Open information and NGOs
Many organisations will have a commitment to transparency and accountability, and opening up access to information is an extension of both of these.
While transparency can be seen as a principle and therefore often passive (a window is used as a metaphor for transparency, for example), being open is about taking action.
Openness is proactively releasing information into the public domain, usually in accordance with an Open Information Policy (OIP).
There are five core elements of open information:
- accurate and complete
Developing an open information policy
One of the best ways of becoming more open as an organisation is to develop an open information policy. An open information policy is a public statement of current and future attitude to sharing information about key areas of governance, finance, performance and programmes. We’ve identified a five-step process for organisations to follow to create their open information policy. As with any policy, creating it is not the same as embedding it within your organisation. As you work through the steps, consider what else you will need to do to support this change in practice within your organisation.
Step 1: Commit
Initial commitment to the idea of openness as a whole organisation is incredibly important and can be a change in the way that your organisation works. Whilst UK civil society organisations are not included under the UK Freedom of Information Act, the Information Commissioner’s Office has called for an extension to the law to cover UK charities, such as housing associations, which provide public functions. The FOIA provides a useful framework making information publically available in a way that makes it accessible and useful to anyone who has an interest.
In a 2014 Charity Commission report, 96% of 1,163 people surveyed agreed that it was important to provide the public with information on how they spent their money, 94% that it was crucial that charities demonstrated how they benefit the public and 90% that charities explain what they have actually achieved (via an annual report).
With this in mind, you may want to think about the following before you start:
- How can you keep it simple? It’s important to start small and within your resources, and plan to become more open over time.
- Who within your organisation will need to be involved in developing the open information policy?
- Who you will need to persuade or negotiate with, in order to get the policy agreed? What might their concerns be?
- How you are going to communicate to staff, volunteers, partners and other key stakeholders about your policy, and manage the change in working practice?
- What information can your organisation be open about now, and what will you plan to be open about in the future?
- If you work through partners, how will you encourage them to follow the policy?
If you are a very small organisation, you may wish to produce an open information statement rather than a policy. However, the steps you will need to go through are the same. So if you are able to commit to writing a policy it may be a better use of resources in the long-term.
Step 2: Analyse
Do an analysis of the people you think have an interest in your information. Examples include your partner organisations, the people you work with on the ground, your staff, current and potential grant makers and your supporters. What information would they need or want to better understand who you are and what you do? You could use this target group toolkit as a framework for that discussion.
Draw up a list of information you collect, the format you share it in, how often it’s updated and whether you already provide public access to it via your website. Typical types of information include the following.
Project and performance:
- what you’re doing and where
- why you’re doing it (logframes, theory of change etc)
- who you’re working with (partners and the people receiving services)
- the results you’re getting and evaluations of completed projects
- finances relating to the project (you may already share this via IATI)
Governance and decision-making:
- policies such as anti-bribery, vulnerable persons, equal opportunities, environmental impact
- mission, vision, long-term strategy and annual plan
- memberships and affiliations which may influence decisions
- trustees and senior staff (within the bounds of privacy and security)
- board meetings and minutes
- salary range of highest paid member of staff
- trustee annual report and accounts
- value for money statement
- progress against annual plan or strategy
Do a risk analysis on information that is not currently publically available or where you intend to release more complete or timely information or in a more accessible format. What do you worry might happen if you release this data? How does this correspond to the risks identified in your organisation’s Risk Register, if you have one? Using a scenario planning tool may help.
Information that is likely to affect the security and safety of staff, volunteers, partner organisations or the people they work with should be considered carefully. An open information policy can also include the information that you will be excluding because of this.
Analyse how your information is currently published, and whether more open formats can be used. For example, sharing financial information in a way that can be compared with information from other organisations, using the XML file format of IATI, is more open than publishing it as a PDF. However, it also may take more time to set up, so be prepared to balance the two, and start small. Bond provides free support on IATI data reporting to NGOs who are DFID grant holders.
Step 3: Decide
Use the evidence in Step 2 to help you to decide the following:
- what types of information will be routinely open
- what types of information will be open on request only (try to keep this to a minimum, if at all)
- what types of information will be excluded and the criteria
Exclusions criteria will be unique to each organisation, but typically might include the following:
- security and safety of staff, volunteers, partner organisations or people who you work with (beneficiaries)
- privacy, security and data ownership
- confidentiality and intellectual property rights clauses in contracts (for example grant funders or partners)
- commercially sensitive information (relevant to organsations regularly contracting to provide services, for example, to DFID)
Sharing information about the performance of your project and organisation can be daunting. We know that in development, results don’t always turn out as the plan predicted. However, there are definite benefits in collecting and sharing the information, and so we would advise an organisation to think carefully before excluding project performance data per se from an open information policy.
Where your organisation decides to include other criteria, for example, the high cost of disclosing information, it is important to make sure that you have an appeals procedure. As charities are exempt from the Freedom of Information Act, an appeals procedure means that people can ask for a decision to exclude a piece of information that they have requested to be reconsidered. The easiest way to do this is to use your existing complaints procedure.
Decide on who will sponsor the policy within the organisation. Ideally this will be at a senior level in the organisation. Decide on who will be responsible for updating it on an annual basis, and the process for doing so. If you have an existing procedure or cycle for updating all your policies, add your Open Information Policy into this cycle rather than create a new process.
Step 4: Create the open information policy
You don’t need to write an open information policy from scratch. You can also look at other organisation’s policies (see links below) or use our template. Use the evidence and information you’ve gathered in steps 1 to 3 to fill in each section of the template. If your organisation shares information using the IATI data standard, remember to include this in the policy.
Examples of NGO open information policies:
Step 5: Communicate
Once you’ve completed all the hard work in steps 1 to 4, it’s important to communicate the policy – to people inside your organisation, and those outside. For staff, it may involve a change in thinking and practice about what and how they share information with others. There’s some useful information on managing change here. For people you work with, your partners, supporters and funders, it’s also important that they know about the policy so that they know what information they can expect and crucially, what information you will not be sharing.
Ideas for communicating the Open Information Policy
To people within your organisation:
- breakfast briefing
- specific staff and volunteer meeting
- scenario planning for each team – what does the OIP mean for their work?
- board meetings
To your supporters, partners, funders and the people who use your services:
- your website, either on an existing About Us page, or a new Open Information page.
- Facebook and Twitter accounts
- annual report and accounts
- grant funding applications and annual reports
Further information and support
If you would like further information and support on how to develop an open information policy for your organisation, please contact us at [email protected].