Use of XI identifiers for national or sub-national NGOs and CSOs


(SJohns) #1

I have been doing some investigation into the use of the XI identifiers for civil society organisations/networks. I’ll write it up properly, but I just wanted to open up some thoughts that I have had.

IATI organisation identifiers are unique to each organisation and their function is to tag an activity back to the organisation. But an IATI organisation ID is also another tool for data users to help them identify an organisation from the details in the ID, and thus to show the organisation is who they say they are. This is important because anecdoctally we are hearing that funders and international NGOs are using IATI data to find partner organisations.

The organisation identifier rules are here but generally this has been handed over to org-id.guide, a service hosted by Open Data Services Cooperative in the UK.

I’d like to flag up the growth in issuing XI-IATI- identifiers to national and sub-national level NGOs (NNGOs) and civil society organisations (CSOs). Funders are pushing for transparency of the delivery chain and at the same time increasing funding directly to NNGOs/CSOs, which means that there’s a new market in NNGOs and CSOs having an IATI ID. Whilst most NNGOs and CSOs in countries with stable registration systems will have an IATI ID, XI-IATI- are being issued where the org-id.guide team cannot find out how NNGOs/CSOs are registered/deemed legitimate in country contexts that do not have easily accessible/online registration systems.

My challenge is therefore: how can we serve NNGOs/CSOs in these contexts better and ensure that they own a unique ID that reflects their reality and also provides the useful information to data users?

This is an important challenge not just for IATI, but for all the other data standards that use the org-id.guide to generate unique IDs for organisations. I know that the org-id.guide is on the surface just a centralised list of registries, but there is a risk of excluding NNGOs and CSOs from being properly identified, if this challenge is not solved.

Reviewing the list of XI-IATI identifiers and looking at the org-id.guide issues list on Github, I worked on the premise that the majority of CSOs that need identifiers, will need them because they are receiving funding. Therefore they will have a bank account or their nearest family member will have a bank account. To have a bank account they will need to be a registered entity. This also holds true for international networks and alliances that are receiving funding. If an organisation does not meet this criteria, it’s perhaps enough to be named in the funder’s data and not have an IATI organisation identifier.

In the 30 minutes I had to do a review, I found two organisations which could legitimately have a unique ID.

The first is, I think, a legacy issue. The network CABI has the identifier XI-IATI-CABI. However a search on the UK Companies House shows that it has the registration number 1973924.

The second is a recent org-id.guide issue for Somalia Family Services. ODSC were unable to find a registry in Puntland, Somalia, that was suitable, so ODSC closed the issue and handed the request back to the IATI technical team to issue an XI-IATI identifier. However, a quick search shows that Somalia Family Services is a US registered organisation, and the Puntland organisation is a locally registered operational office:

The United States based Somali Family Services here after referred to as “SFS” is a non‐profit organization headquartered in Minneapolis, Minnesota registered under Federal Act 501(C3) and a leading Somali capacity enhancement entity, locally registered with the Ministry of Planning and Local Government in Garowe, Puntland

At the very least, Somalia Family Services could use the US-EIN number of the US office, which would show that the organisation is who they say they are. Even better, the US organisation should be able to provide advice on how their Puntland office is registered with the government which would help build up the list for Somalia.

I am still thinking through the solutions to this challenge. My feeling is that it includes the engagement of national NNGO and CSO networks to advise IATI and org-id.guide. At the very least by acting now, we can ensure that organisations take ownership of their own unique IDs rather than accepting the default of XI-IATI identifiers.

What do you think?


[Added] New Organisation Identifier: XI-IATI-EFRD
(Andy Lulham) #2

I wonder if the org-id.guide issue template could do with restructuring… It currently frames the question as:

Where can I find a register in country X, for type of organisation Y?

But the question that’s usually being asked (in the context of IATI, anyway) is:

Where can I find an identifier for organisation Z?

In the Somalia Family Services example, it appears that the whole search was geared around Puntland (the region) and not around the organisation. But the recommendation made relates to the organisation.


(Yohanna Loucheur) #3

Thank you @SJohns for opening this important conversation!

You’ve outlined quite well some concerns I’ve had over the years with the creation of XI-IATI identifiers. Assigning XI-IATI identifiers is an easy short-term solution that may well turn out to be counter-productive over time as they will make it more difficult to link information about organizations across various data sources. Especially since there has been a tendency to treat the creation of an XI-IATI number as a temporary measure until a more permanent solution is found/ready (see for instance [Added] Request for new org ID: XI-IATI-OCHASDC or [Approved] New Organisation Identifier: XI-IATI-BEH )

This very important point has not been receiving enough attention, in my opinion. The org identifier is ultimately about the legal entity. It may be that this is more difficult to find in some countries than in others, but creating an XI-IATI number should not be the default option - especially not if it is meant to circumvent the fact that the publisher is not a legal entity (for instance [Approved] Create new Organisation Identifier XI-IATI-FIABEL)

It seems to me that a useful first step when an organization requests an XI-IATI number would be to ask for the legal entity information and help it figure out its proper identifier (following advice from org-id.guide). The issuance of XI-IATI identifiers should be a very last resort solution, presumably only for organizations based in countries where institutions have faltered entirely.


(K Armstrong) #4

Hi Yohanna

I work on the Org-ID team at Open Data Services. We do ask for evidence of organisations’ status when supporting them with identifier requests. We are often working with photocopies of certificates and forms and so on.

However the problem we are coming up against is that being legally registered does not mean that the organisation has a unique, persistent, stable ID conferred on it. It very much depends on the particular business and administrative processes in a given country, how digitized they are and how transparent they are. There may not be a ‘list’ which is missing from Org-ID that simply needs adding.

I hope that helps clarify the situations we are finding and why more XI-IATI- identifiers are being issued.


(Yohanna Loucheur) #5

Yet, the fact that there isn’t a searchable list does not mean that we could not use the number issued to the organisation to generate a better identifier than XI-IATI. Org-ID can figure out what the ID string would be in that country and document it on Org-ID. A huge benefit of such an approach would be to generate identifiers that would convey more useful information (e.g. country) and be usable across open data standards.

In addition, there are examples when an XI-IATI number was assigned to something that was not a registered organisation/legal entity.

Again, I welcome the discussion opened by @SJohns, especially as we collectively think about IATI’s strategic priorities in support of the 2030 Agenda. It’s a good opportunity to examine whether our approach to assign identifiers, while expedient in the short term from a publishing perspective, is supportive of our longer-term vision.

I do think the whole XI-IATI approach needs to be rethought.


(Simon Whitehouse) #6

Hi Johanna

I work on org-id (not on IATI at present) at Open Data Services Co-operative.

This is an important point.

The checks we make when we try and add a registrar/list to org-id do not include a searchable online list. My understanding is that if we can be certain that an organisation has a unique, persistent, stable ID then that is sufficient.

Where there is a searchable list then, for various reasons, it is easier to establish that IDs on the list are unique, persistent and stable.

If you have examples where registrars have been excluded from org-id because there is no searchable list then I think we should take another look at them.


(Simon Whitehouse) #7

Hi there

Thanks for raising this issue.

I think it would be really useful to do this. At the moment there is a relatively small community of people involved in org-id. We can often spend quite some time on desk research that feels like it comes very close to adding an organisation register, but then not being able to.

This issue, to add an organisation list for Joint Stock companies in Pakistan is one that illustrates this.

We just don’t know how the ids are being created here and after considerable effort we have suggested an XI-IATI identifier. This isn’t satisfactory and I think we could have made more progress if we had a wider network that includes local, in-country networks.

I’m resistant to suggestions to relax the constraints we have on accepting registrars/lists to org-id. In general I think we should try and expand our network, as you suggest, before we consider this.

What would be the next steps towards doing this?

Thanks again for raising this
Simon


(SJohns) #8

Hi, I just wanted to thank everyone for their contribution to this discussion. To summarise:

The challenge that we are trying to solve: that each civil society organisation assigned a unique identifier using the org-id.guide approach has an ID that includes information about their organisation, not a neutral ID like XI-

In order to do this, an organisation needs to already have a unique, persistant (not temporary), stable (not likely to change) identification number/code in the country which is linked to registration on an (ideally) government registration service that can be added to the org-id.guide service.

Do you think that’s a fair summary so far?

I just wanted to add further thoughts:

National registration can be used as means to legitimise NNGOs/ CSOs in a particular context, but may also be used to control NNGOs/CSOs. For example, a government may require registration in order to control national NNGO/CSOs’ access to foreign funding, or to be able to de-register CSOs in order to criminalise their activities. As funders increasingly spend ODA in fragile or conflict states, this scenario becomes more likely (Civicus estimated that 6 out of 7 people in the world now live in a country where CSOs are under threat in this way).

This throws up a couple of extra scenarios:

  1. Even in countries where government-level CSO and NGO registration exists, a registration number may not represent a stable ID. For example, 959 NGOs were threatened with de-registration in Kenya in 2015 and CSOs were also threatened in Zimbabwe in 2018, a country where all of the NGOs were de-registered in 2007. There are other examples - even in the UK where CSO registration is used as a control mechanism.

  2. Government registration systems which were previously stable may be completely fragmented through conflict, for example Syria, even though there are national CSOs operating and delivering humanitarian aid in partnership with funders.

Whilst an XI- ID could of course be used in these scenarios, it doesn’t solve the challenge. I’m starting to think, like @YohannaLoucheur, that there may be a need to include different lists (for example NGO-owned network lists) to ensure the inclusion of NNGOs and CSOs.

I think a place to start is to have a conversation with national NGO and CSO networks where the majority of the issues are occuring (judged by the org-id.guide github issues list?) or perhaps with Forus, which is the network of networks.

What do you think?


(Michelle Levesque) #9

Once we solve the issue of civil society orgs can we attempt to solve the issue of government agencies? Other than for Canada (they made a list that is available in the OrgID Guide) and the UK (they have so many IATI publisher numbers) I can’t find references to the various agencies of most governments. Germany has a lot on the DAC-Agency list but that appears to be more of an exception.

I very much appreciate the efforts made by the OrgID Guide but finding participating org IDs is still one of the most painful processes and often leaves one empty handed.


(Jahnvi Dave) #10

Hi all,

Thank you, Sarah, for raising this discussion and for your suggestions of making use of the NGO and CSO networks to support research into organisation registration agencies.

There are currently three organisations that are in the middle of the process to get an XI-IATI identifier. On a practical note, these need to be taken forwards as the organisations have been waiting for an identifier for some time, and have time pressures on publishing. In the interests of not letting this discussion further delay them in publishing their data, we have followed our current process as follows:

  • We currently have two XI-IATI proposals that have been on Discuss for more than 7 days (XI-IATI-ATTIC and XI-IATI-SGJ). Following our usual process, I have approved these identifiers and they will be added to the IATI Organisation Identifier list in due course.
  • I have shared a new proposal (XI-IATI-EFRD), as the decision was made by the Org-ID team in January that an identifier could not be constructed at this time, for the Registrar of Joint Stock Companies in Lahore City District, on the basis of the current research available to them. @SJohns If there are any relevant networks in Pakistan that could be useful to Org-ID’s research in this case, please do comment directly on the Discuss proposal.

(Yohanna Loucheur) #11

The thing is though that 1) the substantive discussion is always further delayed in the interest of the short-term action of creating new XI ids, which 2) then compounds the problem further as these XI ids will have to be dealt with at some point.

@SJohns, I do see the very serious issues you raise about control, and see these becoming more acute in the context of development cooperation focusing increasingly on fragile states.

Yet, these organizations are able to function, for instance to open/hold bank accounts. What do banks accept as proof of existence/identity? Could we not use a similar approach (ie the same references)? For one thing, donors are more likely to have the same reference in their system than a random XI identifier - thus enabling traceability.

To my mind, IF indeed identifiers need to be created from scratch, a more suitable solution than XI-IATI- would be a string that could be common to all relevant open data standards (e.g. IATI, Open Contracting), along with a strong commitment from the NGO/CSO receiving this identifier ot use this unique identifier in all its communications/dealings, so that data about the NGO/CSO can be joined up. We really should stop seeing this as creating an “IATI Identifier” (which implicitely means “only to be used in IATI data”) and instead think of a “CSO identifier” to be used in everything until a proper national identifier can replace it.


(Yohanna Loucheur) #12

It was almost certainly in the context of creating new XI-IATI, so you’d probably find them in older Discuss posts seeking non-objection to new XI-IATI.


(Steven Flower) #13

Thanks @SJohns for raising this, and to colleagues for feedback

I think this goes to the heart of it. I dont think it’s sustainable or relevant for the IATI Tech Team or (my colleagues) at Open Data Services Co-operative to be researching at great length these cases. Is it controversial to suggest that we’ve been giving too much support to prospective publishers?

Should our way forward be along the lines of

  • prospective publisher uses their identifier, based on available lists
  • prospective publisher proposes their identifier based on their legal status / entity type, when their Registry is not on the list (they then use this once the Registry is on the list)
  • If they cannot identify themselves, then they cannot publisher. Advise should be sought from support networks / donors / peers

(I’m aware that the last step sounds harsh - but it’s that last step which results in pressure on creation of a XI-IATI?)

I am minded that IATI is promoting a protocol through which to construct an organisation reference. It is great that IATI has been a huge champion and user of this methodology. However, we need to avoid IATI becoming the gatekeeper to, or keeper of, any unique list imho


(Matt Geddes) #14

Here is an XI request where I was able to find some unique codes but was rejected because they were no available through an online searchable list.

On that chain I had wondered whether it would be possible to at least standardise the XI-IATI identifiers to give some more information - at the moment, unless you can find the request on github, you often have very little idea if working backwards from an XI-IATI ID. For example, what about adding a UG, giving IA-IATI-UG…for all Uganda based organisations?

Even better would be XI-IATI-UG-NGO-BEH…so I know that we are looking at a Ugandan NGO with the name BEH but without an online registry for me to lookup more information.

Even further down the wishlist, it would be great if this information (the non-online/searchable registration details, perhaps a list of the numbers they do have) was put on the publisher profile e.g. here which also shows me that we could at least encode the ‘publisher type’ into the XI-IATI chain given we have that information, in this case XI-IATI-CAR-NGO-ACATBA.

In this way, once there is an NGO registry in the CAR that is online and searchable, then it will be much easier to find all the IDs on XI-IATI that we can now shift off there to proper IDs.

Last thing, I thought that some of the suggestions of using the registrations from parent organisations was a bit dangerous as it would give the impression that the contract/funds/management flow through the parent organisation, which it may not.