In the search for evidence of impact, donors and investors are asking that more and more data be generated by grantees and those they serve. Some of those driving this conversation talk about the ‘opportunity cost’ of not collecting, opening and sharing as much data as possible. Yet we need to also talk about the real and tangible risks of data collecting and sharing and the long-term impacts of reduced data privacy and security rights, especially for the vulnerable individuals and groups with whom we work.
This week I’m at the Global Philanthropy Forum Conference in the heart of Silicon Valley speaking on a panel titled ‘Civil Liberties and Data Philanthropy: When NOT to Ask for More.’ It’s often donor requests for innovation or for proof of impact that push implementors to collect more and more data. So donors and investors have a critical role to play in encouraging greater respect and protection of the data of vulnerable individuals and groups. Philanthropists, grantees, and investees can all help to reduce these risks by bringing a values-based responsible data approach to their work.
Here are three suggestions for philanthropists on how to contribute to more responsible data management:
1. Enhance your own awareness and expertise on the potential benefits and harms associated with data.
- Adopt processes that take a closer look at the possible risks and harms of collecting and holding data and how to mitigate them. Ensure those aspects are reviewed and considered during investments and grant making.
- Conduct risk-benefits-harms assessments early in the program design and/or grant decision-making processes. This type of assessment helps lay out the benefits of collecting and using data, identifies the data-related harms we might we be enabling, and asks us to determine how we are intentionally mitigating harm during the design of our data collection, use and sharing. Importantly, this process also asks us to also identify who is benefiting from data collection and who is taking on the burden of risk. It then aims to assess whether the benefits of having data outweigh the potential harms. Risks-benefits-harms assessments also help us to ensure we are doing a contextual assessment, which is important because every situation is different. When these assessments are done in a participatory way, they tend to be even more useful and accurate ways to reduce risks in data collection and management.
- Hire people within your teams who can help provide technical support to grantees when needed in a friendly — not a punitive — way. Building in a ‘data responsibility by design’ approach can help with that. We need to think about the role of data during the early stages of design. What data is collected? Why? How? By and from whom? What are the potential benefits, risks, and harms of gathering, holding, using and sharing that data? How can we reduce the amount of data that we collect and mitigate potential harms?
- Be careful with data on your grantees. If you are working with organizations who (because of the nature of their mission) are at risk themselves, it’s imperative that you protect their privacy and don’t expose them to harm by collecting too much data from them or about them. Here’s a good guide for human rights donors on protecting sensitive data.
2. Use your power and influence to encourage grantees and investees to handle data more responsibly.
If donors are going to push for more data collection, they should also be signaling to grantees and investees that responsible data management matters and encouraging them to think about it in proposals and more broadly in their work.
- Strengthen grantee capacity as part of the process of raising data management standards. Lower-resourced organizations may not be able to meet higher data privacy requirements, so donors should think about how they can support rather than exclude smaller organizations with less capacity as we all work together to raise data management standards.
- Invest holistically in both grants and grantees. This starts by understanding grantees’ operational, resource, and technical constraints as well as the real security risks posed to grantee staff, data collectors, and data subjects. For this to work, donors need to create genuinely safe spaces for grantees to voice their concerns and discuss constraints that may limit their ability to safely collect the data that donors are demanding.
- Invest in grantees’ IT and other systems and provide operational funds that enable these systems to work. There is never enough funding for IT systems, and this puts the data of vulnerable people and groups at risk. One reason that organizations struggle to fund systems and improve data management is because they can’t bill overhead. Perverse incentives prevent investments in responsible data. Donors can work through this and help find solutions.
- Don’t punish organizations that include budget for better data use, protection and security in their proposals. It takes money and staff and systems to manage data in secure ways. Yet stories abound in the sector about proposals that include these elements being rejected because they turn out to be more expensive. It’s critical to remember that safeguarding of all kinds takes resources!
- Find out what kind of technical or systems support grantees/investees need to better uphold ethical data use and protection and explore ways that you can provide additional funds and resources to strengthen this area in those grantees and across the wider sector.
- Remember that we are talking about long-term organizational behavior change. It is urgent to get moving on improving how we all handle data — but this will take some time. It’s not a quick fix because the skills are in short supply and high demand right now as a result of the General Data Protection Regulation (GDPR) and similar laws that are emerging in other countries around the world.
- Don’t ask grantees to collect data that might make vulnerable individuals or groups wary of them. Data is an extension of an individual. Trust in how an organization collects and manages an individual’s data leads to trust in an organization itself. Organizations need to be trusted in order to do our work, and collection of highly sensitive data, misuse of data or a data breach can really break that trust compact and reduce an organization’s impact.
3. Think about the responsibility you have for what you do, what you fund, and the type of society that we live in.
Support awareness and compliance with new regulations and legislation that can protect privacy. Don’t use ‘innovation’ as an excuse for putting historically marginalized individuals and groups at risk or for allowing our societies to advance in ways that only benefit the wealthiest. Question the current pathway of the ‘Fourth Industrial Revolution’ and where it may take us.
I’m sure I’m leaving out some things. What do you think donors and the wider philanthropic community can do to enhance responsible data management and digital safeguarding?
Linda Raftree is an Independent Consultant and MERL Co-Founder