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Open data: exclusion Policy for IATI

1.    Introduction

Defence for Children is committed to the principles of transparency and accountability. Defence for Children supports the idea of Open Data and complies with the standards stipulated by the International Aid Transparency Initiative (IATI). By January 2016, Defence for Children will be IATI registered and publishing data in .XML format on a quarterly basis, according to the most recent IATI standard.

Defence for Children believes that by publishing about our work, we enhance our accountability to children, families, communities and the partners we work with as well as the funders and other supporters of our activities. Similarly, Defenc for Children believes that by publishing data,  collaborations, synergies, networks and replications can be enhanced while duplication can be reduced.

This policy sets out which information will be published, either proactively or on request, how requests for information will be handled and explains exclusions that will be made and the rationale for them.

This policy is available on the website of Defence for Children and if necessary updated.

2.    Scope

This Policy applies to information produced by Defence for Children. For information and documents produced by other Defence for Children or ECPAT sections and the International Secretariats, we refer to their own web pages and corresponding policies, if existent.

3.    Associated Documents

The procedures and policies set out in this document should be read in conjunction with the following associated documents:
-    Child Protection Policy
-    Complaint Procedure

4.    Information available to the public

Information concerning Defence for Children NL's programmes and operations are publicly available through IATI but also through the annual year reports for the organization.

The following information will be made available to the public, subject to the exclusions set out in section 5 below:
-    Organization description: statutory provisions, annual reports, governance structure and board members.
-    Activities: project name, description, funding source, total budget, disbursement and expenditure, proposals, intervention logic (logical frameworks, Theories of Change), summary budgets, final report, evaluation, external audits, for international projects directly funded by the Dutch Ministry of Foreign Affairs and carried out by Defence for Children.

5.    Public access

Information is published on the Defence for Children website, including a link to the IATI compatible .XML file.  Additional information is available from Defence for Chidlren NL's publications.

Defence for Children will work with its partners and ensure that information needs of all stakeholders, including children and youth, are met, thus ensuring stakeholders' ability to hold DCI-ECPAT accountable.

6.    Responding to requests

A request for information can be made by e-mailing to the Communications Department of Defence for Children:

A response to a request for information will be given within 10 working days of the request if possible.

The appropriate Programme Managers within Defence for Children are responsible for ensuring that requests for information from interested parties relating to their areas of work are addressed.

If a request is denied a justification will be given.

7.    Exclusions

Defence for Children makes publically available all project/program data with the exception of those data that match the following exclusion criteria.

Defence for Children applies the principle of "Open, unless…". Information is excluded only if disclosure would:

1.    Negatively affect children, their parents, families and/or their community;
2.    Negatively affect the external relations of Defence for Children or of partner organizations with government(s) or other stakeholders;
3.    Put the security and safety of persons and organizations at risk;
4.    Jeopardize privacy of children, parents, families, staff, partners or other specific persons;
5.    Harm the commercial or strategic interest of Defence for Children, partners, suppliers, back-donors or cooperating partners;
6.    Breach data-protection or other laws and regulations; or
7.    If the costs of producing information significantly outweigh any possible benefits from the public production of that information.

Information that does not meet basic quality requirements is excluded from publication as well, in order to safeguard the consistency of the data-sets. New data sets that are published are more complete or of better quality than earlier versions. Therefore new data will always replace the earlier version.

General reasons for exclusion

1.    Child Protection

Defence for Children will not publish information that would expose children, or their parents, families and communities to potential abuse or exploitation, such as personal information regarding assisted children and other children Defence for Children works with.

2.    External relations

Defence for Children keeps data confidential that might otherwise harm its relations with governments, partners or (back)donors. Defence for Children informs partners about its publication policies and partners can request exclusion, based on the principles in this exclusion policy. Defence for Children is the final decision-maker for not publishing part of its data.

3.    Safety and security

Defence for Children keeps confidential any information that might pose a security or safety risk to persons, communities, organizations, its own staff, back-donors or suppliers. In view of such risks, transaction data are disclosed per quarter on a cumulative basis and partner address details are not disclosed.

4.    Privacy

Defence for Children does not publish information that is traceable to an individual person and can reasonably be judged as an invasion of the privacy of that person without prior permission of the person involved.

5.    Commercial and strategic information

Defence for Children keeps confidential any information that is of commercial interest or strategic interest to Defence for Children, partners, suppliers, back-donors or cooperating stakeholders, but only if the information is not publicly available otherwise. Defence for Children will not publish information that would harm either the financial interests of Defence for Children or those of other parties involved. For this reason we exclude information on individual companies we cooperate with.

6.    Legal and contractual reasons

Defence for Children does not publish data if we do not have the right to publish the data. For example, if third parties have a copyright on certain information or if contractual agreements with back donors or partner organizations impede Defence for Children 's right to publish the data. Also, Defence for Children does not publish data where national or international law prevent their publication. This may include, but is not limited to, the names of private donors. Non-disclosure may also be part of a cooperation agreement or copyright provision, or other contractual obligations.

Similarly, information covered by legal privilege or related to access to internal audit reports is excluded from publication.

7.    Consistency and data quality

Defence for Children aims at utilizing its staff time and resources for the greatest impact on children; publishing data according to the IATI standard should not lead to a disproportional work load or disproportional costs and Defence for Children publishes insofar data is available. If the costs of producing information significantly outweigh any possible benefits from the public production of that information, or if requests for information are considered dilatory, we may choose not to publish.

Optimal transparency can only be achieved if all relevant data are checked. Project data that do not meet minimum quality and consistency requirements are not published.

Defence for Children publishes project data for activities that started after January 2016 and that receive funding from the Dutch Ministry of Foreign Affairs.

More information about exclusions and tresholds can be found on the IATI website.

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