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New protocols for Personally Identifiable Information

January 25, 2023
February 6, 2023

During the roll out of Loop, as part of the Ukraine Response, we have been very sensitive to the issue of how much Personally Identifiable Information we should share on the Loop open platform.

Should an individual who gives positive feedback about an organisation on the platform, and who uses their first and last names, have those names made public along with their comments? 

Should we post the first name and city of residence of a woman with six children who has chosen to share that information when providing feedback about the accommodation she is provided? And does the decision change if she also asks for additional support?  

Many users from Ukraine are also posting on Facebook, Telegram and Twitter about their views, opinions and concerns. Through these broader non humanitarian specific tools anyone seeing their comments can contact them directly, without any moderation or safety mechanisms.

Compare this scenario with sector-wide best practice, which is very much reinforced by UNHCR policies to ensure no Personally Identifiable Information is available on an open platform. 

With all these aspects of the issue front of mind, we decided to talk to local people who were using Loop, to ask for their views and perspectives. 

We interviewed Ukrainians currently living in Poland, who were strongly of the opinion that their voices should be heard; and that putting a name to the information is important as it personalises the feedback, and helps readers to better understand and empathise with their experiences and views. 

They referred to the #metoo movement as being powerful exactly because people made themselves vulnerable, but also more relatable, by self-identifying. They wondered if we were being too protective or paternalistic by deciding what should be posted or not.  Importantly, they felt themselves to be sufficiently educated and informed to be able to decide for themselves.

However, in another setting the results of our enquiries were different. When we asked people in Zambia and Somalia the same questions, they felt that they would feel less safe attributing their name to the feedback and, if they made a mistake, would rather have this information edited in some form. They felt more uncertain about the internet and who has access to it and to their information. They felt more vulnerable to possible misuse of their feedback.

Considering this learning from users of Loop about the topic of Personally Identifiable Information, we then consulted, through a few learning sessions with our Moderators, Case Managers and Designers, considering the implications of editing stories, or redacting information. 

We wanted to maintain the right balance between ensuring the integrity of the stories that people choose to share, and wanting to make sure that there is no risk of us changing the meaning or subtleties of the text in any way. 

We saw areas where understanding in translation is sacrificed due to acronyms, spelling mistakes or other small elements of a story. 

We also did not want to push too much non-sensitive feedback to the Sensitive Feedback page of the Loop platform, when in fact many pieces of feedback are only sensitive due to the information the author has chosen to share. 

We want to make sure that every voice counts in a meaningful way: if feedback is tagged as sensitive when it is in fact gratitude and thanks, then the value is being lost, even if the organisation mentioned in the feedback is informed directly.

As a result of our investigations we have reprioritised some budget to design and deliver a speedy fix, enabling editing of the feedback, according to strict, but country-specific Operating Procedures about what can and cannot be edited.  

We have designed the moderation to have two versions of stories:

First, the original text, to safeguard the integrity of the original feedback as a reference and quality control on editing. This feedback stays on the moderator’s page and is not open on the public platform to see. 

Second, a copy of the feedback can be edited multiple times, according to the Protocols for each country's context. This version is what the general public can see on the open platform.

We are excited to now have implemented these changes to the platform and our protocols. We believe it will help to improve the data on the platform, whilst ensuring that people's voices are heard safely, and at the same time maintain the integrity of each person's contribution and the value of the aggregate data.

The improved protocols on the Loop platform have country specific elements based on risks: so in Ukraine we only publish first names, and we do not publish surnames or location data; whilst in Zambia and Somalia we will only use one name, either first name or surname but not both, and only if the author chooses to share it. 

All phone numbers and addresses will be removed from posts and replaced with XXX. 

Sensitive Stories will continue to be entirely confidential and protected. 

We are excited about this improved functionality on the Loop platform and how it will help to keep people safe, respect their choices and deliver valuable statistical information. We are proud of how our global platform can integrate country specific adaptations respecting local realities and preferences. 

Over the coming months we will clean the data that came into Loop prior to this functionality being introduced.

If you have any further recommendations on how to improve the Loop platform we look forward to hearing from you and continuing to improve as we learn.

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