In 2021, the teams that developed the Responsible Data for Children (RD4C) principles and the IASC Operational Guidance on Data Responsibility in Humanitarian Action (IASC Operational Guidance) conducted a comparative assessment of their respective principles.

In April 2023, the Data Responsibility Working Group revised the IASC Operational Guidance, including minor updates to the Principles. To commemorate Universal Children's Day, the teams met again this year to reflect on how these frameworks still complement one another. 

In this piece, we provide an overview of both frameworks, the value they provide, and information on how they complement and reinforce one another.

The Frameworks

Launched in 2019 by The GovLab at New York University and UNICEF’s Chief Data Office, RD4C is a framework for assessing risks and opportunities for advancing children’s rights through data and data technologies (analytics, machine learning, AI, etc.) across the data lifecycle that is grounded in a set of principles for responsible data handling. It recognizes that children face unique vulnerabilities that can be best addressed by spotting the particular risks and opportunities in the contexts that children reside in. The principles are informed by observations about data use for children around the world and across contexts.

The principles included in the IASC Operational Guidance on Data Responsibility in Humanitarian Action (the IASC Principles) inform the safe, ethical and effective management of personal and non-personal data for humanitarian response. The IASC Principles are based on a review of 55 documents offering guidance on data management.* The IASC Principles were developed in 2021 by a sub-group of IASC Results Group 1, with minor updates by the Data Responsibility Working Group in 2023.

The IASC Principles and RD4C Principles complement and reinforce one another. Whereas the IASC Principles address responsible handling of data about all demographics in humanitarian settings, RD4C focuses specifically on children, regardless of the context in which they live. The RD4C Principles provide practitioners with a roadmap for implementing and embodying the IASC Principles in their work, specifically with children’s data. 

Value of the Principles 

Principles-based guidance for data management such as RD4C and the IASC Operational Guidance has distinct benefits over more detailed and specific governance instruments such as laws and regulations. 

A principles-based guidance provides a common framework that can be adapted to various contexts. From country to country or issue to issue, the RD4C’s and IASC Operational Guidance's  approach provide a useful supplement to policies, providing contextual flexibility to fill in the gaps that might be left by the more “rigid” requirements imposed by laws and regulations. This flexibility can allow organizations to accommodate a variety of circumstances and adapt to the challenges they face in their work. 

Core to both sets of principles is the recognition that data moves through distinct steps. Both sets of principles inform responsible data management throughout the data lifecycle, including collection, processing, storage, quality assurance, sharing, analysis, use, and retention and destruction. The examples below illustrate how data responsibility has been implemented at different stages of the data lifecycle within a variety of contexts and sectors.

Principles in Practice: Accountability in HOPE

There are many contexts in which adopting policies consistent with a principles-led approach has yielded value and allowed organizations to accommodate different challenges. For example, both the RD4C and the IASC Operational Guidance state the importance of accountability mechanisms related to data management by establishing institutional processes, roles, and responsibilities. 

As highlighted previously, the Humanitarian cash Operations and Programme Ecosystem (HOPE) serves as a prime example of how professional accountability can be pursued. Designed by UNICEF as a humanitarian cash transfer management information system, HOPE aims to enhance the quality of Humanitarian Cash Transfers (HCT) programs and ensure compliance with UNICEF guidelines and tools, maintaining accountability and traceability of managed information. HOPE supported UNICEF and partners to deliver USD 430 million in the last two years to almost three million individuals.

Key to achieving this level of accountability is the establishment of clear roles within the project team. HOPE has been deployed in multiple countries, including Palestine, Kenya, Sri Lanka, Ukraine, Sudan, South Sudan, Slovakia, Somalia, Czech Republic, Philippines, Afghanistan, Niger, Nigeria, Central African Republic, Democratic Republic of Congo and Antigua and Barbuda. 

Ukraine, for instance, has established functions and responsibilities, for both UNICEF staff and partners, in an iterative way, embedding them both in office standard operating procedures and in HOPE, while updating as programme needs evolve. In the State of Palestine, HOPE rolled out a new accountability feature. In response to the humanitarian needs in Gaza, with many Mobile Money vendors closing and reopening as security allowed, HOPE supported UNICEF staff to use real-time monitoring and convey up-to-date information on where to safely access cash to beneficiaries. 

Overall, these efforts speak to HOPE’s desire to pursue professional accountability and empower stakeholders to responsibly handle data for and about children and their communities — to make informed decisions and effectively address challenges in their country.

Principles in Practice: Data Responsibility in Afghanistan

Following the de facto authorities’ decree in December 2022 banning Afghan women from working for NGOs, the IASC established minimum criteria for programming, including robust commitments around AAP. The AAP Working Group (AAP WG) launched the Afghanistan Community Voices and Accountability Platform to help humanitarians collect, analyze and respond to community feedback across the response in Afghanistan in a timely and secure manner.

Given the sensitivity of the data shared through the collective platform, the AAP WG took steps to ensure data responsibility by design. This included conducting a data impact assessment to identify and mitigate data-related risks, and establishing a standard operating procedure (SOP) for data management by all partners involved. The SOP specifies that no personal data should be stored within the platform. It also includes steps to ensure that data management within the platform does no harm, and promotes equality and non-discrimination. This is achieved through collective analysis of complaints and feedback received from affected communities, and the presentation of key insights in a neutral and impartial manner. The SOP is aligned with the system-wide Information Sharing Protocol for Afghanistan, which was endorsed by the Humanitarian Country Team in May 2023.

This approach aligns with the IASC’s Data Security and Confidentiality principles and the RD4C principle of preventing harms across the data lifecycle. 

Principles in Practice: Being Proportional in the Democratic Republic of Congo

Finally, both frameworks encourage organizations to be proportional in their data management and to align all data collection and retention with a clearly defined purpose. In the Democratic Republic of Congo, UNICEF’s Cellule d’Analyse Intégrée (CAI) made proportionality a central, guiding principle.

CAI is an operational research and analytics cell created by UNICEF to provide local and national level actors, government leaders, UN staff, and associated partners with integrated and actionable evidence to respond to public health emergencies and contexts. Formed in response to the 10th Ebola outbreak in the Democratic Republic of Congo, CAI put extensive thought into how they could responsibly collect data in communities without overburdening them.

Ultimately, the team decided to only collect data when they can be sure it will be relevant and used. CAI also ensures that it uses locally identified and trusted researchers—women working with women and men with men, but also specific members of communities—to ensure they capture all (and only) relevant data.

Though it might sound straightforward and sensible, it is not always easy to ensure proportionality.  During its work, the CAI team sometimes faced difficult ethical situations that required referral. Enumerators and community workers sometimes struggled to know how to deal with unexpected and sensitive information shared by children and their communities—such as disclosure of sexual exploitation and abuse. Frequent exchanges were therefore organized by the CAI team to remind practitioners about how to handle these incidents and what to do with the data. 

These actions reflect an organization thinking critically about the ways they can meaningfully contribute to improved humanitarian outcomes, be consistent with relevant mandates, respect and promote rights and freedoms, and carefully balance those where needed. CAI aspires for its data collection to be relevant, limited and adequate to what is necessary for achieving intended purposes. 

Recommendations

Since the release of the IASC Operational Guidance and the RD4C principles, four commonalities emerge across implementation of the principles to support the responsible use of data for children, including in humanitarian settings:

• Understand Partner Priorities: First, one major challenge that organizations can encounter during their work is difficulty in collaboration with partners. Actors have unique needs and interests that need to be understood in order to identify issues of common concern as well as the appropriate scope for the collaboration. Open conversation with stakeholders including governments, data sources, donors and others at the outset of a data management activity helps identify the needs of each stakeholder and the resources available, which in turn helps identify reasonable expectations for the collaboration. 

• Provide Tools and Infrastructure to Connect Data: One major challenge in the use of data for children and in humanitarian response is a lack of data access. The supply is not well-connected to the demand either because it is held by other actors or because the data is fractured across systems and formats. To avoid missed uses of data, organizations might look at ways that they can connect disparate sources. Developing a data management registry helps identify what data is available, and to have more systemic conversations about potential data use.

• Provide Training on Responsible Data Management: Another common challenge that UN staff encounter is insufficient availability of skills required for safe, ethical and effective data management. To address this, organizations might look at ways of articulating legal and institutional requirements. They might train their staff not to simply be reactive in response to challenges as they arise but to identify ways they can be proactive—thinking critically, for example, about the value of avoiding duplicative or excessive data collection, the importance of engaging with and informing community stakeholders, and more. In these ways, individuals can foster a healthy, responsible ecosystem. 

• Develop Processes and Procedures to Deliberate Ethical Challenges: Another challenge commonly identified for staff is the need for guidance when encountering ambiguous situations for which available guidance does not provide direct instructions. Many humanitarian settings call upon individuals to engage in field work that may present unique problems. Rather than aiming to develop specific guidance for all possible situations, humanitarian organizations should focus on developing processes and tools to support staff in ethical deliberation and decision-making. 

In these ways, RD4C and the IASC Operational Guidance enable responsible data governance for children and adults in any corner of the planet and empower organizations to realize the promise of existing policies. In an age of changing technology and data linkage, the world requires flexible and adaptive guidance that can promote responsibility and is well-suited to manage the complexity of data use in different regions of the globe. 

Your feedback matters! Both the RD4C initiative and the IASC Operational Guidance aim to be field-oriented, driven by the needs of both the populations they serve and the practitioners across sectors. If you have any comments on the above or suggestions on where to focus our attention in 2023, please contact us at [email protected] (RD4C) or [email protected] (UN OCHA Centre for Humanitarian Data, for feedback related to the IASC Operational Guidance). 

* The complete list of documents reviewed is included in Annex D of the IASC Operational Guidance on Data Responsibility in Humanitarian Action, available here: https://interagencystandingcommittee.org/system/files/2023-04/IASC%20Operational%20Guidance%20on%20Data%20Responsibility%20in%20Humanitarian%20Action%2C%202023.pdf

Photo by Yannis H | Unsplash is licensed under CC0.

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