Privacy Impact Assessment of UNHCR Cash Based Interventions

In 2014, the Office of the United Nations High Commissioner for Refugees (UNHCR) commissioned Trilateral Research & Consulting to conduct Privacy Impact Assessments (PIAs) of two of its Cash-Based Interventions (CBIs) in middle-income countries.

The purpose of the PIAs was to help UNHCR assess the specific data protection and privacy risks arising from the collection, processing, storage and sharing of personally identifiable information (PII)2 relating to refugees and other persons of concern by country operations and its transfer to partners involved in the implementation of CBIs.

The complexity of large-scale CBIs has brought data protection and privacy issues to the forefront of UNHCR operations. These PIAs are among various initiatives by UNHCR to enhance beneficiary privacy, including the recent adoption of a global data protection policy. This report presents the findings of the PIAs of CBIs in the two UNHCR country operations.

The report also highlights key issues related to data protection that go beyond CBIs and are equally relevant to in-kind assistance, and need to be addressed globally. Since cash assistance involves multiple actors and stakeholders, many of the report’s recommendations will be relevant to other humanitarian actors with CBIs or similar assistance programmes. However, it should be noted that country-level findings may not be applicable to CBIs in other UNHCR operations.