THE MISCONDUCT DISCLOSURE SCHEME
The Inter-Agency Scheme for the Disclosure of Safeguarding-related Misconduct in Recruitment Process within the Humanitarian and Development Sector
The Scheme
The Inter-Agency Scheme for the Disclosure of Safeguarding-related Misconduct in Recruitment Process within the Humanitarian and Development Sector, or Misconduct Disclosure Scheme for short, establishes a minimum standard for organisations to share information as part of their recruitment process about people who have been found to have committed sexual abuse, sexual exploitation or sexual harassment “Misconduct” during employment. It complements the work that organisations are already doing as part of their recruitment processes.
This scheme ensures that all organisations who sign up to it work to a common minimum exchange of relevant sensitive information, while respecting applicable legal and regulatory requirements. By so doing it contributes to organisations’ work to prevent and address the consequences of sexual harassment and sexual exploitation and abuse in the humanitarian and development sector.
The Scheme can be found here, and its Explanatory Notes here.
The Scheme and Data Protection
All organisations participating in the Scheme must comply with the data protection laws that apply to them. A Data Protection Impact Assessment (DPIA) has been undertaken of the data protection impacts of the Scheme, and how data protection risks can be mitigated. This DPIA follows the UK format, but it can be used as basis from which DPIAs can be developed and adapted for other juridictions.
A copy of this DPIA is available here.
The purpose of a DPIA is to help analyse, identify and minimise data protection risks of a project or plan. It is a key part of accountability obligations under the EU Global Data Protection Regulation (GDPR). The DPIA does not have to eradicate all risk but should help minimise and determine whether the level of risk is acceptable in the circumstances, considering the benefits of what you want to achieve.
Conducting a DPIA is a legal requirement for any type of processing that is likely to result in a high risk to the rights and freedoms of individuals. It can reassure individuals that you are protecting their interests and have reduced any negative impact on them as much as you can. Conducting and publishing a DPIA can also improve transparency and make it easier for individuals to understand how and why you are using their information.
Who to contact to signify adoption of the Scheme and / or ask questions related to implementation
Please write to schr@ifrc.org if your organisation is interested in participating in the Scheme and / or you have any question related to the Scheme and its implementation. We have also prepared a supporting document for potential new signatories and other stakeholders
Organisations which are implementing or in the process of implementing the Scheme:
