Plan policy template - Plan International USA

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Oct 31, 2015 - a) Chief Marketing Officer with support from Chief Information Officer: Publication of information on Pla
Plan International USA policy Open Information Policy

Policy Name: Owner:

Approved by: Date of Approval: Version: Date of next review: Applicable to: Related Documents:

Contact:

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Open Information Policy Senior Advisor, Innovation, Transparency and Strategic Change

1.0 10/31/2015 All Plan International USA Staff • International Aid Transparency Initiative (IATI) Standards • Plan International Information Disclosure Policy • Plan International USA Child Protection Policy • Confidentiality Policy • Privacy Policy [email protected]

Open Information Policy Summary/Purpose Plan International USA is committed to the principle of transparency in our operations, as a means of enhancing our accountability both to the children and communities with and for whom we work, and to those who provide us with the funding and other resources required to fulfill our mission. This policy describes the data that Plan International USA will make publicly available either proactively or on request, how and when it will be shared, and explains any exclusions that will be made and the rationale for them.

Scope This policy applies to organizational and program management information from Plan International USA. For information and documents produced by Plan International Inc., (International Headquarters, Regional Offices, and Country Offices) please see the Plan International Information Disclosure Policy. Due to the pooled nature of sponsorship funds, detailed information on program work funded with sponsorship funds raised by Plan International USA falls under the scope of the Plan International Information Disclosure Policy and is not covered under this Plan International USA policy. (Summary information is available through the Plan International USA Annual Report and Accounts.)

Policy 1.1 Plan International USA’s Open Information Policy (hereinafter referred to as the “Policy”) is intended to ensure that Plan follows the International Aid Transparency Initiative (IATI) guidelines and standards for the publishing of international aid data. The following information will be made available to the public in phases by October 15, 2016, with the exception of confidential or sensitive information as outlined under “Exclusions”: i) Phase 1 (by October 15, 2013): (1) Plan International USA Operations: Annual report and financial report, governance structure and board members, and Plan International USA’s program strategy. (2) Plan International USA Programs: Project name, period of performance, description, funding source, total budget (initially for projects of $200,000 or above) funded by bi- or multi-lateral donors, foundations and corporations and where Plan is the primary recipient and implementer. ii) Phase 2 (by October 15, 2014): In addition to the above, summary of proposals, disbursement and expenditure (as internal systems permit), results when projects conclude, and external audit (where available) for projects of $200,000 or above funded by bi- or multi-lateral donors, foundations and corporations, where Plan is the primary implementer or where Plan is the sub-recipient and has authorization from the prime to publish. iii) Phase 3 (by October 15, 2016): information on funding that is received through sponsorship and other types of private giving, and information on grant funded projects under $200k, as internal systems permit and depending on Plan International’s progress with IATI publishing. 1.2 This policy is available on the Plan International USA website.

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1.3 As additional international transparency initiatives and standards emerge, this policy will be updated to reflect Plan’s growing interest in being as transparent and accountable as possible.

Responsibilities 2.1 Accountability for the implementation of this policy will lie with the Executive Office. Compliance with this policy is the responsibility of all staff within Plan International USA. 2.2 Specific responsibilities are as follows: a) Chief Marketing Officer with support from Chief Information Officer: Publication of information on Plan International USA website b) Communications Director: Provision of information in response to requests c) Provision of information for publication: (1) Special Assistant/Board Liaison: On Governance (2) Chief Financial Officer: On Finance (3) VP for International Programs: On Programs (4) Chief Marketing Officer: On Advocacy & Campaigns

Procedures Information publication Plan International USA will publish to the IATI standard on a bi-annual basis. 3.1. Information will be published on the Plan International USA website and a link to this information will also be made available through the IATI Registry. 3.2 If the information is not readily available, the public can contact Plan International USA directly at [email protected] to inquire whether further information can be given. 3.3 Plan International USA will endeavor to make its information available in formats that are compatible and comparable with emerging international standards and formats, such as IATI, to enable more effective use of that information by people outside of Plan. Responding to Requests 3.4 The appropriate VPs and Directors within Plan International USA are responsible for ensuring that requests for information from interested parties relating to their areas of work are addressed. 3.5 A response to a request for information will be given within two working weeks of the request. 3.6 If a request is denied, a justification will be given. Procedure for Appeal to the Chief Executive Officer

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3.7 In the event that the person making a request for information is not satisfied with the response from the responsible VP or Director and a request for information is denied in whole or in part, the person making the request may ask for a review of this determination by the CEO whose decision will be final. 3.8 Every request for appeals will be acknowledged. The CEO shall review the denial of requests to disclose a document or portion of a document to a member of the public, and provide a final determination generally within 30 calendar days of receipt of the appeal but never later than 60 calendar days. Progressive Publication Sensitizing and supporting all staff to value transparency and open information and ensuring that we have cost-efficient systems in place to make information available will take time. Plan International USA will adhere to the principle of “publish what you can,” and will set targets that require it to progressively move towards full compliance with this policy. Plan International USA’s Implementation Plan for IATI sets out our timeframe and commitments in this regard. Exclusions While seeking to maximize our transparency, there will be circumstances in which Plan International USA will not disclose certain information. Reasons for exclusion will be: • Security: we will not publish information on activities where there is a significant likelihood that such publication would place the security of staff, partners, or communities we work with at risk. • Data Protection: we will not publish any information that contravenes Plan International USA’s Privacy Policy, Confidentiality Policy, Child Protection Policy or any relevant US legislation. • Child Protection: we will not publish information that would expose children we work with to potential abuse, privacy risks or exploitation. This primarily relates to personal information (full names and contact details) regarding sponsored children and other children we work with but also includes their schools or club meeting places. • Commercial sensitivity: we will not publish information that would harm either the financial interests of Plan or those of other parties involved. This may include but is not limited to detailed unit costs (e.g. individual salaries and payment rates), proprietary proposal information, and fundraising/ marketing plans. • Confidentiality: we will not publish information received from or given to third parties under an expectation of confidentiality, including research subjects. • Information covered by legal privilege, intellectual property, or related to access to internal audit reports will not be published. • Historical Documents: this policy applies only to information related to current and new activities starting from the time the policy is approved. Given the level of effort required, we will not retroactively publish information. • Cost effectiveness: we will not publish information if the costs of producing it significantly outweigh any possible benefits from the public sharing of that information, or if requests for information are considered dilatory. This may include setting a minimum project value below which we will not produce and update information. Annexes Plan’s IATI publication schedule, description of information to be published, and definition of data.

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