Gardens, Libraries & Museums (GLAM) Human Remains Policy
Table of contents
5. Claims for the Return of Human Remains
6. Procedures for Making a Claim
Appendix: the Criteria that the University will consider
1. Introduction
In 2006 the Policy on Human Remains held by the University of Oxford’s Museums was developed and published in line with recommendations from the UK Government Department of Culture, Media and Sport (DCMS) 2005 Guidance for the Care of Human Remains in Museums. The 2006 policy was published in the Oxford University Gazette, Supplement (2) to no.4787 on the 15th of November 2006. In 2024 a GLAM Restitution Policies working group was formed to update and review the policy as part of good practice recommended in the DCMS Guidance. A cross-GLAM Museums subgroup was formed to update the policy. This policy and the procedures for making a claim updates and replaces the 2006 policy. This policy was approved by Oxford University Council on 13 July 2026 and shall remain in place until a revision is issued.
This policy specifies the standards the University’s museums and libraries will adhere to with respect to the acquisition, storage, management, research upon, access to, and display of the human remains held in the collections of the museums and libraries of the University of Oxford. The procedures which will be followed when claims are made for the repatriation of human remains, and the circumstances in which the University may accede to claims, are outlined below.
This policy does not apply to claims for the return of cultural objects, which are governed by the Procedures for claims for the Return of Cultural Objects.
1.1 GLAM comprises five institutions which currently hold human remains:
- The Ashmolean Museum of Art and Archaeology
- The History of Science Museum
- The Oxford University Museum of Natural History
- The Pitt Rivers Museum
- The Bodleian Libraries
These institutions hold internationally important collections which include works of art, scientific instruments, natural history specimens, archaeological, ethnographic collections and archives and libraries related to them.
1.2 These collections are a most important resource for teaching and research, both to the University and to visiting scholars from around the world. Wherever possible and appropriate, the collections are also made widely accessible to members of the public by means of display, through educational programmes and through loans to other collections and online. All the collections in the five institutions have been ‘designated’ by Arts Council England as being of national or international significance, and the institutions themselves collectively receive more than a million visitors a year.
1.3 The collections of each of the five institutions include human remains, both modified and unmodified. These include hair and tissue samples, preserved bodies and parts of bodies, skeletal remains, fluid preserved specimens and artefacts made from or incorporating human remains. Everything listed here is included within the definition of human remains under, and so falls within the scope of, this policy.
1.4 The reason for the University acquiring and holding human remains has evolved over time. Human remains were acquired for research, display and teaching across scientific, humanities and social science disciplines. Human remains are stored and managed to national and international standards but the ethics with regards to keeping human remains has changed significantly in the past century.
1.5 The University recognises that certain human remains and artefacts made from or incorporating human remains are culturally sensitive. Some human remains were undoubtedly obtained in circumstances that today are regarded as unacceptable and need redress. The use of human remains in research and display has to be balanced against ethical considerations including the claims of genealogical descendants and cultural custodians and changing disciplinary practices (including in medicine, anthropology, archaeology and museum studies).
2. Scope
2.1 The definition of ‘human remains’ used in this policy is informed by the definition in the DCMS Guidance. ‘Human remains’ comprise the bodies, and parts of bodies, of once-living people from the species Homo sapiens (defined as individuals who fall within the range of anatomical forms known today and in the recent past). This includes osteological material (whole or part skeletons, individual bones or fragments of bone and teeth), soft tissue including organs, skin, hair and nails, embryos and slide preparations of human tissue.
2.2 Human remains also include any of the above that may have been modified in some way by human skill or physically bound up with other non-human materials to form an artefact composed of several materials. Another but much smaller category of materials included in this definition is that of art works composed of bodily fluids and / or soft tissue.
2.3 For the purposes of this policy, ancestral remains are recognised within part of the wider definition of human remains and the two terms are used interchangeably within this policy.
2.4 In the case of claims relating to composite objects which incorporate human remains they will be dealt with under this policy.
3. Inventory of Collections
3.1 Each museum holds an inventory of its collections which may be publicly available through online collections portals. Basic details can be found for most human remains collections through these. However, detailed information requests should be made via the relevant museum and holding department.
3.2 List of contacts:
The Ashmolean Museum of Art and Archaeology
collections-directorate@ashmus.ox.ac.uk
The History of Science Museum
collections@hsm.ox.ac.uk
The Oxford University Museum of Natural History
life@oum.ox.ac.uk
The Pitt Rivers Museum
objects.colls@prom.ox.ac.uk
The Bodleian Libraries
https://www.bodleian.ox.ac.uk/collections-and-resources/special-collections
4. Collections Management
4.1 Each institution will be guided on all aspects of collections management according to their institutional Collections Development Policy required under the Arts Council England UK Museum Accreditation Scheme with reference to relevant standards, for example Spectrum. Furthermore, the DCMS Guidance provides extensive guidance on the extra procedural responsibilities and ethical principles of managing collections of human remains for the following primary procedures and activities (4.2-4.6)
4.2 Acquisition. GLAM’s institutions may in certain circumstances consider acquiring further human remains—In this event, the institution will follow their Collections Development Policy with reference to the DCMS Guidance.
In the event of future acquisition of human remains, the receiving institution will be subject, as appropriate to the Human Tissue Act 2004 and will, where relevant, be guided by the Human Tissue Authority in that respect.
4.3 Loans. With the agreement of the individual institutions’ Governing Bodies, human remains may be loaned to other institutions for display and/or research, provided that the borrowing institution meets legal, ethical and practical considerations.
4.4 De-accessioning & Disposal. Human remains may be de-accessioned, for instance (a) in response to approved claims for return submitted in accordance with the University’s procedure for the consideration of claims (see paragraph 5), or (b) in accordance with agreed inter-institutional policies for the location of certain types of material. On such occasions the de-accessioning institution will need to be satisfied that the remains will be appropriately dealt with within the accepted framework of legal, ethical and practical matters.
Where an institution wishes to deaccession and dispose of human remains otherwise than in accordance with (a) and (b) above, the relevant institution will work to establish whether any genealogical or cultural descendants exist who might wish to make a claim for return or reburial in accordance with paragraph 5 before the human remains are deaccessioned and / or disposed of.
4.5 Storage, conservation and collection management. The University’s museums will store human remains professionally and respectfully following sector guidelines. Where associated communities have been identified cultural protocol will be followed and we will try to accommodate reasonable adjustments where possible and practicable.
Human remains will be kept in suitably safe, secure, watertight premises, with stable, monitored environments, which are kept clean and regularly checked for pests.
Handling will be kept to a minimum, and, where appropriate, direct contact with skin avoided using conservation standard gloves and other PPE.
Access to human remains will be allowed only to authorised staff and visitors with specific permission under agreed supervisory arrangements and where possible, in consultation with communities of origin.
Unmodified human remains will wherever possible be stored in a designated area, to create conditions likely to engender respectful treatment. Wherever possible, the remains of each individual will be stored in a separate storage box (or osteological storage box if appropriate) or container.
Where human remains require conservation, the principle of minimum intervention and reversibility will always be applied, avoiding unnecessary treatments or treatments that will contaminate or damage human remains.
The museums will take into consideration the wishes of communities of origin with regards to all work with human remains including (but not limited to) storage, handling, access and conservation.
The request of any member of staff not to participate in any work directly involving the handling of human remains will be respected.
4.6 Display. GLAM’s institutions display human remains only after sensitive consideration of the reasons for, and circumstances of, such displays, which will always be accompanied by explanatory and contextual information. Each museum will regularly review human remains on display with reference to relevant sector guidance including; DCMS Guidance for the Care of Human Remains in Museums (2005); ICOM Code of Ethics for Museums (2017), the Museum Association Code of Ethics for Museums (2016); and other relevant guidance as appropriate. Individual institutions will give consideration as to how best to prepare visitors to view remains on display respectfully, and to warn those who may not wish to see them at all.
4.7 Access for research and educational purposes. Access to human remains and associated documentation may be requested but is provided at the discretion of the individual institution. Each institution will provide guidelines on how collections are accessed. This will include physical access, invasive or destructive sampling and photography, visualisation and scanning.
The University’s museums will not normally allow research and educational access to human remains while the outcome of any claim for their return to a community of origin is pending.
4.8 Compliance. It shall be the responsibility of the director of the individual museums to ensure compliance with this policy in consultation with the relevant committees, curator(s) and collections managers.
5. Claims for the Return of Human Remains
5.1 GLAM will consider claims for the return of human remains on a case-by-case basis if:
a. a claim for their return is being made by genealogical descendants (see Appendix A); or
b. the claim is being made by a community of origin (see Appendix A) which displays a cultural continuity with the remains in question; or
c. the claim is made through a national government, national agency, or equivalent with explicit agreement of the relevant community of origin; or
d. the claim is made through a national government, national agency, or equivalent in instances where specific communities of origin are not currently identifiable or have no surviving descendants to be held in care of the state for future provenance research and access.
5.2 Claimants must provide evidence of their right to make a claim including, where appropriate, documented support of recognised community stakeholders.
5.3 Where competing claims are received by the University, it may wait for the parties involved to resolve and send written confirmation on who will act as the claimant before proceeding with any one claim.
5.4 The University will be open and transparent regarding approaches from claimants wishing to see the return of human remains to communities of origin and will try to ensure throughout the process that its actions are consultative and that negotiations are as equitable as possible.
5.5 In considering claims for the return of human remains, the University will take into account any relevant information including:
a. the extent to which the criteria in the Appendix are evidenced;
b. the basis upon which the University is in possession of the human remains, and the powers it has available to return them;
c. the strength of the supporting information provided by the claimant; and
d. any other information gathered by the University.
6. Procedures for Making a Claim
6.1 Potential claimants are encouraged to begin the process by emailing the relevant institution to discuss the claim informally at the relevant email address in paragraph 3.2.
6.2 Should the University receive a claim which does not relate to a specific identified item but to the potential presence of unidentified eligible items among a class of materials in a collection, the University will not normally be able to undertake research to establish the presence or absence of such an item unless there are strong grounds to believe that one or more eligible items would be identified and that the cost of the investigation is proportionate to the likely outcome.
6.3 Following the informal consultation stage, if the claimant wishes to proceed with their returns claim, requests should be formally submitted in writing to the University of Oxford’s Head of GLAM at the following address: glam@admin.ox.ac.uk.
6.4 The request should include as much information as possible about the human remains being claimed, the individual or community submitting the claim, the reasons for making the claim, and the evidence that substantiates the claim. Claimants should state how their claim meets the criteria outlined in the Appendix.
6.5 Details of the claim will be forwarded to the Director of the relevant institution, who will appoint a dedicated member of staff or a working group to act as a point of contact for the claimant, and to produce an initial report for a meeting of the relevant Board of Visitors. If the claim is clearly ineligible for consideration, it may be rejected at this stage and the claimant will be informed of that decision and the reasons for it.
6.6 The claim will be formally acknowledged in writing by the University's Head of GLAM or the Director of the relevant institution and will include an indication of how long it is likely to take the University to process the claim and of who will be consulted during this process. This is likely to be a period of some months. The time taken will in part depend on the quantity and quality of the information submitted with the claim, and on the timing of meetings, respectively, of the governing body of the relevant museum or collection, GLAM Board (which will advise the University Council on the claim) and of the University Council itself, with which the final decision will rest.
6.7 In cases involving individuals whose claim may be the subject of dispute within a community or between communities, the University will use its reasonable endeavours to publicise details of the claim with the assistance of relevant international bodies for a minimum period of four weeks in order to inform the decision-making process.
7. Decision-making Process
7.1 Each eligible claim will initially be considered by the Governing Body of the relevant institution or collection at the next possible meeting following the receipt of the claim, allowing time for the work outlined in section 6.5 (above) to take place. At this meeting the claim will be considered based on its eligibility (by reference to the criteria in the Appendix), the strength of the supporting information provided by the claimant, and any other relevant information gathered by the University. This may include advice from independent advisers or information gathered in further consultation with the claimants and other interested external parties (including the national government and diplomatic representatives of the country in which the claimants normally reside) before formulating a recommendation. Advice may also be sought on the circumstances of the acquisition of the human remains.
7.2 If the legal capacity of the University to dispose of the human remains is in any doubt, the relevant Governing Body will obtain seek legal advice (via the GLAM Registrar) on their possible return, and any consequences of the same, and may engage with any necessary external regulators to seek authority in principle for the possible disposal.
7.3 Following consideration, the Governing Body of the relevant institution will make a recommendation to the GLAM Board on the claim. The claim will be advertised in the Gazette. A dossier of the case will be made publicly available giving an opportunity for all with an interest to comment. Any comments received will be considered by the GLAM Board in reaching a recommendation decision to be submitted to University Council. The recommendation may be unqualified, or subject to conditions.
7.4 Following referral pursuant to paragraph 7.3, the GLAM Board will consider the recommendation. If GLAM Board endorses the recommendation, a formal request to approve the recommendation will be submitted to University Council. Any comments received in respect of the application will also be considered by the University Council in reaching its decision.
7.5 If GLAM Board does not approve the recommendation at that stage, the Head of GLAM will discuss with the Chair of the relevant Governing Body and seek a further review of the case. At this point additional research and legal clarity may be required, but the case will not be readvertised in the Gazette. Following consideration by the Governing Body, a recommendation will be submitted to the GLAM Board for review. When a consensus is reached the final recommendation will be submitted to Council for approval.
7.6 Once a decision has been made by University Council, the relevant institution Director will inform the claimant of the decision in writing. At the same time the decision will be published on the GLAM website.
7.7 If the decision is taken to return the human remains then the relevant institution will begin discussions with the claimant as to when and how this will take place, taking into account (where applicable) the need for regulatory consent.
8. Appeals
In the event that the University Council's decision is disputed by the claimant, an appeal will be heard by an Appeals Committee. The committee will be chaired by the High Steward and comprise external experts nominated by Council. The claimant will be informed of the process for consideration of the appeal before it commences.
9. Procedures for Return
9.1 The human remains will not be returned unless and until due legal authority has been obtained, either by the University (in the case of having the authority to dispose) or by the claimant (in the case of the export of the human remains). It is the responsibility of the claimant to arrange any export licences required.
9.2 Where a claim for return is approved, the claimant will be responsible for the costs of returning the human remains in question, including the costs of any processing that may be required for safe transport, packaging, transport and travel. An exception to this may be made in cases of financial hardship, where the University may consider a contribution towards the costs on a case-by-case basis.
9.3 Any relevant associated documentation from the relevant museum will be copied and provided to successful claimants to accompany the return of the human remains.
9.4 The University will retain original documentation for its records, within the relevant legislative context for the retention of records.
Appendix: the Criteria that the University will consider
A. The status of those making the request
Genealogical descendants. Under normal circumstances the wishes of claimants will be seriously considered if they can demonstrate a direct and close genealogical link to the human remains being claimed. Where multiple genealogical descendants exist, it is the onus of the claimant to provide evidence that they have the right to make the claim and approval of the other descendants.
There may be exceptional cases where remains would not be returned to genealogical descendants, for example if the remains are deemed to constitute evidence in a criminal investigation. However, it is expected that in most cases human remains would be returned to demonstrated genealogical descendants.
In practice, individuals who died more than 100 years ago may have many descendants from more than one community, such that genealogical descent alone may not be a sufficient criterion justifying return.
In such cases, the museum will need to assess the range of potential claimants and gauge how the interests of these individuals might be balanced with any other relevant considerations. The ethical principles set out in the DCMS Guidance will help to guide museums through these cases. The principles of avoiding harm (to the particular individuals concerned) and solidarity (seeking co-operation and consensus) are likely to be particularly important here.
Community of origin. Where a claim is submitted by a cultural community of origin the University will seek to consult to verify that the claimants have the authority to submit a claim for the return of the human remains; or where there is more than one group of claimants that they are fully supported by the other claimants. In some circumstances, the University may seek the advice of the relevant national government as to the authority of those submitting the claim and may ask claimants to make their claim through their relevant national government, agency or institution.
For a group to be recognised and their claim for human remains considered the University would expect claimants to be able to demonstrate a continuity of culture in one or more of the following ways; belief, location or customs between themselves and those of the community from which the remains originate. The relationship between the location of the claimant community and the origin of the remains might also be a consideration.
It would be unusual to accept a claim for return from a group who did not either occupy the land from which the remains came, practice the same religious beliefs, share the same culture or language, or could not demonstrate why this was no longer the case.
A clear demonstration of a continuity of association between the claimant and the remains will be of great importance in dealing with any claim.
The country of origin. In some cases, a nation may make a claim for remains, either on behalf of a particular community or for all its nationals. The University will only normally consider claims made through a national government where the community from which the human remains originated has been clearly identified and where it is clear that the community wishes to see the human remains returned or if there is no clearly identified community of origin. In the latter case, the nation would need to clearly articulate the intended destination of the claimed remains: for example, holding in a public national holding centre, resting place or provenance research institute.
B. The cultural and spiritual significance of the human remains
It would be expected, but not regarded as essential, that the claimant should demonstrate that the human remains and their treatment have a particular cultural or spiritual significance to their community. Examples might include the fact that the human remains were removed outside the laws and normal practices of the community at the time, or that the correct ‘laying to rest’ of remains was not followed and is of religious or spiritual importance. Demonstration of a strong cultural or spiritual significance of the human remains will be duly considered by the University when making a decision. This is particularly so in cases where there is clearly a risk of harm to the individuals or communities concerned, for example where the continued holding of the remains by a museum perpetuates a strong feeling of grief amongst claimants.
C. Consent of the deceased
It is not normally the case that there is evidence that the deceased gave consent for their remains to be transferred to a university museum or collection. However, if there is evidence one way or the other then it would strengthen or weaken the claim for return accordingly.