Although digitization has become a word that is almostsynonymous with democratization and citizen participation, manymuseums and other cultural heritage institutions have found it difficult to live up to this political vision of inclusivity and access for all.In Sweden, political ambitions to digitize the cultural heritage sectorare high. Yet, institutions still struggle to reconcile their previouspractices with new technologies and ethical guidelines for collecting and curating material. In this article we identify, analyse, andtry to find resolutions for the current gap that exists between cultural heritage practice and government policy on digitization, openaccess, and research ethics. By examining two Swedish examplesof Holocaust collections that have not been digitized because of internal policies of secrecy and confidentiality, we attempt to demonstrate how discourses about vulnerability affect the ways in whichcertain archival practices resist policies of accessibility and ethicalresearch. In order to unpack the discourses on vulnerability, Carol Bacchi’s post-structural approach to policy analysis has been usedtogether with Judith Butler’s theories on vulnerability and resistance. In addition to understanding how cultural heritage institutionsin Sweden have protected some of their collections and how thishas obstructed efforts to make these collections more accessible,we also offer some suggestions on how these issues can be resolved by reimagining digitization as transformation.