The WATAN Scheme for Flood Relief - Pakistan Floods 2010

The WATAN Scheme for Flood Relief: Protection Highlights 2010 ‐ 2011

THE WATAN SCHEME FOR FLOOD RELIEF: PROTECTION HIGHLIGHTS 2010‐2011

Table of Contents

Summary of Key Recommendations ........................................................................................... 5 Abbreviations and Acronyms ................................................................................................... 7 Introduction ....................................................................................................................... 8 Part 1: Background ............................................................................................................... 9 1.1 A History of cash transfer in Pakistan ............................................................................... 11 Part 2: Procedure and implementation ..................................................................................... 13 2.1 Eligibility criteria....................................................................................................... 13 2.2 Information dissemination ............................................................................................ 13 2.3 The registration process .............................................................................................. 14 2.4 Grievance/redressal system .......................................................................................... 16 2.5 Release of payments ................................................................................................... 17 Part III: Key Protection Concerns ............................................................................................ 19 3.1 Data sources ............................................................................................................ 19 3.2 Information dissemination ............................................................................................ 20 3.3 The registration process .............................................................................................. 21 3.4 Grievance/redressal system .......................................................................................... 26 3.5 Release of payments ................................................................................................... 27 Part 4: Recommendations for Phase I, II and beyond WATAN ........................................................... 29 4.1 PHASE I Grievances .................................................................................................... 29 4.2 PHASE II .................................................................................................................. 30 4.3 Information dissemination ............................................................................................ 30 4.4 Identification of Eligible Households ................................................................................ 31 4.5 Registration/verification process .................................................................................... 31 4.6 Grievance procedure .................................................................................................. 32 4.7 Release of payment .................................................................................................... 34 4.8 Reporting/Monitoring/Analysis ....................................................................................... 35

Part 5: Conclusion: Beyond WATAN ......................................................................................... 36 Annex A: Institutional Arrangements........................................................................................ 37 Annex B: Application Process ................................................................................................ 39 Annex C: Registration Form .................................................................................................. 40 Annex D: Best Practices ....................................................................................................... 41 Annex E:World Bank MOU with the Government .......................................................................... 43 Annex F: Protection Response to Reported Protection Concerns....................................................... 44 Annex G: List of Flood Affected Districts: Source: NDMA - January 2011 ............................................. 46

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FOREWARD In the summer of 2010, Pakistan experienced the worst flooding in its history. It followed heavy monsoon rains across the four regions of Khyber Pakhtunkhwa, Sindh, Punjab, and Balochistan. According to data released by the Government of Pakistan (GoP), the floods directly affected some 20 million civilians. The disaster seriously damaged public infrastructure, including roads, bridges, schools, health, and education facilities. Families lost their crops, livestock and agricultural land, essential for their livelihoods. Their homes were damaged or destroyed completely, leaving millions homeless and displaced. The sheer scale of the disaster and the unprecedented number of vulnerable people exceeded the capacity of any single stakeholder. The geographical scale of the disaster and the number of affected people made it a more complex situation than almost any other ever faced by the humanitarian community. At the earliest stage of the disaster, the GoP recognized that humanitarian aid alone would not be able to provide relief quick enough to alleviate the suffering of those caught in danger. Rightly so, the Government decided to embark upon a large scale cash relief programme called the WATAN Scheme. The aim was to provide a more rapid alternative source of assistance to affected families in the flood areas. Indeed, the scheme reached many flood affected populations in reasonable time, providing the much needed assistance. The WATAN Scheme for Flood Relief: Protection Highlights’ is, therefore, a report that looks at how this important scheme was implemented. It also suggests and recommends ways of improving the process so that more beneficiaries, including the most vulnerable persons, can be reached in future disasters. As pointed out, the WATAN scheme is an innovative tool that provides quick relief to those hit by large scale disasters/emergencies. The report, therefore, highlights the mechanisms used in the 2010 disaster, as much as it raises key protection concerns and recommendations designed to provide the lessons learned. The recommendations at the end of the report are intended to guide the Government, UN agencies and other aid actors to improve the process to better target the most vulnerable among the affected people. The report is the work of the Protection Cluster which functioned between August 2010 and January 31, 2011. It is based on data collected by its members, through the Rapid Protection Assessments that took place between August 2010 and January 2011. The Cluster conducted 2970 focus group discussions, covering 25 affected districts and involved an estimated 56,000 individuals. It is the Protection Cluster’s hope that all the stakeholders that were involved in the WATAN process will utilize this tool in designing and implementing the second phase of the payment scheme, as well as for future natural disasters in Pakistan. Considering that Pakistan is prone to disasters, the WATAN scheme is a creative initiative for the humanitarian community to build on for a predictable response to future disasters

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Many other actors participated in the making of this report and its compilation was guided by UNHCR as the Protection Cluster co‐ lead. I recognise that the WATAN process is an evolving one, and on behalf of the Protection Thematic Working Group, I encourage all actors to continue to contribute information and support to the GoP in order to continuously improve on this initiative. I would, therefore, like to express my profound gratitude to everyone who supported UNHCR by providing information or responding to issues that we raised, including, but not limited to, NADRA, NDMA, the provincial and district governments, IRC as Protection Cluster co‐lead and all Protection Cluster members. Lastly, I wish to thank the Norwegian Refugee Council (PROCAP) for deploying staff to support the Protection Cluster in Pakistan. Mengesha Kebede UNHCR Country Representative Pakistan

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SUMMARY OF KEY RECOMMENDATIONS The cash compensation scheme is an innovative tool which facilitates the provision of quicker alternative support to those hit by large scale disasters/emergencies. From a protection stand point, all efforts should, however, be made to ensure the most vulnerable persons have access to the scheme, while responding to the needs of all the affected communities without favour or discrimination. This report, therefore, highlights protection concerns and suggests recommendations for better response. These are the key recommendations:

To NADRA: Use its technical expertise to provide a detailed operational manual for each step in the implementation of Phase II of the WATAN process; providing clear guidance to staff involved in the WATAN scheme. Solicit technical advice from mandated protection organizations. Include within the operational framework the supporting activities of and mechanisms for collaborating with the humanitarian community. Ensure that eligibility criteria are outlined and that definitions of damage and of household are included. Ensure roles and responsibilities are clearly outlined. Ensure that the appeals process is inclusive of all grievances, including allegations of assessment irregularities, discrimination, extortion, corruption, and access issues. Make this document publicly available to establish transparency. Ensure standardization of the procedures, including during implementation through the training and monitoring of NADRA, DCO, IOM, and NGO staff. Continue to carry out outreach activities through mobile vans to support access to civil documentation, WATAN verification and the addressing of grievances. Ensure that all NADRA Centers and mobile vans are sensitive to the special needs of women, older persons and persons with disabilities by deploying female staff, prioritizing the most vulnerable and establishing separate queues and spaces for women and men.

To Cabinet Division/NDMA/PDMA/DCO: Collaborate closely with the existing humanitarian coordination mechanisms, NGOs and IOM to ensure access to the communities for information dissemination and for ensuring the inclusion of all eligible households. Ensure clear, accurate and timely information on the current situation for addressing grievances for Phase I and ensure that any deadlines/cut‐off dates are clearly communicated to the beneficiaries before such dates come into effect. Ensure clear, accurate and timely information on the eligibility criteria, the verification procedures and the appeals process for Phase II. Increase outreach programmes for information campaign to rural areas targeting women, older persons, persons with disabilities and minority communities. Establish systems for monitoring to ensure equity at each stage of the process and have clear and transparent mechanisms in place to take action on allegations of discrimination and/or corruption.

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Deploy additional DCO staff (including female staff) at NADRA registration centres for addressing grievances/complaints. Ensure, through monitoring and training, that all provinces use the same grievance procedure and rejection reasons. Ensure that all DCO grievance centers / sites are sensitive to the special needs of women, older persons and persons with disabilities by deploying female staff, prioritizing the most vulnerable and establishing separate queues and spaces for women and men. Strengthen agreements with the participating banks to improve their accountability to beneficiaries.

To Donors Make distribution of funds for Phase II dependent on successful resolution of pending grievances, based on independent monitoring. Make distribution of Phase II dependent on the establishment of satisfactory systems to reduce issues of exclusion, particularly through discrimination or corruption. Encourage and financially support the standardization of Phase II across Pakistan, through financial assistance for training, monitoring, staff deployment and the development of standard systems and procedures. Financially support the human resources and logistical requirements involved in ensuring that the implementation of the scheme is gender sensitive and accommodates the needs of the most vulnerable – additional female staff, separate spaces, increased mobile/outreach and accessibility. Financially support the issuance of civil documentation (CNIC, birth, death, marriage, divorce registration) through mobile registration and cover the fees for flood‐affected communities. Consider the exclusion issues faced during WATAN and previous cash compensation schemes; and, in the future, design schemes that are not solely dependent on beneficiaries possessing and being identified as head of family on the basis of a CNIC. To all, review the detailed recommendations at the end of this document and incorporate mechanisms to ensure that protection concerns are removed from the process.

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ABBREVIATIONS AND ACRONYMS ATM BISP CNIC DCOs PPAF FAQ’s GoP HH HoF IOM PDMA IDP KPK MC NADRA NDMA PKR SMBR UNHCR NRC MRV

Automated Teller Machine Benazir Income Support Programme Computerized National Identity Card District Coordination Officers Pakistan Poverty Alleviation Fund Frequently Asked Questions Government of Pakistan Household Head of Family International Organisation for Migration Provincial Disaster Management Authority Internally Displaced Person(s) Khyber Pukhtunkhwa (province) Mass Communications National Database and Registration Authority National Disaster Management Authority Pakistan Rupees Senior Members Board of Revenues United Nations High Commissioner for Refugees Norwegian Refugee Council Mobile Registration Van

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INTRODUCTION In July 2010 Pakistan experienced the worst flooding in its history following heavy monsoon rains in the Khyber Pakhtunkhwa, Sindh, Punjab, and Balochistan regions of Pakistan. According to data released by the Government of Pakistan (GoP), the floods directly affected 20 million people, destroying property, livelihoods and infrastructure. The GoP estimates nearly 2,000 people lost their lives and 1.7 million homes were either partially or totally destroyed 1. While respondents from the profiling exercise Photos: Courtesy of UNHCR and UNOCHA conducted by NADRA and UNHCR reported more than 10,000 deaths after the floods.2 Having realised that humanitarian aid alone would not be able to provide relief quick enough to all in need, the GoP decided to embark upon a large scale cash relief program to affected families in the flood affected areas. During the flood emergency the cluster approach was activated and the protection cluster, as per its mandate, provided technical advice and undertook monitoring in the field during the implementation of the scheme. The cluster further advocated for the inclusion of the most vulnerable into the cash scheme3. The following report is prepared based on inputs from cluster members, protection partners, and government authorities and it analyzes the protection implications of this WATAN card/cash compensation scheme. The findings are meant to provide the basis for a constructive dialogue with the GoP and the international community for possible improvements during the second installments, as well as for future cash compensation schemes. It is acknowledged that any compensation scheme of this scope covering such a huge and diversified area represents considerable challenges for any Government. This is especially given the urgent time frame within which the scheme had to be set up and implemented.

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Source for NDMA data: http://www.pakistanfloods.pk/response/gender‐a‐child‐cell/press‐release “Watan Card Project 2010 – 2011: Profiling of Flood Affected Population in Pakistan” 3 The protection cluster for flood response (in the early recovery phase known as the protection thematic working group) in Pakistan is led by UNHCR with sub‐clusters on child protection (UNICEF) and GBV (UNFPA); an age and disability working group as well as a housing, land and property rights working group complement the cluster set up. The International Rescue Committee (IRC) is currently functioning as the protection cluster NGO co‐lead. Several INGOs, NGOs and ICRC as observer are part of the cluster. 2

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The report is divided into 4 parts, excluding the conclusion: (i) a brief overview of the development of the scheme including prior similar exercises, (ii) the set up of the procedure divided step‐by‐step including particularities at the provincial level, (iii) the protection challenges emanating from the procedure and its implementation, (iv) recommendations for different actors involved in the cash compensation scheme to ensure protection concerns are taken into account in the process.

Map 1: Reported Deaths in Family as % of Total Reported Deaths

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Part 1: Background In the aftermath of the 2010 floods, the GoP established a cash compensation scheme to provide immediate relief to the most severely impacted among the 20 million affected persons. The design of the cash transfer programme was based on two previous cash compensation schemes that had been established in response to the earthquake in 2005 and the ongoing conflict displacement that commenced in 2007. In the scheme for the floods response, the GoP initially proposed that each family located in a flood affected area would get compensation of PKR 100,000 disbursed in two installments; PKR 20,000 followed by PKR 80,000. The money was to be disbursed through the issuance of WATAN Cards (ATM card). The funds would be transferred into the participating banks. Based on funding constraints, it was finally agreed that the second phase would be a total of PKR 40,000 and that the beneficiary numbers would be restricted to households 4whose houses suffered damage during the floods. Widows and disabled heads of households would be included regardless of whether their houses were damaged. The second round of WATAN cash transfer would be based almost solely on those who were registered during the first phase.5 For Phase I cash payments the provincial and federal governments contributed 50 percent funding each for the scheme. In a first meeting of the National Disaster Management Council, attended by the Chief Ministers of the provinces and relevant Federal ministers, it was decided that the National Database Registration Authority (NADRA) would manage the registration process. It was agreed that the National Disaster Management Authority (NDMA), the Ministry of Social Welfare, United Nations High Commissioner for Refugees (UNHCR) and the provincial authorities, through the respective Provincial Disaster Management Authority (PDMA), would provide the necessary support to the exercise.6 NDMA predicted that approximately 1.6 million families would be registered for the WATAN card scheme. According to NADRA, as of 28 May 2011, in total 1,637,717 cards had been processed, 1,635,168 of these cards were issued and 1,580,954 were activated; 32,690 cards were not verified by NADRA and therefore not activated. 7 4

Watan card Operational Manual, second tranche The World Bank has agreed with the Government to include certain vulnerable persons who were left out of Phase I in Phase II. 6 See annex A for the institutional arrangement for the implementation of the program. 7 See WATAN card progress report 28 May 2011. 5

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Initially, the planning foresaw that the whole registration process was to be completed by mid December 2010 (with Balochistan scheduled for end of December 2010 because the registration process started late there). However, UNHCR raised concerns regarding those persons who had not been able to register on time and thus, the programme was extended, with the exception of Punjab, who shut their centres on 15 December 2010. During the WATAN Registration process families were requested to complete a simple registration form designed by UNHCR (see Annex C). Because of the time lag between data input and processing the numbers for the following report are based on a total of 1,222,908 flood‐affected internally displaced families registered in the period September to December 2010 (see figure below). The majority of the respondents were registered in Punjab (63%), followed by Sindh (26%).8 The registrants in Balochistan, Khyber Pukhtunkhwa and from other areas make up the remaining 11%. The detailed registration process did not take place in Kashmir or Gilgit‐Baltistan and because the issuance of WATAN started later in Balochistan registration data has not yet been processed for all. Of the registered respondents, 92% were male head of family or their representatives. Only 8% of the registrants were women, with the highest number of them in Punjab with 46,503. Sindh registered f34,658, Khyber Pukhtunkhwa 11,938 and Balochistan recorded 4,240.9 The reason for the scarce inclusion of women is that they are rarely registered as heads of families on their CNICs, even when they are de jure heads.10 Overall registration of CNICs for women in general lags behind that of men. 1.1 A History of Cash Transfer in Pakistan It is not the first time the Government has launched a large scale registration and compensation scheme following natural disaster or displacement. After the 2005 South Asia earthquake, affecting AJK and NWFP which killed 73,000 and made 3.5 million persons homeless, the Government quickly endorsed two compensation schemes: one‐off payment of 3,000 PKR for livelihoods with a housing reconstruction programme. Government house rebuilding payments and loss of land compensation payments followed. Some key issues that came up as lessons learnt included: questions around transparency of the eligibility criteria, and problems of access to the scheme for those without CNICs. Cash disbursement was done through cheques, which required that beneficiaries visit post offices or banks to open bank accounts, in order to access the cash. Lack of capacity and liquidity at local banks were reported to be problematic. The 8 9

“Watan Card Project 2010 – 2011: Profiling of Flood Affected Population in Pakistan” ibid See Eligibility Criteria to understand the importance of the CNIC and identification of the ‘head of family’.

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extent of the problem was demonstrated through the registration and support by the Norwegian Refugee Council (NRC) to more than 41,000 households trying to access the scheme. The majority of the cases required administrative support and recovery of CNICs. Following the IDP crisis in Khyber Pakhtunkwa (KP) in 2009, the Government initiated a compensation programme that included a one‐off payment of 25,000 PKR and a special regime for South Waziristan with a monthly payment of 5,000 PKR paid for 5 months. IDP registration was again based on the possession of a valid CNIC. Families without CNICs were referred to mobile NADRA units but were in many cases prevented from registration due to technical problems, such as extended family tree records, data entry errors, duplication in the system or other technical constraints. Of the total 558,125 HH registered, only 268,672 were initially found eligible; however, approx. 400,000 in the end benefited from the scheme. Other concerns reported to the Humanitarian Country Team at the time are similar to those that have been reported during the implementation of the WATAN scheme. This included: registration being open only to those coming from notified areas with the process of notification being unclear; lack of dissemination of information to IDPs humanitarian agencies and civil society; difficult access to registration points with registration points located only in official camps and a single off‐camp location per district. IDPs were scattered throughout districts and were not always able to travel the long distances to the official registration points; Access issues also existed for persons with special needs as no separate desks or lines for women and vulnerable groups were provided; security incidents were also reported at registration points. Unfortunately, protection concerns identified during these earlier cash transfer schemes continue to be of concern in the current exercise (as outlined below), thus, providing a strong argument to review and improve the procedures. To the extent possible, the protection cluster responded to these concerns as they arose and advocated for protection concerns to be solved. A detailed overview of these interventions is attached as Annex F. However, many protection concerns continue to exist in the current WATAN scheme and remain of concern for the second phase and future design of large scale cash transfer schemes. Identified protection issues will be outlined in the following chapter.

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Part 2: Procedure and Implementation In order to understand the protection concerns which emerged from the WATAN card scheme the procedure and its implementation needs to be outlined first. The overall procedure can be divided in different steps which cover: (i) the information dissemination about the WATAN cards as such, (ii) the registration process, the grievances/redressal procedure, (iii) (iv) the release/receipt of the payment. The overall implementation procedure was established by the federal government; however, at province level some divergent practices were observed which will be highlighted accordingly. 2.1 Eligibility Criteria Any citizen of Pakistan registered in the NADRA CNIC database as head of a family residing in one of the Government notified flood affected areas, as recorded in at least one of his/her addresses on the CNIC. A family is defined by NADRA’s business rules as “two or more spouses with their unmarried children”. No other family member was eligible to register for the WATAN scheme. Refugees, stateless persons, and other immigrants were not eligible to receive this compensation.11 2.2 Information Dissemination Step 1: Information campaign on the WATAN cards and the procedure According to the agreement on the institutional roles and responsibilities of key institutions (see Annex A) the Provincial Governments/PDMAs were entrusted with the local information campaign on the WATAN scheme. However, it is not clear which systematic measures they took to implement the information campaigns. NADRA also established help‐lines to provide information on the procedures for accessing WATAN cards which were widely publicized in the media to provide information on the scheme and support remedial systems. Other independent organisations, such as the International Organization on Migration (“IOM”) and other NGOs contributed to passing on information by providing training to staff, printing and distributing banners at ATMs, launching radio announcements as well as carrying‐out awareness raising sessions in the field and field staff based in 18 severely flood affected districts helped to report challenges and access assistance. IOM and the participating banks also established telephone help‐lines offering advice and information to the public.

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As the scheme only covered Pakistani nationals and given UNHCR’s mandate, Afghan refugees affected by the floods were assisted with UNHCR’s non‐food item kits, emergency shelter and community based projects.

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2.3 The Registration Process Step 1: Revenue Departments identify and notify flood affected areas and communicate this to NADRA Beneficiaries of the WATAN scheme are those families living in areas notified by the Government as flood affected. It was agreed that the provincial governments (District Coordination Officers through Senior Members Board of Revenue [SMBR]) would notify NADRA with the names of districts and, where required, Tehsils and Union Councils affected by the flood.12 The lists of notified areas were changed and modified based on updated information ‐ for example, in Sindh the same list was revised several times due to areas being inaccessible due to the water levels. The villages were supposed to be selected after a house to house damage assessment undertaken by the district governments through the revenue departments. The decision was made that any village suffering more than 40 percent damage to their property would be eligible for compensation.13 Unlike the other provinces, in Khyber Pakhtunkhwa (KP) province, flood affected Districts; Tehsils and Union Councils were not identified and used to determine eligibility criteria. In KP the damage assessments were used to provide the names of affected families to NADRA based on housing damage and the decision of local committees. Step 2: NADRA populates the list of families which are listed in the national identity database In the provinces other than KP, NADRA then extracted the names of all heads of families registered as residents in these areas from their existing database and returned the list to the PDMAs. In KP, NADRA took the list of families and verified the data in their database. Step 3: PDMAs check and approve list of flood affected families and send it back to NADRA for registration and issuance It is unclear what the procedure involves for checking these lists and what criteria is used. Step 4: Registration at NADRA office: access and set‐up of centres The WATAN Card registration centers were established by NADRA at district and tehsil level and in some cases at Union Council Level. According to NADRA, throughout the 5 provinces 128 registration centres were set up by NADRA.14 The opening hours of the centres were from 9 am to 4.30 pm, Monday to Friday. Each centre had four main desks: NADRA registration desk, 12

In Pakistan, the term tehsil is generally used except in Sindh where the term taluka (Urdu: ‫)ﻩقلعت‬ predominates, [1] e.g., Larkana Taluka. The tehsil is the second‐lowest tier of local government in Pakistan; each tehsil is part of a larger District (Zila/Zilah (Urdu: ‫))علض‬. Each tehsil is subdivided into a number of Union Councils. (From Wikipedia, the free encyclopedia.) 13 The criteria announced was based on 40% damage to any particular village. However, since the magnitude was so high, in many cases, the list included all villages in a given tehsil or sometimes district.. 14 Flood affected provinces are Punjab, Sindh, KPK, Balochistan, AJK and Gilgit‐Balistan. However, only the provinces of Punjab, Sindh, KPK and Balochistan are covered in this report due to coverage of humanitarian actors able to provide information/assessment on protection concerns.

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NADRA’s biometrics desk, UNHCR’s form filling desk and the desk where the WATAN cards were issued (see Annex B). Some centres later in the process established a complaints desk for facilitating the registration of complaints by the flood affected families. Step 5: Registration at NADRA office: Authentication through CNIC At the registration desk those registering for the WATAN card had to present their CNIC card. The CNIC card had to indicate that the bearer was the head of the family, as residing in a notified flood affected area and the CNIC had to be checked for authenticity and problems ‐ for example, only CNICs issued with the complete biometrics could be accepted. As many families did not have CNICs, had problems with their CNICs or had lost civil documentation due to the floods, NADRA agreed to facilitate flood affected Pakistanis with a fast track process to access or amend CNICs free of charge.15 Step 6: Registration at NADRA office: NADRA staff checked finger prints and verified with the national database NADRA used the sophisticated biometrics methodology to verify the identity of the bearer and to prevent duplicate applications. It took NADRA 48hrs to verify the applicant’s finger prints. WATAN cards were issued at the time of registration, but it was only after this final verification that the WATAN Card was actually activated. Step 7: Registration at NADRA office: applicant fills registration form with signature The registration and verification of 1,222,908 flood‐affected internally displaced families in the period September to December 201016 offered an unprecedented opportunity to assess the impact of the floods with a particular emphasis on protection. With UNHCR’s long standing experience of using registration as a protection tool the Government requested UNHCR to design a registration form that could enable humanitarian stakeholders to gather useful qualitative and quantitative data on flood affected populations and that would supplement the information available in the CNIC database.17 The form’s design was based on the 2009 IDP registration form with modifications based on input from a variety of stakeholders. The form was part of the registration process and school teachers served as enumerators by asking the questions and filling out the form. Data on this form included the CNIC number, numbers and ages of family members, details of any special needs of the head of family, information on damage to housing and other losses. Given the volume of this statistical data the analysis has been presented in a separate report which will be published alongside this report. 15

See for example in “FAQs II Punjab” and a FAX sent from NADRA Islamabad on 20 August 2010 to the provinces. “Watan Card Project 2010 – 2011: Profiling of Flood Affected Population in Pakistan” 17 See Annex C. 16

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Step 8: Registration at NADRA office: at “bank counter” applicant receives WATAN card including PIN for usage at ATM With a separate paper the applicant received his/her WATAN card including a PIN to access the ATM. The Cards were issued prior to final verification of the biometrics which took place within 48 hours of issuance. Cards were activated after final verification. 2.4 Grievance/Redressal System This mechanism was made functional at both provincial and district levels. However, the system was put in place some time after the WATAN Card scheme had started. The mechanism was put in place gradually in different provinces from August‐ September 2010. The management structure for the grievance redressal was headed by the DCO at the district level. In addition to the above shown figure standard operating procedures (SOPs) were developed by respective PDMAs in Punjab and KP to address complaints of exclusion.18 Step 1: Applicant visits the DCO office to inquire about rejection reason According to the Grievance Redressal System (see above) applicants could either call the Call Centre established by NADRA to inquire about his/her rejection reasons or visit the DCO office. It is not clear how complaints made at the DCO Office linked into NADRA’s redressal system and vice versa. The system for redressal was essentially the same in all districts; however, based on the SOPs from NADRA, the complaints that could be handled by the system were different for each province: In Sindh and Punjab once an individual was rejected at the information counter at the NADRA centres they would be informed of the rejection and advised to lodge a complaint with the District Coordination Office (DCO) but only for the following reasons: (i) Address not matching i.e. “Goth (sub‐village) not linked with notified Dehat (village)”; (ii) “the marital status was not updated”; (iii) “Death registration/widow” In KPK, AJK and Gilgit‐Baltistan a complaint would only be retained if: (i) the CNIC was lost or (ii) the CNIC was wrong/invalid.19 For Balochistan, no agreement was made between the authorities and NADRA; however, the registration centers did establish their own redressal mechanism. Step 2: Applicant files a complaint and is provided with a complaint ID The complaint was supposed to be handled within an average processing time of 5 to 7 days. In order to track individual complaints and to enable NADRA to report on the types of complaints NADRA used the Complaint Management Solution (a web based solution). All stakeholders including beneficiaries would be able to track complaints and their status on the web by visiting www.WATANcard.nadra.gov.pk. 18

See NADRA document “Case Management – Complaint Redressal System”. “Invalid CNIC” means according to NADRA SoPs that the card has more or less than 13 digits.

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As of end of January 2011, using its Complaints Redressal System, NADRA had resolved 151,220 complaints received from flood affected population. In case, the complaint was successful, the DCO forward the case to the Provincial Disaster Management Authority (PDMA) along with the signed “Performa”.20 PDMA, acting as single point of contact, would forward the lists to NADRA. NADRA would subsequently check the CNIC of the applicant against its “internal business rules” outlined in the SOPs which said that the CNIC verified by the DCO had to fulfill the following criteria before being added to the list of beneficiaries: (i) CNIC need to be valid; (ii) any duplication will be rejected; (iii) one address has to be from the affected district; (iv) CNIC need to be clear in NADRA database, i.e. no duplication and/or fraud cases; (v) one beneficiary per family only. Verified records would then become part of the Flood Beneficiary List and all rejections would be provided to PDMA for information. Step 3: Applicant visits DCO office for second time to be briefed about rejection reason In case the applicant’s complaint was not successful, he/she could visit the DCO for a second time to inquire about the rejection reason. However, according to the Grievance Redressal System (see chart above) additional rejection reasons which were not part of the prior information could be brought forward by the DCOs.21 Step 4: Applicant files a petition in court It is unclear how this final stage will work as no complaints have yet been resolved through the courts. There are some 3000 cases pending in the courts in Punjab where all registration and complaints redressal closed as of 15 December 2010. More cases may be coming to the courts in other provinces as WATAN applications and ongoing verification is coming to an end. There are two possible legal options which might be available for filing a petition: (i) a petition filed by an individual using the civil jurisdiction and (ii) a petition filed by an individual and/or group at the High Court being based on Art. 199 of the Constitution (Mandamus writ) with the reasoning that NADRA and/or other authorities involved at redress mechanism (DCO etc) has not 'performed the duty' by issuing the WATAN card. 2.5 Release of Payments Step 1: Cash withdrawal at ATM For the delivery of payments to the beneficiaries the Federal Government engaged a consortium of three commercial banks (United Bank Limited, Habib Bank Limited and Bank Alfalah). The three banks had a nationwide coverage and were agreed to be made available 1,800 Point of Sale (PoS) machines and ATMs in the flood affected areas.

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Standardized complaint templates requiring specific information for eventually entering in the NADRA data base Since only a few types of issues (e.g. address related, marital status related and death/ widow etc) were redressed through the NADRA system, the additional reasons (e.g. duplicate CNIC etc) were provided to the applicant at this stage.

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After registration and verification with NADRA, the names of the heads of families were sent to the designated bank to create a virtual account and to transfer the money from the Provincial Government’s account to the Bank.22 The head of family subsequently could go to any of the ATMs across Pakistan of the participating banks and use the WATAN Card with the PIN provided to him/her upon registration to withdraw money without any bank charge. The WATAN card could also be used in other banks, but there was a charge at some banks. In addition to ATMs, the WATAN card could be used at temporary Point of Sale (PoS) machines. The respective banks also provided a real time update to the NADRA, NDMA and PDMAs about the payments released to each individual for reconciliation purposes. As of May 28, 2011, a total of 1,637,717 cards have been processed, 1,635,168 of these cards were issued and 1,580,954 were activated; 32,690 cards were not verified by NADRA and therefore not activated. 23 The number of ATM cards that have been activated can be obtained from the banks involved. As of 28 May 2011, the banks had disbursed a total of PKR 30,116,414,177 (PKR 4,289,783,491 in Khyber Pakhtunkhwa, PKR 11,988,756,829 in Punjab, PKR 11,324,882,493 in Sindh, PKR 2,158,823,864 in Balochistan) 24

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Virtual accounts are special purpose temporary accounts created for the transfer of payments. These accounts cannot be used as a regular drawing account. Each time a cash transfer is to be made to the beneficiary, another temporary account will be created just for the purpose of a one‐time transaction. 23

See WATAN card progress report 28 May 2011. Figures based on WATAN Card Progress Report dated 28 May 2011; AJK and Gilgit Baltistan are not mentioned above as the report does not include these areas.

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Part III: Key Protection Concerns The identification of key protection concerns and recommendations is designed to provide lessons learned and to develop improvements for the second round of the WATAN scheme and for the implementation of future cash compensation schemes. A large number of concerns and issues were raised by beneficiaries, affected populations, NGOs and other stakeholders during the registration process; however, most information was not compiled in a systematic manner. The following report therefore attempts to compile existing information based only on reliable data sources and quantifiable or verifiable data. It is important to note that the information outlined below is also supported by a vast array of anecdotal evidence, reports from monitoring visits, individual interviews, and secondary information. The protection concerns will be again linked to the respective steps of the overall procedure, i.e. information dissemination, registration process, grievance system, and release of payments. 3.1 Data Sources The protection cluster carried out a series of Rapid Protection Assessments (“RPA”) following the 2010 flood emergency; RPAs were carried out in Khyber Pakhtunkhwa in September 2010, Northern Sindh, Southern Sindh and Balochistan in November and December and Punjab in January 2011.25 Overall, 2970 focus group discussions were conducted covering 25 districts and an estimated 56,000 persons.26 A household survey focusing on WATAN issues was also conducted in Northern Sindh in January 2011 covering five districts and 825 households. Through its Humanitarian Call Centre and CARD database IOM traced complaints made with regards to WATAN cards and documentation issues covering all flood affected provinces. The International Rescue Committee (IRC) received individual complaints in their offices, Citizen Advice BureauX and through outreach, kept records of these complaints and shared concerns with the appropriate authorities. Oxfam GB was also involved in analyzing and sharing information collected from affected communities and beneficiaries.

25

The data from these RPAs are therefore varying depending on the time they were carried out and are stated in this report. The RPAs were conducted by the Multi‐Cluster Rapid Assessment Mechanism (McCRAM) in Pakistan. The aim was to: (i) better understand, at the community level, current protection trends and the concerns of flood affected persons, particularly in the returns and recovery context; (ii) use the findings to better focus existing and promised resources to priority areas, with a view to ensuring that the most at risk populations are served and (iii) develop new protection oriented projects in response to identified needs and protection trends. 26 RPAs were carried out in 10 districts and 162 UC in KP; 9 districts and 200 UC in Punjab; 10 districts and 61 UC in Sindh; 6 districts and 12 tehsils. 960 FGD in KPK; 1,200 Focus Group Discussions (FGD) in Punjab; 337 FGD/key informant interviews in Sindh; 173 FGD/key informant interviews in Balochistan. People surveyed were approximately: 19,200 in KPK; 24,000 in Punjab; 8,425 in Sindh; 4,325 in Balochistan.

19


UNHCR and NGO teams regularly visited the registration centres and randomly interviewed centre staff as well as applicants coming to the centres. During the whole registration exercise, the WATAN scheme was a permanent agenda point at the provincial protection working groups to get feedback from partners working in the field and address concerns locally. Findings from these missions were communicated to the national protection cluster. 3.2 Information Dissemination 3.2.1 Information dissemination did not sufficiently target affected populations living in remote locations, less literate populations or women confined to the private sphere. Adult literacy is very low in Pakistan according to the Pakistan Ministry of Education the total adult literacy rate is 66.25% for men and 41.75% for women.27 The literacy rate among the flood affected populations appears to be even lower than the national average with only 3% of the respondents reporting themselves to be educated. Targeting information for these groups would require community outreach workers and non‐written information to be the primary means of communication and this was not the case during the information campaign and provision of services that relied heavily on electronic media. 3.2.2 Overall the information campaign was not sufficient which meant that many communities and individuals were unsure of the procedures on how to access WATAN cards, the eligibility criteria, the grievance procedure and were therefore at risk of missing out on assistance, being exploited or excluded. 25% of focus group discussions in Northern Sindh and 32% in Southern Sindh mentioned that did not receive information on WATAN cards in Punjab, 18% of the focus group discussions indicated that they don’t know about the WATAN cards.28 A baseline study covering Sindh and Punjab indicated that only 36.3 percent of respondents said that the information that they had received had allowed them to get a WATAN Card.29

27

With Punjab at 60.8% (male 70%, female 51%), KPK at 47.4% (male 63%, female 30.8%), Sindh at 5.15% (male 60.5%, female 42.5%) and Balochistan at 34% (male 45%, female 23%) 28 See RPA Sindh and Punjab. 29 “Providing Humanitarian Information to Flood‐Affected People in Pakistan” Baseline Study Sindh and Punjab Nov‐ Dec 2010

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Although separate information desks were established in Sindh at registration centres, no separate information desks were established in the centres in Balochistan, KP, and Punjab for addressing the information needs of the people 3.3 The Registration Process 3.3.1 Some flood affected villages were not included in the list provided by the revenue department and the process for identifying flood affected villages was not systematic or transparent. According to FGD respondents in Punjab and affected communities in KP, allegedly political considerations, discrimination and bribes led to the wrong villages or individuals being added or left out of the notification list.30 In Sindh, a majority of the interviewees complained that their mozas were not included despite being fully affected.31 Based on individual complaints lodged with the IOM Humanitarian Call centre the most frequently recorded complaint was related to “assessment irregularities” with 22% of all callers32 while 13% of the complaints related to corruption at patwari level (98% of which came from KPK).33 In KPK and Balochistan individual cases rather than villages were included in the list of flood affected despite agreements that villages and districts would be identified and sent to NADRA for family identification. Reports came from KPK that the committees involved in making the decisions were not always fair, representative or transparent. In Sindh, any settlement smaller than village level was not included in list; the applicant had to go to nearest NADRA office, collect a form to update the address on his/her CNIC to reflect the list of notified areas and the nambardar (village leader) had to verify that the applicant is a resident of the area. This involved multiple travel and the costs and difficulties associated with this especially for those living in remote locations FHHs and the less mobile. Recommendations:

A transparent, standardized and documented process should be developed on how the assessment of flood affected villages takes place Assessments should be documented and monitored by independent monitors should be used to verify lists and decisions should be made based on standard criteria for assessment and verification. 3.3.2 The cost and inconvenience of travel and repeated visits impacted on many families’ ability to access the registration centre while adequately protecting their family members and dedicating time and money to reconstruction of lives and livelihoods. In Punjab, it was reported that in some centres there were cumbersome bureaucratic procedures which meant that multiple visits needed to be made, this made access to the facility very expensive and difficult particularly for the flood affected women and for those coming from remote places.34 30

See RPA Punjab. See RPA Punjab. 32 See IOM call centre database. 33 The data base tracked 389 calls regarding WATAN card complaints between mid January and mid March 2011. 34 See RPA Punjab. 31

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Management of the centres put people at risk of having to make multiple visits. Opening hours were reported not to have been observed thus forcing people to make repeated visits. In Punjab, the location of the registration center in Abad Pur Center in Rahim Yar Khan was changed without prior notice. In Punjab reports indicated that applicants were not informed about their date of receipt of WATAN Cards as well as the centre of delivery by the local government which meant that they sometimes needed to make multiple trips or to rely on informal information and middle men.35 3.3.3 Allegations of extortion and corruption added extra obstacles to accessing registration centres. In Balochistan 12% of the focus group discussions complained about extortion when trying to register for WATAN; during the RPA exercise, the teams reported on a daily basis that extortion was reported by flood affected surveyed in twelve tehsils in six districts of Balochistan; overall in Pakistan 49% reported that they paid at least one of nine service providers in 201036 3.3.4 Access to registration was not facilitated for women and persons with special needs. In most registration centres the set‐up was not suitable to assist the special needs of the vulnerable groups including persons with disabilities, pregnant women, women observing purdah, the sick and older persons, for instance no separate sitting and waiting area and no preferential handling of such cases was established. There were no separate waiting lines for women, making it culturally not acceptable for women practising purdah to access the centres and stand in line with men. 3.3.5 There were difficulties faced by many in accessing the required civil documentation, without which they could not access the WATAN registration. There were already low‐levels of civil documentation in many of the remoter flood affected areas and the floods exacerbated this issue. Prior to the floods, according to the DNA, at a national level only 72% of women had a CNIC and this was reportedly lower in rural and remote locations; CNIC registration of informal dwellers in Kacha areas also lagged behind. During the MCRAM assessment it was noted that at the national level some 4% of the respondents reported lost CNIC, Death and Birth Certificates with the highest numbers of lost documentation being reported in Sindh (note that Balochistan did not feature in the MCRAM survey). NADRA covered some districts with Mobile Registration Vans (“MRV”);37 however, while increasing awareness on the benefits of documentation and the procedures involved the services provided were not sufficient in most cases because: The MRVs could not issue the CNIC card which still has to be picked up at NADRA registration centre, the MRV had no access to NADRA data bank and thus could not verify any CNIC, the MRV could not process change of family status in CNIC (e.g. for married couples)

35 Punjab monitoring reports 36 See Transparency International website: transparency.org/policy_research/surveys_indices/gcb/2010/interactive. 37 E.g. in Sukker, 19 MRV are covering 12 districts according to NADRA.

22


In Sindh 13% of the female focus group respondents mentioned that some women were prevented by someone in the family from visiting a registration centre to recover their lost CNICs or other important documents.38 3.3.6 Complex, lengthy and costly procedures and lack of information involved in accessing the supporting civil documents required to apply for or update CNICs put many at a disadvantage, especially those in remote areas, illiterate persons, those with mobility issues and women. To apply for a CNIC for the first time or to verify supporting documents for changes to CNIC data a civil servant of the 17th grade needs to confirm the information in the application form which is not always possible, especially in rural areas.39 This civil servant also needs to be from the place of origin, and during displacement and after disruption caused by the disaster this is not always possible and often requires additional travels and costs In order to register as a new head of family after marriage, divorce or death the applicable marriage, divorce or death certificates are required. Accessing these documents and getting them verified again requires the added burden of more travel and costs, both official (cost of document and administration charges) and unofficial (travel, lost employment, overnight stays and bribes). For these reasons, and the lack of earlier incentive, many families had not registered as separate families on their CNICs prior to the floods, they had not registered marriage, births, and deaths, and therefore they were not included in the WATAN beneficiary list. This is reflected in registration statistics which documented families of more than 20 members, but also under‐ represented new births and children’s numbers.40 Families who had not updated their CNIC with new residential addresses were either excluded or they had to go through similar lengthy processes of verifying their change of address and appealing for inclusion in the WATAN scheme. In some cases, affected heads of family were still registered as an overseas resident although living in Pakistan and in order to reapply for a CNIC they needed to first pay large fees to cancel their current overseas NIC and then pay for the costs of re‐issuance of CNIC. 3.3.6 Costs involved in the issuance of a CNIC excluded and marginalized the poorest families. Irrespective of the fact that NADRA indicated that they would ensure the issuance of new CNICs or replacement CNICs free of charge for flood affected persons, this was not the case in some provinces: According to reports received by UNHCR in Sindh people reportedly had to pay a “fee” up to 1,000 PKR for processing the CNIC even during the fast track procedure

38

RPA Sindh See Oxfam‐GB WATAN card report, December 2010. 40 Again these records are being checked with NADRA to see if there were some clerical errors. 39

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In Punjab, NADRA charged 150 PKR for a duplicate CNIC.41 Supporting documentation (marriage, death and birth certificates) required to apply for or update CNICs also cost considerable amounts Required travel also cost money for transport, food and accommodation as well as lost income and lost time. 3.3.7 There was unequal access to CNIC registration and assistance for women and children. There are potentials for inequalities of access to assistance within polygamous households. Second wives have no legal rights to request equal distribution of money, while the children of first wives were reported to be often neglected. 3.3.8 Female headed households were at particular risk of exclusion from the WATAN scheme. Women are required to be registered on the CNIC of a male head of family; only when a woman is widowed or divorced is she able to register as a head of family. Culturally it is less acceptable for women to register as heads of family and they therefore usually register under another male family member as part of their household. The procedures for widowed or divorced women registering as heads of family is not well known or understood by the women, their families or the responsible authorities. There were cases when widows and divorcees were turned away by NADRA staff and told that they could not register. NADRA staff in Sindh/Punjab was not informed about the procedure regarding divorced women or were unwilling to implement it unless otherwise instructed by NADRA head office.42 To apply for widow status the woman needs to provide both the marriage and the death certificate, both of which require attestation by a 17th grade civil servant A death certificate is only available if the husband died in a hospital which is often not the case; if the husband died at home, the family normally does not get a death certificate43 Accessing the supporting documentation, marriage and death certificates or divorce papers is complex and requires official and unofficial costs. In Sindh, UNHCR received reports from women noting discriminatory behavior of NADRA and DCO staff when seeking assistance. 3.3.9 Unaccompanied/separated minors and child headed households were excluded from the WATAN scheme. CNIC card/registration is given only to Pakistani nationals 18 years or over. Therefore child‐ headed households would not be eligible to receive the WATAN card despite the common practice of early marriage across Pakistan, predominantly in rural areas. A total of 72,177 unaccompanied and separated children were reported from the flood affected areas.44 As a standard cultural practice, children who lost their parents/guardian 41

See “FAQ II Punjab” issued by IOM MC on January 2011; however, the same document states: “For those who have lost their cards during the floods or never had a National ID Card, the National Database and Registration Authority (NADRA) is providing free of cost duplicate identity cards (ID) cards and new cards (at minimal cost) to flood affected citizens to speed up government’s efforts for rehabilitation and relief.” 42 Divorced women in Punjab were informed that they had no right to a WATAN Card by virtue of being divorced. Although the information being received was not consistent for example in Kotri, the officials were aware that divorced women were eligible for assistance while in Thatta they were not. 43 UC authorities, i.e. the town committee could provide a death certificate after an application is made with evidence provided by the family; however, it is not known if and how often this procedure is actually applied in reality.

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are cared for by the extended families; however, some participants of RPAs raised concerns that these children might not be treated well and in some instances may be left out altogether from assistance if they were married and living as a separate family unit. 3.3.10 Inequitable Access to Registration and Assistance Based on NDMA’s initial estimates, approximately 20 million people were affected by the floods.45 However, only 1,637,717 households so far benefited from the WATAN card scheme (see table below) Table 1: Comparison between initial estimates and registration data46 Province

Balo.

KPK

Punjab

Sindh

P.A.K

GB

Other areas + untagged locations

Total

Percentage variation

-11%

-44%

8%

-57%

-3%

-8%

0%

-34%

Population Affected (NDMA)

700,000

3,800,000

6,000,000

7,274,250

200,000

100,000

0

18,074,250

Population Affected (Reg. data)

491,525

867,725

2,929,480

1,905,030

41,627

21,410

121

6,256,918


-30%

-77%

-51%

-74%

-79%

-79%

0%

-65%

Population Affected (Reg. data adj.)

461,565

1,014,562

3,228,748

2,174,127

44,899

22,094

45,060

6,991,055


-34%

-73%

-46%

-70%

-78%

-78%

0%

-61%

One may argue that the noted population did not pass the 40% threshold (of damages) to be eligible. However, this is unlikely when the districts declared by NDMA AS being severely affected alone have a population of more than 39 million persons (see Annex G). Families who had moved to flood affected areas, including conflict affected IDPs, and had not updated their addresses were often excluded, while families who had previously moved away from the flood affected areas but had never updated their addresses remained eligible to register for and receive WATAN assistance.47 Families living in villages located in the border of two provinces were often excluded, as neither province wanted to take responsibility.48

44

See “Profile of the IDPs from the Floods in 2010 in Pakistan” a report prepared by EBDM for UNHCR and GoP, TableA 7.17, p.91. 45 "The degree of severity to which people have been affected by the floods varies depending on their particular losses and damages. UN assessments have been launched in at least three provinces to identify severely affected families who require life‐saving humanitarian assistance. The UN experts have identified 2.7 million people in Khyber Pakhtunkhwa, 5.3 million in Punjab and over 6 million in Sindh that are affected. " http://pakresponse.info/factsandfigures.aspx quoting Source: NDMA, PDMAs, GBDMA. 46 Data taken from “Profile of the IDPs from the Floods in 2010 in Pakistan” a report prepared by EBDM for UNHCR and GoP, Table 1.2, p.4; with more information of the “registration data adjusted”. 47 This was observed during the real time evaluation of the Displacement Crisis in 2009, but is probably also valid for the flood situation as the situation remained the same; see: Cosgrave, John, Ploastro, Riccardo, Zafar, Farwa (2010), Inter‐Agency Real Time Evaluation (IA RTE) of the Humanitarian Response to Pakistan’s 2009 Displacement Crisis p.45. Commissioned by the Inter‐Agency Standing Committee; Final Report Version 1.959 August 2010. 48 This was reported in Punjab.

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There were reports of exclusion of minority communities, such as Christians and nomadic communities. As an example, in one district in KP, Christian families were identified as being left out of the WATAN scheme and the Government responded that they had no policy to deal with minority communities. Twenty six families were subsequently identified as eligible and included by the DCO. Refugees and persons without Pakistani citizenship were excluded from assistance and this included nomadic Hindu tribes, who at the date of the report are not recognized as citizens of Pakistan. According to the WATAN registration, many single member families were issued with WATAN cards despite the NADRA business rules that only families (married spouses and their children) were eligible to apply. 3.4 Grievance/Redressal System 3.4.1 In WATAN phase one many complaints are unresolved and pending. Based on the IOM call centre database, KP has the highest number of unresolved issues at 64% while the highest number of pending issues were reported in Sindh at 50%.49 In January 2011, UNHCR Sindh received information from the local NADRA offices that 25,000 complaints had been registered in Thatta alone and sent to the DCO office; similarly, Khairpur received 4,200 complaints. There are some 227,000 pending in Sindh, 15,000 pending in Balochistan and around 300,000 pending in KP. Approximate numbers are not available for Punjab, but some 3000 remain pending in the courts. 3.4.2 There were no standard or transparent criteria for receiving complaints or assessing their validity. Complaint procedures were not harmonized across provinces or even across districts. NADRA developed different criteria for receiving complaints in Sindh/Punjab and KP/Kashmir/GB and did not develop any for Balochistan. Balochistan set up its own redressal system without following NADRA SOPs; however, it is unclear which criteria they applied, if they had written SOPs and what they said. According to the NADRA/NDMA grievance system there is a possibility to indicate different rejection reasons than those which were given to him/her before he/she filed the complaint.50 The NADRA SOPs do not explain/define the various rejection causes, and thus Government staff are put in a position where they have to make decisions without standard guidance or procedures and this can lead to allegations of arbitrariness, discrimination, and corruption and undermines the credibility of the system. 3.4.3 There were restrictions and confusion on the types of complaints that were being accepted and processed Official NADRA complaints criteria only addressed CNIC problems; in KP they were completely limited to incorrect or lost CNICs. This did not encourage complainants to lodge grievances related to inclusion of locations or families on notified lists, to lodge complaints 49

The database tracked 389 calls regarding WATAN card complaints between mid January to mid March 2011. See above p. 7.

50

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about alleged extortion or corruption, to lodge complaints related to exclusion for other reasons or to lodge complaints related to accessing the money at the bank. According to information received from NADRA, the complaints which were registered through the complaints data base included: (i) name is not in the list; (ii) received card but funds are not credited in the account; (iii) lost my card; (iv) PIN number lost; (v) where can I get card? This does not correspond with the list of rejection causes established through the SOPs by NADRA and it is therefore not clear whether standard response/referral was developed for these cases. 3.4.4 Lack of standardization, transparency and information sharing related to grievance submission deadlines Cut‐off dates for submission of grievances were set by the PDMAs without prior warning to beneficiaries and no clear communication was sent to the district authorities Sindh closed all new registration and the verification of pending complaints as of 15 March 2011 and then subsequently re‐opened the grievance procedure with a new deadline of 15 April which was once again extended. In Sindh, DCOs from the districts Kashmore, Ghotki, Qambar, Larkana claim not to have been informed about this decision.51 Punjab stopped any new registration and/or verification of pending complaints as of 15 December 2010 and claimed that only complaints that were filed in the court would be considered. Filing complaints in court is costly for the complainant, does not ensure a positive response and is also not in the public interest. 3.5 Release of Payments 3.5.1 Difficulty in using the ATM machine Lack of information at the ATM on how to use it. ATM operated in Urdu/English rather than local language which made it difficult even for literate people to follow instruction on screen. In the district of Thatta/Sindh, 35% of people surveyed indicated that they did not know how to use the machine.52 In Northern Sindh, 44% of people surveyed reported to have experienced difficulties using the ATM.53 When people did not know how to use the ATMs, they often turned to middle men who allegedly extorted or stole money from them. 3.5.2 Costs and complaints of extortion when using ATM points An NGO in Sukker reported that women confirmed that they had to pay up to 5000 rupees to a middle man to receive cash on their WATAN Cards During the household survey in Sindh 8% of the respondents stated that bank guards asked for a fee, and 6% of respondents stated that “someone else” (very often a bank official) requested a fee. Amounts of these fees ranged from PKR 500 ‐ PKR 5000. According to reports received during UNHCR monitoring missions in Punjab, people reportedly paid for assistance to receive the cash.. 51

Information provided upon request to IOM MC coordinators in Sindh after PDMA Notification was published. Village profiling data from UNHCR/PDMA carried out by NCHD covering 1,800 villages through, to be published shortly 53 Household survey on WATAN cards, Northern Sind, January 2011 52

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3.5.3 Restricted access to the ATM machines, especially for those in remote locations, the poorer sections of society, women, single headed households and the less able bodied. Coverage of ATMs especially in rural areas is not sufficient. As an example, in Northern Sindh, there are only ATMs available in 4 districts: Shikarpur, Sukker, Khairpur, Qamber Shahdadkot. It was hard for those in remote locations to travel the long distances to the ATM machine. In Northern Sindh, the nearest average distance to the ATM was reported to be 30 km; travel costs for public transport covering this distance is approximately PKR 50 one way.54 3.5.4 Technical problems led to multiple journeys and the costs associated with that, as well as difficulties in accessing assistance and drawn out investigations. Around 15,000 households in KPK were unable to activate their card because of technical reasons with the NADRA’s database – e.g. in some cases, problems with fingerprints not matching or parentage issues were reported55 In Sindh, it was reported that the PIN sometimes did not work 79% in Northern Sindh claimed to have not received the full amount of 20,000 rupees.56 17% of complaints related to WATAN cards received at the IOM call centre indicated that “they have not received the WATAN card” or “the amount not received”.57 3.5.5 Lack of available money in participating banks In KPK after complaints were filed by some beneficiaries with the support of the Directorate of Social Welfare, the Women Development and the Welfare Centre that there was no money in their account, it became clear that someone already withdrew the money from those accounts. The Chief Minister ordered an inquiry into the matter. NAB authorities along with PDMA came in and finally the bank authorities admitted their fault and released the WATAN card payment to 24 families. In Sindh, families who have received the WATAN card after going through the appeals process are finding that there is no money available in the banks.

54

Household survey on WATAN cards, Northern Sind, January 2011 Daily Dawn newspaper, Nov 22, 2010 56 RPA Sindh 57 The data base tracked 389 calls regarding WATAN card complaints between mid‐January to mid March 2011. 55

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Part 4: Recommendations for Phase I, II and beyond WATAN The recommendations are based on the protection concerns outlined above and are linked to thematic topics and the respective phase to which they apply, i.e. Phase I, Phase II and beyond WATAN. The responsibility to implement each recommendation is based on the current institutional arrangements (see Annex A). It is acknowledged that several actors are involved in the overall process and that it is challenging to ensure that a coordinated response is provided. Nevertheless, there are concrete steps which can be realistically implemented to improve the overall quality of the cash compensation scheme from a protection point of view. It should be highlighted that additional time and effort invested in the ongoing process will facilitate any future roll‐out of such cash compensation schemes as SOPs, mechanisms and lessons learned will already be in place.58 4.1 PHASE I Grievances The PDMAs in Punjab and Sindh have closed the registration of WATAN cards and verification of pending complaints on 15 December 2010 and Sindh has changed the deadline at least twice, from a protection point of view it is regrettable that this decision was taken without prior broader consultation or respective information sharing among the concerned communities. To NADRA: For remaining grievances across the provinces, establish clear and standardized criteria for verification and referral support. Clearly communicate to beneficiaries the remedial procedure and the current situation regarding their pending grievances. Establish a list of those households which are flood affected according to the Revenue Departments/NADRA’s lists, but have not yet received the WATAN cards; analyze the lists and establish locations where large numbers are excluded. Target these households through information campaign and send mobile registration vans if necessary to the respective areas. Ensure that there is money available for each WATAN card issued. Identify households left out of phase I that fall into the phase II criteria and work with PDMA and the Cabinet Division to ensure their inclusion in Phase II. To Revenue Department: Entrust third party/neutral entity with assessment on which areas are flood affected in the other provinces, but not listed with NADRA yet and include them in the list for NADRA. 58

The World Bank after a high‐level mission to review the existing WATAN card program provided several recommendations which formed part of a joint MoU between the GoP and the World Bank; the MoU recommendations are attached as Annex F.

29


Government/Banks Ensure that money is available for all WATAN Cards issued 4.2 PHASE II When this report was drafted, the information available on the eligibility criteria and procedure to be put in place for the second instalment had not been finalised. The information available states that the second phase will be issued based on house damage to household heads (rather than families) and will include payment in two instalments. It was also suggested that female headed and disabled headed households would be included regardless of house damage. In case the procedure changes, the recommendations remain valid for any future cash scheme regardless of eligibility criteria. To NADRA: Use its technical expertise to provide a detailed operational manual for each step of the whole process which provides clear guidance to all staff involved in the WATAN scheme. Solicit inputs from mandated protection organizations and finally make this document publicly available to ensure transparency. 4.3 Information Dissemination To PDMAs/DCO/NADRA:59 Training should take place for all DCO and NADRA staff on the eligibility criteria, the grievance procedures and the importance of clear and transparent communication with beneficiaries. Relevant information needs to be communicated to the population in a timely manner (e.g. if a cut‐off date is decided this needs to be communicated early enough for people to react including an update of the consequences of such an action).60 Eligibility criteria for the second installment need to be clearly defined and informed to the affected populations. When designing the next mass communications strategy the use of community organizations and outreach groups/persons should be factored in to ensure illiterate and those excluded from mass communication (e.g. mostly women) are reached. Loudspeaker announcement in public places such as markets and through mosques should be integral part of any information campaign. The information should explain the importance of possessing a CNIC, not only for the current scheme, but for future assistance and encourage people to access civil documentation (e.g. birth certificates/CNIC) regardless of the WATAN scheme During each stage of the process, such as household surveys, information campaigns, registration points etc. information on accessing civil documentation should be distributed with clear referrals to NADRA’s registration points. This should include information on the 59

The mass information campaign was substantially supported by IOM MC; it will be seen if they or another actor will continue to support the GoP in their efforts to reach out to the communities. 60 When needs are particularly severe, people are likely to spend cash on basic essentials such as food items. Where large debts are a source of livelihood stress, cash grants have been used to pay them off; see Harvey, Paul. Cash‐ based responses in emergencies. HPG report 24 January 2007 p.37.

30


importance and the procedure of how to get a CNIC; this can be done through simple low cost leaflets which use pictures rather than text to reach the illiterate part of the community. ‐> BISP through Pakistan Poverty Alleviation Fund (PPAF) has currently 91 partner organisations across the country and a grassroots network of over 249,000 community organisations and groups which can be utilised to disseminate information on cash schemes/WATAN cards second instalment61 ‐> IOM’s mass communication programme and UNHCR implementing partners and other NGOs can support transparent and timely communication with affected populations.

i. ii. iii. iv. v. vi.

4.4 Identification of Eligible Households To NADRA Clearly define and disseminate information among Government staff and affected populations on: what a household is, and who is the head of household (recipient). what extent of damage is required to receive second phase payments. how to respond to households who have used their own money/assets/loans and debt to rebuild houses. what are the vulnerability criteria being used and how will this be verified. who will be carrying out the household and vulnerability assessments. how an appeal can be made. Ensure inclusion of locations which were left out in Phase II. Ensure that the identification of beneficiaries is monitored. Available assistance IOM’s mass communication programme and UNHCR implementing partners and other NGOs can support transparent and timely communication with affected populations. 4.5 Registration/Verification Process To NADRA: Provide separate waiting and queuing areas for women and ensure that persons with specific needs, such as persons with disabilities, older persons, pregnant women, and women with infants, are prioritized in queues and assisted first.

61

BISP has to date over 3 million families (all female heads of household) registered as the poorest of the poor in NADRA’s database. It is currently conducting, using Pakistan Poverty Alleviation Fund Organization (PPAF) and NRSP, house to house poverty surveys that will eventually cover the whole of Pakistan with GPRS linked data. BISP claim that they will have approximately 25 million families registered in their database at the end of the survey. From this they identify the poorest of the poor, using the information collected in the poverty survey. By June 2011 BISP hope to have 5 million beneficiaries registered. Each of the beneficiaries (families) is given PKR 1,000 per month. According to BISP, after the floods just over 1 million BISP beneficiaries (families) were affected by the floods. What BISP was able to do for its flood‐affected families was to give them PKR 4,000 as a one off cash compensation payment.

31


Increase number of mobile registration vans and ensure that they are equipped to the extent possible with all technical features of the NADRA centres including civil documentation advice and support and the ability to access NADRA databases. Hire female staff as part of the registration team to allow/encourage women to register. Waive fees for issuance of new/lost CNIC and communicate this clearly to all partners involved at provincial/district level. Cross‐check the BISP database with the NADRA database to ensure that at least those vulnerable female headed households in the BISP database affected by the floods will receive the first and/or second installment.62 Clarify beforehand and communicate accordingly if the second installment is time‐bound, i.e. if there will be a cut‐off date for “registration/withdrawal of funds.” Monitor the registration process to ensure that access is equitable and that procedures are being followed. At registration/verification points provide clear information on eligibility criteria in verbal and written form. Establish systematic mechanisms to monitor and respond to reports of extortion or corruption. Available assistance UNHCR implementing partners, IRC and other NGOs can provide support in identifying and prioritizing the most vulnerable and monitoring registration/verification points for extortion or corruption concerns. Staff can also support those seeking information on appeals procedures, access to documentation issues and can refer to other service providers where appropriate. 4.6 Grievance Procedure To DCOs: Deploy additional staff based at the NADRA registration centres and grievance redressal. Centres, including particularly female staff who can deal with complaints directly on the spot and give appropriate advice. Ensure that all staff understand the appeals process and do not turn people away without clear information on the reason for rejection. Ensure available written, pictorial and verbal advice available on the procedures and eligibility criteria for obtaining phase II assistance and the appeals process. To Donors: Provide financial support for the deployment of additional staff at NADRA registration/ verification centres and grievance centres. Provide financial support for the roll‐out of training on SOPs and the Operational Manual for Government, NGO and IOM staff. Ensure compliance with transparency, equity and proactive inclusion of the most vulnerable. 62

The BISP has already provided some cash to flood affected families: Balochistan: 38,627, Punjab: 344,845, KPK: 379,480 and in Sindh: 248,408.

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To NADRA: Open Grievance centres in easily accessible locations and advertise them widely among the affected populations. Set up clear SoPs for each step of the appeals process and identify a third party to monitor the implementation of the appeals procedure. Ensure that the grievance procedure deals with a multitude of possible grievances from civil documentation support, assessment irregularities, inclusion on notified lists, corruption, political manipulation, family disputes, access to ATMs, technical problems at the bank etc. Establish a standard Government redressal system to deal with complaints of corruption, extortion or coercion. Disseminate information on the appeals process among affected communities. Establish a simple system to support those having problems accessing their CNICs and connect this to support in accessing other civil documentation requirements – birth, death, marriage etc. Train DCO and NADRA staff as well as NGO information/advisory service providers and IOM staff on the appeals procedures. Helpline staff need to be well trained to answer inquiries competently and should be able to speak the local language. Ideally, quality control is done by randomly monitoring calls (e.g. similar to commercial call centres). Link up the IOM Call Centres with the NADRA Help lines data bases and track complaints systematically.63 Develop guidelines on best practice for identifying eligible families not included in Phase II and linking them to agriculture or shelter assistance. If the Government agrees, a list of eligible beneficiaries left out of WATAN for various reasons can be established and made available to other sectors to include within their beneficiary selection criteria, not as a sole eligibility criteria, but one among many. To UNHCR: Design standardized WATAN card monitoring format to be distributed widely and compile information gathered by all partners for overall analysis and lessons learned. Available assistance UNHCR and the protection cluster/thematic group can provide technical assistance on transparency and accountability at the federal, provincial, and local levels through capacity building, communication, and public information, monitoring and evaluation as well as provision of advisory services for beneficiaries IOM, IRC, and UNHCR are establishing a list of common complaints and a referral mechanism and database to deal with the concerns. This information could be used to support the design of the appeals process and could work closely together with the Government to ensure that targets of inclusion and transparency are met. IOM will have staff available to assist at several DCO offices and a help line established to manage grievances (WATAN as well as other grievances related to access to humanitarian assistance)

63

Efforts are currently ongoing between IOM MC and NADRA to set up a MoU which outlines the link up of both data bases for the call centres.

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UNHCR implementing partners (IPs ), IRC and IOM staff could be trained to ensure that there is a common understanding of the eligibility criteria and the appeals process to help reduce false complaints/ineligible cases and facilitate the processing of eligible cases. UNHCR and IRC are running social welfare centres and citizen’s advice bureaux to support documentation assistance and give advice to affected populations. These could be used as referral pathways for complaints that are not WATAN related or cannot be resolved without individual case support. IOM can produce pictorial and written information for DCO offices, grievance centres as well as running radio campaigns to reach a wider audience. 4.7 Release of Payment NADRA/Donors Ensure that non‐participating banks agree to waive fees for WATAN card holders. Banks should be held accountable to ensure that ATMs are functioning and that money is available. The Government should ensure that money is transferred to the banks in a timely fashion. Release of money should not be restricted to within a certain time frame. Banks should be monitored to reduce the chances of corruption and extortion at the point of cash withdrawal. To the participating banking consortium: More ATM points or Cash Points should be established to reduce the travel distance. These should be well publicised and should be reliable. Print pictorial charts explaining how to use ATM machines and display them next to ATMs and also at registration/verification centres to facilitate usage. Agree contractually that no fees are deducted for usage of non‐participating bank ATMs. WATAN cards which have been confiscated due to entering the wrong PIN code should be kept at the local bank and not sent back to the issuing branch64 in order to avoid several journeys for the beneficiary. Banks should ensure that ATMs are functioning and that money is available. Banks should be responsible for ensuring that middlemen, security personnel, and bank staff do not take bribes or payments for support in accessing the WATAN money. Available Assistance IOM can support with the creation and distribution of information messages at the ATMs and in Government offices.

64

For normal bank cards the card is simply secured by the local bank branch when the PIN is entered wrongly and not sent to the issuing branch; so this should be easily feasible for WATAN cards as well.

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4.8 Reporting/Monitoring/Analysis To NADRA/PDMA: Data on those applicants which have been rejected at the registration centres should be made available to the protection cluster65 for analysis (disaggregated by age/gender/cause) to provide the basis for improving the information campaign and designing the SoPs (dealing with the second installment). Consider potential use of the registration database after the WATAN card scheme is completed. Carry out spot checks and monitoring at every level of interaction between government staff and beneficiaries. To Donors: Assess the impact of providing cash instead of in‐kind assistance (e.g. what people did with the money, how it affected local communities, what people intend to spend the second installment on etc). Assess inclusion and exclusion concerns through analysis of the grievances procedure and spot checks. Available Assistance The protection cluster members will be able to assist the Government in highlighting and analyzing trends and using the information to develop robust cash compensation procedures for future emergencies 65

As of 31 January 2011 the emergency phase was declared by the Government to be over and thus, the former cluster system was transformed; the protection cluster has transitioned in the early recovery set up and continues working as Protection Thematic Working Group.

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Part 5: Conclusion: Beyond WATAN The cash compensation scheme is an innovative way to quickly provide large numbers of affected persons with relief assistance in emergencies, for example when the emergency shelter cluster had provided overall 840,000 households with emergency shelter66, the WATAN scheme had already reached 1.53 million households. In addition, based on past experience, beneficiaries indicated that they would prefer cash schemes over in‐kind assistance in areas where there was access to a functioning market.67 In order to support the quickest delivery time possible it is therefore recommended, similarly to the BISP, to already have a system in place through which money can be distributed. The BISP was able to deliver immediately cash assistance to its beneficiaries, while the set up of the WATAN card scheme took from the onset of the crisis in July 2010 to September/October to distribute the cash cards to the population (see table below). Table 1 Registration period by province68 Province of registration Balochistan KPK Punjab Sindh ICT, AJK and GB

9,035 11,134 423,732 326,562

11.43 67.06 77.24 77.99

6,302 146,743 95,871 50,776

7.97 88.38 17.47 12.12

41,551 3,918 19,136 25,025

1,627

15.42

2,375

22.52

Pakistan

772,090

63.13%

302,067

24.70%

Sep

Sept %

Oct

Oct %

Nov

Nov%

Dec

Dec%

Total

52.5 2.35 3.48 5.97

22,156 4,229 9,843 16,349

28.02 2.54 1.79 3.90

79,044 166,024 548,582 418,712

3,504

33.22

3,040

28.82

10,546

93,134

7.61%

55,617

4.54%

1,222,908

It is clear that for a disaster of such a scale it is not possible to provide everyone with assistance, especially not with cash assistance. It would therefore be worthwhile considering the possibility of using the BISP for any future emergency cash compensation scheme. BISP envisages that they will have approximately 25 million families registered in their database at the end of their survey. The database will provide information on the most vulnerable in Pakistan which would be an ideal entry point for targeted (cash) assistance. Another aspect should be taken into consideration when designing future cash compensation scheme: the amount of money to be issued with one installment should not be too high to induce further displacement, i.e. the most vulnerable might be inclined to leave their village (temporarily) because of the amount of money offered to IDPs. This reasoning already in 2009 during the IDP crisis led to the disbursement of 5 installments every month of “only” 5,000 PKR instead of one installment of a higher amount. Indeed, 35% of respondents in Northern Sindh said that “if the ATM were closer, I would have preferred to withdraw the money in two or three visits, instead of all at once.”69

66

See Pakistan Shelter cluster website www. Shelterpak2010. See e.g. IA RTE 2009 IDP crisis, p. 42. 68 Data taken from the “Profile of the IDPs from the Floods in 2010 in Pakistan” a report prepared by EBDM for UNHCR and GoP, Table 1.1, p.3. 69 Household survey on WATAN cards, Northern Sindh, January 2011 67

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Annex A: Institutional Arrangements A. The institutional arrangement for the implementation of the program

B. Responsibilities of the official stakeholders Agency Role Council of Common Interest, CCI Policy Decisions National Oversight Disaster Management Oversight and Audits Council, NODMC Cabinet Division Management of Funds, Reconciliation with Banks National Disaster Management Authority, Coordination with Provinces NDMA NADRA Registration, data management, case management of enrollment (grievances for CNIC) Associated Banks Beneficiary payments incl. case management (grievances for payment Provincial Governments, PDMAs etc. Notification of calamity hit areas, logistics for enrollment, public information, case management Local Government, DCOs etc. Public Information, case management (grevances etc.)

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1) a) b) c) 2) a) b) c) 3) a) b) c) d)

4) a) b) c) d) e)

Cabinet Office Preparation of policy decisions for NODMC Management of funds Selection of Partner Bank/Financial Institution Provincial Governments/PDMAs Issue of notification of flood affected areas/Union Councils to NADRA Selection and setting up of enrollment sites Mobilization of flood affectees to the sites and running of the local information campaign NADRA Consolidation of registered population list after verification as per notified calamity hit Union Councils On‐site biometrics verification of data through NADRA’s database Intimation of verified lists to Partner Bank, NDMA and PDMA Assist in provision of CNIC (new or lost) and update of family tree information to those potential beneficiaries who need to. Partner Bank/Payment Delivery Agency Opening of virtual accounts and issuance of WATAN Cards to the beneficiaries Provision of On‐site cash withdrawal facility (PoS machines) Activation of cards verified by NADRA Replacement of lost WATAN Cards to applicants Maintaining a helpline for complaints related to payments.

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Annex B: Application Process

39


Annex C: Registration Form

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Annex D: Best Practices Many good practices by the authorities were used and observed during the monitoring of the registration process. In the following these are outlined briefly. It should be acknowledged that there might be other good practices and the list provided is not meant to be exhaustive. The examples given are those which were brought to the attention of the protection cluster. Sindh: Pictorial charts were used to explain usage of ATM to people. Protection cluster set up a WATAN card WG to address protection issues jointly. NGOs when implementing their activities also collected information on those excluded from the scheme. Help Centres run by SHARP provided assistance for individual cases to get required documents and/or WATAN cards. Protection cluster organized a household survey on WATAN card issues covering five districts in Northern Sindh. In Dadu the DCO set up a center to redress complaints, with three categories: (i) Those that have approached WATAN card centers but the cases has not been recommended or forwarded to the DCO, (ii) All ABC category cases forwarded to him, (iii) Those that have received cards, but the no amount has been disbursed; unfortunately the center only functioned for one week as the process was closed. Punjab: With issuance of WATAN card, information on which bank to use was provided. In some centers preference was given to women, older persons and others with specific needs. Mobile registration vans were used including a mobile ATM. Balochistan: A desk specifically for women and run by women was set up. NADRA in Balochistan developed a Union Council level registration plan and are planning to visit all the Union Councils where there are reports of people without the CNIC card in order to register them. UNHCR coordinated with NADRA at provincial as well as district level through the field staff by reporting all cases of people without a CNIC. NADRA has six MRVs (four in Jafarabad, one in Nasirabad, one in Sibi) registering affected without CNIC; each MRV registered 50‐55 persons a day. Islamabad: Gender Task Force invited NADRA to their meeting to discuss issues on the WATAN card. UNHCR designed a separate registration form which was included as part of the registration process for the WATAN card with the purpose of getting timely updates on number of affected and displaced persons, disaggregated by age and sex, their location and type of housing, key humanitarian needs and key protection concerns from the process itself; the data collected is part of a comprehensive report which will be published alongside this report.

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After the earthquake in 2005, newspapers advertisements and local publicity solutions were devised and low cost pamphlets and handouts were published and distributed across the affected areas; community based publicity approaches, where mosques and local people were used to disseminate information about the right of applicants to appeal against ineligibility decisions through the grievance procedure worked well.

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Annex E: World Bank MOU with the Government 70

i)

ii) iii)

iv)

v) vi) vii) viii)

At the request of the Government, the World Bank fielded a high‐level mission to review the existing program. The Mission found the basic framework of the existing program to be reasonable but made specific recommendation. Based on the findings of the World Banks mission, the Government indicated its intention to adopt the following measures to strengthen the cash assistance programme: Adopt the principle of improving the targeting of planned additional payment (based on an analysis of existing data to establish objective eligibility criteria); also maintain flexibility to consider adjusting the payment amount based on beneficiary needs and fiscal space; Clarify the roles and financing by federal and provincial levels; and build ownership at both levels, besides managing the size of eligible beneficiary lists; Disburse these un‐conditional payment (s) in instalments to manage cash flows to better help the involved institutions and individuals cope with security, to better manage utilization of funds by beneficiaries, and permit adjustments based on program assessments; Strengthen grievance redressal mechanisms and institute a robust public information campaign to mitigate the risk of exclusion of eligible beneficiaries and inclusion of non‐flood affected areas; develop data sharing protocols between provinces and NADRA for recording grievances and their disposal; Deploy robust monitoring systems, such as third party verification and beneficiary assessments, and public disclosure of program performance to increase public confidence Complete tripartite (federal, provincial, and partner commercial banks) formal contract with payment agencies, and ensure appropriate verification of beneficiaries for further instalments; Strengthen governance of the program by developing procedures for curbing misuse of authority by officials and misreporting by participants; and Develop advisory services for the poor to assist in responsible utilization of funds. It is important that the World Bank follows up on these measures as they would be useful for future cash schemes.

70

Taken from the “Memorandum of Understanding on Cash Transfers” between the GoP and the World Bank, signed on November 26, 2010.

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Annex F: Protection Response to Reported Protection Concerns During the registration process the protection cluster and its members had been very active in its responses to the various protection issues that have been identified. They provided technical advice on the overall procedure, advocated for the issuance and modification of the CNIC as well as the inclusion of individuals and villages to access the scheme. Through regular meetings at provincial as well as federal level problems observed by partners on the ground were reported to the relevant authorities. The authorities as outlined below have often favourably responded to this information and several improvements were achieved in the provinces. As of 24 January 2011 (according to NADRA) approximately 300,000 new cards have been issued to people for the first time and approximately 113,000 duplicated cards have been given to people who had lost them during the floods. UNHCR with its five field offices71 and other international NGOs, including IRC, were able to visit the different registration centres in all four provinces as well as regularly visiting the DCO offices and redressal desk to support the complainants. While the presence itself was used to reduce levels of corruption, discrimination and extortion, the findings were used to actively engage in advocacy for inclusion and provided technical advice to improve the overall procedure. However, due to either security constraints or lack of manpower it was impossible to cover all registration centres all the time. In Multan, UNHCR identified and verified 9 villages in the district of Muzaffargarh and 39 villages in the District of Layya as not being listed as flood affected for the distribution of the WATAN Card. With this information the office approached PDMA who immediately responded by looking into the situation. PDMA also agreed to facilitate the status change, as a priority, for widowed females left out of the process. Fifty‐three mozas were identified by the field staff as being excluded from the affected village list. This was followed up by physical verification and advocacy with PDMA for inclusion. In Sindh, mass information campaigns were set up in northern Sindh in October 2010, a WATAN working group was initiated specifically to address protection issues identified with local authorities. In addition, UNHCR, IRC and SHARP72 worked together (through the legal centers) to identify and follow up on individual and group cases, to have them included into the scheme and to continuously monitor the registration centers. In KPK protection partners identified 217 families living in a camp that were eligible for the WATAN Card and advocated for the families to receive them. The office also ensured that separate desks for female headed households were established and were run by female staff, information desks were established at centers to provide guidance and encouraged NADRA to 71

Two field offices in Sindh (Sukker and Hyderabad), one field office in Punjab (Multan), one sub office in KPK (Peshawar) and one sub office in Balochistan (Quetta) 72 From January to February alone the UNHCR/SHARP legal centres in Sindh resulted in 105 persons benefiting from the issuance of WATAN cards and 1162 from the replacement of documents.

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involve DCO office for disseminating information of pending cases to affected families. UNHCR staff worked with the Bank officials to increase staffing levels where required. IRC met with the DCO and bank focal person in Charsadda to organize provision of a separate room for females at the ATM Hub. In Balochistan, it was found that 300 families who received a WATAN card had no money in the bank. UNHCR followed up with the bank and NADRA and it was later established that there was a technical error in NADRA’s database. NADRA also developed a Union Council level registration plan and plan to visit all the Union Councils where it was reported that people don’t have a CNIC card to register them. UNHCR coordinated with NADRA at provincial as well as district level through the field staff. UNHCR, with the field staff along with its partners CRS and BRSP continue to coordinate with NADRA on the ground in disseminating information on the registration scheme. Through different meetings with the World Bank and the production of an advocacy paper laying out specific recommendations, the protection cluster was able to provide updates on the concerns from the field and thus allow the World Bank to proactively engage with NADRA on protection issues. IOM stepped up its communication efforts on the WATAN scheme through: (i) TV (televised infomercials) (ii) providing WATAN‐specific awareness sessions through field staff, (iii) deploying Information Officers to DCOs' offices to provide information on the complaints procedure, (iv) information officers mobilizing and arranging information sessions based on radio programs, and (v) provide training to NADRA's staff at national help lines, provincial and district level officers, DCOs' support staff.

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Annex G: List of Flood-Affected Districts: Source: NDMA - January 2011 73

Neelum

Severe

Total population

10 Balochistan

Jaffarabad

Severe

495,301

17 Balochistan

Nasirabad

Severe

281,396

31 Kyber Pakhtunkhwa

Charsadda

Severe

1'424'408

S. No.

Province

6 AJK

District 74

Affected Status


D. I. Khan

Severe

1,188,432


Kohistan

Severe

658,415


Lower Dir

Severe

999,684


Nowshera

Severe

1,218,222


Peshawar

Severe

2,823,914


Shangla

Severe

605,464


Swat

Severe

1, 752,155


Tank

Severe

331,893


Upper Dir

Severe

802,317

51 Punjab

Bhakkar

Severe

1,420,208

52 Punjab

D. G. Khan

Severe

2,219,373

55 Punjab

Layyah

Severe

1,514,073

56 Punjab

Mianwali

Severe

1,427,181

58 Punjab

Muzaffargarh

Severe

3,560,329

59 Punjab

Rahim Yar Khan

Severe

4,242,641

60 Punjab

Rajanpur

Severe

1,490,665

62 Sindh

Dadu

Severe

2,231,448

63 Sindh

Ghotki

Severe

1,282,392

65 Sindh

Jacobabad

Severe

1,883,623

66 Sindh

Jamshoro

Severe

67 Sindh

Kashmore

Severe

69 Sindh

Larkana

Severe

2,546,257

72 Sindh

Qambar Shahdadkot

Severe

74 Sindh

Shikarpur

Severe

1,163,329

78 Sindh

Thatta

Severe

1,470,875

Total

39,033,995

73

This table is a combination of the information found at the www.pakresponse.info website under “facts and figures” base line data of population and flood affected areas. 74 For those columns which are empty there was no information on population figures in the database.

46