
and consensus (if you can reach it) and it might be a way for us not to have to 
reinvent the wheel at each institution. 

Deb Wythe
Brooklyn Museum
deborahwythe at hotmail.com 




> Date: Wed, 16 Sep 2009 12:46:03 -0400
> From: RealW at CarnegieMuseums.Org
> To: mcn-l at mcn.edu
> Subject: Re: [MCN-L] rights question
> 
> Hi everyone,
> 
> This is a timely discussion for us as we are looking ahead to a redesign
> of our web site and online collection.
> 
> I believe that a few museums have taken the position that publishing
> copyrighted images, in "thumbnail" size only, on their online
> collections, is fair use. I don't know if they publish thumbnails of
> copyrighted works only after a reasonable effort to secure permission,
> or whether they simply publish them without asking. I believe they
> arrived at their policy with legal counsel.
> 
> I don't think there is any commonly-accepted definition of what
> constitutes a thumbnail that would pass a fair use test (100 pixels? 250
> pixels?).
> 
> I'd be interested to hear your opinions: is this approach is an emerging
> trend in the museum field, and/or is there is an emerging understanding
> in the field regarding what a "thumbnail" is?
> 
> Our own legal counsel has suggested that it would be difficult to make
> generalized policies about which images could be published under this
> kind of approach; they recommended we consider each case on its own
> merits--not exactly what we were hoping to hear. In many ways it boils
> down to a risk assessment. 
> 
> Will Real
> Carnegie Museum of Art
> Pittsburgh PA
> 
> -----Original Message-----
> From: mcn-l-bounces at mcn.edu [mailto:mcn-l-bounces at mcn.edu] On Behalf Of
> Eve Sinaiko
> Sent: Tuesday, September 15, 2009 4:02 PM
> To: 'Museum Computer Network Listserv'
> Subject: Re: [MCN-L] rights question
> 
> > 
> > On Sep 14, 2009, at 2:29 PM, Weinstein, William wrote:
> > 
> > We are evaluating our policy regarding obtaining rights for images of
> > works we publish in our online collection section.   The issue of what
> > to do with works where there is an apparent copyright holder that can 
> > either not be contacted or does not respond to repeated permission 
> > requests.  Does anyone have a position of what to do regarding works 
> > in this particular state of limbo?
> > 
> > Bill Weinstein
> 
> > Bill, legally if you do not have permission, you may not use the work.
> > There is no mechanism in US copyright law to help you.  However, if 
> > you are based in Canada, there is an unlocatable copyright owner 
> > provision which can help you just in that circumstance.  And it is 
> > possible that you can use it if using a Canadian work (though I would 
> > have to double check to see who is eligible if you are not in Canada.)
> > 
> > Lesley
> > 
> > Lesley Ellen Harris
> > lesley at copyrightlaws.com
> > www.copyrightanswers.blogspot.com
> 
> 
> I think this is an incomplete answer. I'm not a lawyer, so I can only
> speak to how many publishers and museums are addressing this question in
> practical terms, on the ground. If I've gotten any of the legal aspects
> wrong, please correct me. 
> 
> There are two kinds of "in limbo" works: 1) Those known still to be in
> copyright or probably in copyright (because they are not very old), for
> whom no rights holder can be found; and 2) those whose rights holder
> ignores repeated efforts to obtain permission. 
> 
> The first group are Orphan Works (OWs)--works still in copyright for
> whom no known rights holder can be found. Congress has been working on
> legislation to deal with OWs for several years. Last year the Senate
> passed an OW bill, but the House version died. It's uncertain whether
> the bill will be revived any time soon or not. Absent an OW law, users
> must consider whether they may assert fair use. (At museums, a common
> type of OWs are archive photos of objects, where the object is out of
> copyright but the photo is not, the photographer's name is missing, and
> the museum has no document to indicate that the photo was made as a work
> for hire.)
> 
> The second group includes works where the copyright holder has been
> found and is not responding, or works where it's not absolutely clear
> who the rights holder really is (e.g., two different nephews of a dead
> artist both claim to own the rights, or a work by an artist may have
> been made while he was on staff somewhere and therefore be a work for
> hire). 
> 
> For the second group, as for the first, fair use may be an option. One
> also has to evaluate whether the use one wants to make of the work is
> protected under fair use (or in the UK, under fair dealing). The
> Stanford Fair Use Project has a very good, clear rundown of fair use and
> how it works:
> http://fairuse.stanford.edu/Copyright_and_Fair_Use_Overview/chapter9/ind
> ex.h
> tml
>   
> Fair use depends on the context of the use, so institutions should
> develop guidelines on fair use in consultation with legal counsel--both
> for using works in their own collections and for when others use works
> whose copyrights you control. In the last couple of years there have
> been some important court decisions strengthening the assertion of fair
> use for visual images. Thus, it's not always the case that one must not
> publish a work because the rights have not been cleared. Especially in
> the case of those OWs where it's pretty clear that there is no living
> rights holder, publication may be very low-risk.  
> 
> Fair use and fair dealing are US- and UK-specific, and some institutions
> are concerned that in the internationalized realm of the Internet such
> laws may not fully protect uses. A practical approach to the problem
> that some websites and publishers adopt is to make every effort to
> obtain all permissions, and document the efforts, and then to publish
> the works with a notice that states: 
> 
> "The museum has made all reasonable efforts to ascertain the rights
> status of all works reproduced on this website. Any corrections should
> be sent to the attention of [name/digital rights administrator]." 
> 
> Or: 
> 
> "All reasonable efforts have been made to identify and contact copyright
> holders but in some cases these could not be traced. If you hold or
> administer rights to works posted here, please contact us. Any errors or
> omissions will be corrected." Such disclaimers are becoming more common
> and at a minimum are useful in demonstrating the publisher's good faith.
> If a rights holder should come forward and object to the use, prompt
> removal of the image may be sufficient remedy. 
> 
> In other words, in crafting a policy for the use of works where it's not
> possible to obtain permission, an institution, in consultation with
> counsel, should to consider several things: 
> 
> ~Develop guidelines for doing a proper fair-use assessment in individual
> cases and develop a protocol so that all staff who are responsible for
> rights clearance know how to make a good assessment (and when to consult
> counsel); ~Develop guidelines for what constitutes a sufficient search
> for a rights holder and put in place a program to ensure that staff
> understand it; ~Develop a protocol for rights search documentation and
> document retention; ~Determine its comfort zone with respect to use of
> works that fall into a "gray area" such as OWs; ~Decide whether its own
> internal policy with respect to the use of such works is also going to
> be its policy when others outside the institution make use of a work
> whose rights are controlled or administered by the institution; ~Assess
> the status of the works you want to use. If the rights owner is known to
> be active in asserting rights but for some reason has not been answering
> your request letters, you should not consider that work to be "in
> limbo"; ~Don't be guided by your own convenience: your policy should not
> be driven by a desire to avoid paying legitimate rights fees, or a
> desire to publish fast, without waiting for a slow responder to write
> back (perhaps from a distant country or an understaffed museum), or a
> desire to avoid masses of rights-clearance paperwork. 
> 
> In these notes, I don't mean to encourage users not to clear rights. I'm
> only suggesting ways to address the small group of works that are truly
> in limbo. 
> 
> Regards,
> Eve Sinaiko
> 
> 
> 
> 
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