Care of Human Remains Policy

2. Scope

This policy covers all human remains that are currently under the direct care of Wellcome Collection. Our collections include a relatively small number of human remains, the majority of which are prepared specimen slides created within medical research contexts, contemporary artworks which include bodily fluids, and mementos of human hair within bound volumes. A full list of these collections is available in the Appendix.

In addition to the holdings directly managed by Wellcome Collection, there are 1,059 human remains currently identified in ‘Sir Henry Wellcome’s Museum Collection’ – a sub-collection of over 100,000 objects which have been on long-term loan to the Science Museum Group since the 1970s. These human remains are cared for under the Science Museum Group’s Human Remains Policy [PDF 111.6KB]. However, Wellcome Collection retains ultimate decision making around destructive sampling and disposal of human remains within this subset of the collection.

This policy does not cover any human remains that were formerly under Wellcome’s ownership and where that ownership has since been rescinded. More information on this can be found in the below section 'Context of human remains in Wellcome’s collections'.

3. Review

The Care of Human Remains Policy will be reviewed on a three year cycle, and may also be periodically revised from time to time. Revisions may be required, for example, to reflect changes to the guidance from the Department for Culture, Media and Sport (DCMS), changes in the legal and regulatory environment (including the Human Tissue Act 2004), or in response to concerns and recommendations from cultural communities and other relevant parties.

4. Decision-making

Decisions pertaining to access, management and the return of human remains are distributed across a variety of roles, consultation processes, and internal panels within Wellcome. Where applicable, the decision making may sit at a higher executive level. In the absence of a genealogical and/or cultural descendant community, Wellcome Collection may seek the advice of external specialists, for example academic and non-academic expertise.

If ethical issues arise in relation to any area of this policy, we will be informed by the relevant principles in the DCMS guidance. We will refer matters to Wellcome Collection’s Access Advisory Panel if required, and/or other relevant groups. The Access Advisory Panel will also consider external appeals against decisions relating to the access of human remains within our care.

5. Legal requirements, ethical frameworks and guidance

As an accredited UK-based museum and archive service, this policy sits within a wider set of guidance, legal, and ethical frameworks:

• Human Tissue Act 2004 and associated Human Tissue Authority codes of practice including HTA Code of Practice D Public Display [PDF 543.6KB]
• United Nations Declaration on the Rights of Indigenous Peoples, 2007 [PDF 150.2KB]
• Code of Ethics for Museums, Museums Association, 2016
• Code of Ethics, ICOM, 2017
• Guidance for the Care of Human Remains in Museums, DCMS, 2005

6. Definition of human remains

Wellcome Collection adopts a broad definition of what constitutes human remains. This is in line with definitions set out in the 2005 DCMS Guidance for the Care of Human Remains in Museums: “the bodies, and parts of bodies, of once living people from the species Homo sapiens … This includes osteological material (whole or part skeletons, individual bones or fragments of bone and teeth), soft tissue including organs and skin, embryos and slide preparations of human tissue”.

Whilst the definition of human remains by DCMS does not include human hair and nails (as outlined in the Human Tissue Act 2004), Wellcome Collection acknowledges that they hold a special status for some cultural communities. As such, Wellcome Collection does not exclude hair and nails from this policy by default and will consider their individual context and cultural significance in order to treat them with the appropriate care. For this same reason, hair and nails are included in our list of human remains within our collections [see Appendix].

This definition of human remains includes any of the above which have been modified in some way by human skill and/or physically bound up with other non-human materials to form an artefact composed of several materials. This encompasses artworks that are composed of bodily fluids and/or soft tissue.

Wellcome Collection further acknowledges that the legal definitions cited in this policy do not classify the recordings of human voices, images and photographs of people or ancestors, impressions (such as life and death masks), reliquaries, personal items, burial items and/or other associated documents as human remains. However, we understand that certain cultural communities may recognise these wider collections as occupying their own unique status, as with human remains. We welcome being made aware of such instances and are committed to considering appropriate practices of care. Contact should be made via: collections@wellcomecollection.org.

7. Context of human remains in Wellcome's collections

Wellcome Collection opened in 2007, however, its origins lie with the collections brought together by Sir Henry Wellcome (1853-1936) throughout the late-nineteenth and early-twentieth centuries. These collecting activities were closely linked with the pharmaceutical firm Burroughs Wellcome & Co that Henry Wellcome co-founded with his business partner Silas Burroughs (1846-1895).

Henry Wellcome’s collection is thought to have included over one million ‘items’ at its peak. He amassed vast global collections and founded private museums - including the Wellcome Historical Medical Museum (WHMM) - with the stated aim of better understanding the ‘art and science of healing throughout the ages’. Spanning time periods and cultural contexts, these collections encompassed objects, artworks, archives and texts that included human remains and what we today recognise as culturally sensitive materials more broadly. Henry Wellcome’s wealth, collecting practices, and the institutions he founded are part of wider colonial contexts and power imbalances. Wellcome Collection acknowledges its responsibility to ‘be honest and transparent about the past injustices in which our collections are rooted’ and that human remains hold a distinct place in these considerations.

Henry Wellcome was able to build vast collections with the assistance of his staff, and the varied networks he established himself within. Once within Wellcome’s collections: ‘Objects were classified and displayed in a way that placed European culture at the top of a racist, sexist and ableist system of cultural dominance.’ Human remains formed part of these historic displays, removed from their original contexts and practices of care.

The majority of these collections were dispersed in the decades following Wellcome’s death in 1936 and are now situated in over 100 institutions worldwide. These dispersals included most of the human remains that had been part of the collections and, therefore, are not within the remit of this policy. However, Wellcome Collection does retain the WHMM archive and associated papers which relate to the historic collecting and display of human remains that used to be in our care. Much of this archive material has been digitised and is freely available via the Wellcome Collection website. Questions relating to these archives can be directed to: collections@wellcomecollection.org.

Today, Wellcome Collection retains many of the books, manuscripts and artworks that were acquired by its founder, alongside the collections that have been acquired in the decades since. Full details of Wellcome Collection’s current holdings and their organisation is outlined in our Collections Development Policy.

8. Acquisition

Wellcome Collection will only consider acquiring human remains under exceptional circumstances, for example artworks which include human remains and have the appropriate permissions. As outlined in our Collections Development Policy, any decisions around acquisition will need to prioritise clearly established provenance, ethical and legal considerations, and clarity regarding how this contributes towards our mission. Wellcome Collection will not acquire human remains where there is any suspicion of illicit trade.

Any decision-making will be based on consultation with appropriate parties and in line with our acquisitions due diligence framework. Any proposal for the acquisition of human remains less than 100 years old will be subject to the legislation outlined in the Human Tissue Act 2004 and guidance from the Human Tissue Authority.

9. Loans

Wellcome Collection will consider any request for the loan out of human remains in its care via its internal Loan Committee, subject to any such activity being compliant with all legal and regulatory requirements. This is outlined in our Loans Out Policy.

When considering a request for a loan, we will take into account the sensitivity of the human remains and will not normally loan out remains that are subject to a pending claim, unless the request is directly related to that claim.

Requests to borrow remains held in the care of the Science Museum Group on behalf of Wellcome Collection will be handled by the Science Museum Group.

Wellcome Collection may occasionally borrow human remains for display in its galleries. Any loan-in will follow the legal and ethical guidance outlined in this policy, see section on 'Public display', and our Loans In Policy.

10. Storage and conservation

10.1 Storage

Human remains in the collections will be stored and managed in a respectful, professional and culturally appropriate way wherever possible, in keeping with DCMS guidance and museum best practice. If we are made aware of culturally specific protocols regarding the storage of human remains, we will consider appropriate adjustments on a case-by-case basis. Any enquiries or recommendations regarding the storage of human remains can be directed to: collections@wellcomecollection.org.

10.2 Conservation

Where human remains require conservation, the principle of minimum intervention and reversibility will be applied and in accordance with our decision-making principles outlined in the following section on 'Decision-making'.

11. Public display

Wellcome Collection only displays human remains where there is a compelling curatorial justification to do so and where this is in line with the legal and ethical guidance outlined in the 'Legal requirements, ethical frameworks and guidance' sections'. In keeping with these principles, we acknowledge that the display of human remains can have value and meaning for audiences when presented appropriately, thoughtfully and with careful consideration of our overarching strategy and mission. For a recent example, see: Wellcome Collection 3198544i, Blood Objects, Basse Stittgen, 2019.(view in catalogue)

We do not display human remains that require a Public Display Licence under the Human Tissue Act 2004.

Human remains in our collections that have been identified as particularly sensitive, or are the subject of a pending claim, will not normally be displayed or made available for display, though requests may be considered in exceptional cases.

Any displays of human remains will be considered carefully, in accordance with our decision-making principles [see 'Decision-making' section] and will include scrutiny of the rationale for display.

Wellcome Collection will use appropriate text signage to inform visitors when human remains are on display.

12. Access

Human remains may be accessed for a variety of reasons. At Wellcome Collection this is most likely to be for research, although requests can be made for other purposes. Access to human remains under the care of Wellcome Collection is dependent upon the following criteria:

Human remains from the body of an individual who died less than 100 years ago:

These human remains are not accessible and are considered ‘closed’. However, requests to access human remains that fall within this category will be considered if directly related to a repatriation claim, or from genealogical descendants and/or cultural communities.

All other human remains:

Requests to access any other human remains, such as human materials taken from a living consenting donor during their lifetime or where human remains are older than 100 years, will be considered on a case-by-case basis by an internal panel.

Research requests for the study of human remains will be considered and guided by relevant sections of Wellcome Collection’s Access Policy. All decisions will be in line with DCMS guidance and will include an awareness to the sensitivity of this work, especially to identified genealogical descendants and cultural communities.

Due to the special status of human remains, it may be such that withholding access to the remains, rather than making them available, is the most appropriate or beneficial course of action. Human remains that are the subject of a pending repatriation claim will not normally be made available for historical research unless directly connected to the claim. The full range of access statuses for collection items in our care are available in section 3.2 of the Access to personal and sensitive information within our collections procedures [PDF 1.3MB].

Human remains requiring a licence under the Human Tissue Act 2004 are not available for research in connection with disorders or the functioning of the human body - this applies to material from the living and the deceased. Any requests to conduct invasive and/or destructive sampling will be considered in line with our destructive sampling protocol. Non-invasive and/or non-destructive methods will be given preference over invasive and destructive analysis.

Requests for access to human remains held in the care of the Science Museum Group on behalf of Wellcome Collection will be handled by the Science Museum Group in accordance with their Human Remains Policy [PDF 111.6KB] and Access Policy [PDF 79KB].

13. Inventories of collections

Wellcome Collection takes an iterative approach to managing the metadata for collections in its care, building on the minimum viable descriptions recorded at inventory and acquisition. This is further outlined in our Collections Information Policy.

In recognition of the special status of human remains in collections, documentation outlining our holdings is maintained and made available - see Appendix for a list of human remains currently held by Wellcome Collection. This includes the numbers, physical nature, date and provenance (where currently known) of human remains and items understood to contain human remains.

The Science Museum Group manages a list of the human remains, and items understood to contain human remains, that are part of the long-term loan of ‘Sir Henry Wellcome’s Museum Collection’ to the Science Museum Group. Note that the cataloguing information in this list may contain dated and offensive language.

For specific guidance or assistance in accessing information on human remains currently held by Wellcome Collection, please contact: collections@wellcomecollection.org.

14. Digital

We acknowledge that both analogue and digital content depicting human remains, such as (but not limited to) catalogue records, images, and films, carry their own sensitivities and require specific considerations around access and use. We also acknowledge that digital content requires additional scrutiny regarding sharing and use. All such examples are included within Wellcome Collection’s wider policies and decision-making processes- for further details, please see the Access to personal and sensitive information within our collections procedures [PDF 1.3MB].

We take a responsive approach to best practice surrounding the treatment of digital records of human remains. At present this includes:

• Placing digitised content behind a click-through content notice.
• Restricting certain content so that it cannot be viewed online.
• Considering removal of existing content in-line with Wellcome Collection’s takedown guidelines for digitised content.

15. Deaccessioning

Wellcome Collection may deaccession human remains from its collections for several reasons, including but not limited to:

• Where there are health and safety problems relating to the remains.
• Where there are irresolvable difficulties associated with storage requirements.
• Where it is desirable to transfer remains to another collection where they will be more appropriately utilised and/or cared for.
• Where remains are no longer appropriate within our collecting policy.
• Where remains are part of a process of return – as outlined in the 'Returns' section below.

Before deaccessioning human remains, we will first seek to establish whether there are any genealogical or cultural communities who might wish to make a claim for the return of the remains. Where potential recipient parties do exist, we will consider whether it would be practicable and appropriate to contact and consult with them to ascertain whether a claim might be made. Where it is not possible to identify recipient parties, for example when there is insufficient information to identify remains (through scientific analysis or provenance research) we will carefully consider appropriate next steps.

Decisions around the deaccessioning of human remains within ‘Sir Henry Wellcome’s Museum Collection’ under the care of the Science Museum Group will be made by Wellcome Collection, in consultation with the Science Museum Group and any other relevant parties.

16. Returns

Wellcome Collection is committed to openness and transparency around claims for the return of human remains.

We will be proactive in working towards the possible return of relevant human remains with the appropriate recipient parties – which might include cultural communities, genealogical descendants, next of kin, national governments, national agencies and equivalents.

All requests for the return of human remains will be considered as outlined in the Collections Development Policy. They will be determined on a case-by-case basis following consultation with proposed recipients and any other potential recipient parties in accordance with DCMS guidance. Wellcome Collection prioritises the handling of these requests with care, compassion and an awareness of the sensitive nature of the work.

Enquiries and requests for the return of human remains, including those under the care of Science Museum Group, which form part of ‘Sir Henry Wellcome’s Museum Collection’, should be submitted in writing to the Director of Wellcome Collection. All requests and enquiries will be respectfully considered and subject to final approval from Wellcome Collection’s Quarterly Governance Committee, including consultation with the Science Museum Group, as applicable.

Where appropriate, we may seek independent advice from experts on ethical, scientific or other issues, to help guide our decision making.

Contacts

• Director of Wellcome Collection, Gibbs Building, 215 Euston Road, London, NW1 2BE

17. Appendix

Care of Human Remains Policy Appendix [PDF 138.6KB]

18. Policy history and review

• Version 1.0 (19 June 2018) Approved by Wellcoership Team.
• Version 1.2 (24 August 2023) Approved by Wellcome Collection Leadership Team – Amendment to remove reference to acquiring human remains under 100 years old.
• Version 1.3 (9 October 2025) Approved by Strategy & Impact  Committee  – Update in line with strategy.

Written By: Culturally Sensitive Collections Lead and Doctoral Researcher

Policy sponsor: Director, Wellcome Collection

Functional lead: Associate Director, Collections & Digital

Distribution: Workday internal policies and wellcomecollection.org policy documents page

Requirement: Museum Accreditation, Archive Service Accreditation, Internal Audit

Responsibility for preparation: Culturally Sensitive Collections Lead

Responsibility for review: Strategy and Impact Committee

Review schedule: 3 years 

Next review date: October 2028