Harmonised SEAH data collection and reporting

CHS Alliance and the Steering Committee for Humanitarian Response (SCHR), with funding from the Foreign Commonwealth Development Office (FCDO), have joined forces to increase transparency on sexual exploitation, abuse and harassment in the aid sector through the development of a harmonised framework for SEAH data collection and reporting.

The pilot phase of the SEAH Harmonised Reporting Scheme is being launched on 16 September. It will test the proposed harmonised framework with a range of national and international organisations. However, we need more organisations to join us to find a system that works for all. Read on and look at our Frequently Asked Questions for more details about how your organisation can get involved.

Goal

Increase transparency on SEAH and reduce under-reporting by introducing a harmonised SEAH data collection and reporting framework.

Objective

Advance the development of a harmonised SEAH data collection and reporting approach for aid organisations to support trend analyses and effective learning from aggregated data, which will inform policies and strategies aimed at improving victims’ outcomes and prevention interventions

Why we need the Scheme

“We need to flip the narrative around reporting by underscoring it as one of the key ways we will be better able to prevent and respond to SEAH incidents.” Elizabeth Pender, Senior Advisor, Safe and Accountable Programming, USAID’s Bureau for Humanitarian Assistance.

“We want to reassure organisations that signing up for the Scheme, reporting transparently and in doing so helping to address allegations is a positive step. [The Scheme] will mean we can better analyse patterns and develop evidence driven strategies and interventions to help target areas – both thematically and in terms of locations – with the highest risks of SEAH.” Dr Kweku Ackom, Health Advisor, Safeguarding Unit, UK’s FCDO.

“At the moment, we simply don’t have the adequate quality of data to know what we’re facing; let alone what forms it takes. This is like fighting blindfolded. The more quality data we have the better we can see. See enough to chart a way to stop this unacceptable abuse happening to the people most deserving of support and care.”Wonder Mufunda, Chief Executive Officer, Centre for Humanitarian Analytics.

“Sharing of information and reporting incidents of SEA can help us to understand the scope and complexity of the problem. It will also allow us to address the causes and to support victims and survivors more effectively. We are committed to working towards the harmonization of the UN iReport and the SEAH Harmonised Reporting Scheme to simplify reporting, eliminate duplication, and increase transparency and accountability across the aid sector.” Christian Saunders, Special Coordinator on improving the United Nations response to sexual exploitation and abuse.

Organisations sign up to the scheme on a voluntary basis

Participating organisations adopt the proposed SEAH harmonised framework (commitment)

Organisations are provided with an excel template for recording and sharing agreed set of data of SEAH

Participating organisations invited to provide their data on a quarterly basis, on a voluntary basis, taking account of data protection and confidentiality requirements

Data collected and shared to the SEAH Harmonised reporting scheme Officer and the CHS Alliance PSEAH Manager only

The data is made anonymous, consolidated, and used to produce anonymized aggregated figures and trend analysis

Summary data and any learning captured is presented to the Scheme Steering Committee and shared with organisations participating in the scheme on an anonymized basis as well as to the public

Your organisations must contact Mathilde Belli, sending a short request from the official email account of the head of your organisation (CEO, President or Secretary-General), confirming that they formally endorse the Scheme and commit the organisation to implement it. Once your application is accepted, we will ask you to provide some additional information.

Once you have officially endorsed the scheme, you will receive a briefing from the project officer and will be asked to fill the SEAH harmonized reporting template on a quarterly basis. The non-identifiable data received from all partners will then be aggregated and analyzed on a quarterly basis in a trends report to inform learning, advocacy and policies.

The Steering Committee serves as an effective forum to agree, promote, and adopt the harmonised framework. It is an important body in advising about the potential development of a centralised online reporting system at a later stage of the project.

Resources

Do not hesitate to use these documents as part of your internal updates to sensitise staff within your organisation, engage them, raise awareness about the scheme. You can also request support from the SEAH harmonised reporting scheme Officer to deliver a briefing. The documents can also be useful to promote the scheme externally in external forum, meetings, workshops or seminars.

The SEAH harmonised reporting scheme works to the following principles:

• Transparency around processing
• Guarantee implementing organizations rights throughout the process
• Ensure that all purposes, actions and analysis taken under the Scheme are properly documented
• Confidentiality and anonymity – Retain and store data in a way that will not allow to identify any individuals, in accordance with GDPR retention policies
• A Data Protection Impact Assessment was conducted for the Scheme which informed the design of a Data Protection Protocol to protect the data throughout the reporting process. For more information on the Protocol or to access these two documents, please contact Mathilde Belli (mbelli@chsalliance.org)

What is the SEAH harmonised reporting scheme?

Why do we need harmonisation on SEAH data collection and reporting?

What are the objectives of the SEAH harmonised reporting scheme?

How was the scheme designed and who was consulted to inform the design?

Who can sign up to the SEAH harmonised reporting scheme?

What should I do before signing up to the harmonised scheme?

How can I join the SEAH harmonisation reporting scheme pilot?

Is there a membership/subscription fee to join the scheme?

Can an organisation withdraw from the scheme?

What information should organisations report on a quarterly basis?

My organisation uses different definitions of sexual misconduct than other organisations, which may lead to misunderstandings. How does the SEAH harmonised reporting scheme address this issue?

How will reporting work in practice for pilot members?

Who from my organisations should report the cases?

When will open cases be reported?

If I work with partners, should I report their cases?

Should I report cases that were reported to me on another organisation?

Is the SEAH harmonised reporting scheme a central database?

How will data protection be guaranteed?

How is the SEAH harmonised reporting scheme meeting GDPR’s requirements?

How will data be analysed and shared?

Which organisations are already implementing the SEAH harmonised reporting scheme?

Will donors also be encouraged to join the scheme to facilitate reporting and ensure this isn’t an additional reporting layer for organisations?

Is an expansion of data fields planned in the future, to strengthen trends analysis on the incident, victim/survivor and alleged perpetrator?

Will participating organisation have the opportunity to provide feedback?

Will learning be shared when the pilot comes to term?

If my organisation has limited capacity on PSEAH and limited resources, would I be able to join the scheme?

How is the scheme governed?

Will technical support be provided to organisations who participate in the scheme?

Can I speak with another member to learn from their experiences?

If my organisation can only share aggregated data on SEAH, can I still participate in the scheme?

If my organisation already has a data collection system in place that differs on some data fields but aligns with others, can I still participate in the scheme?

What is the SEAH harmonised reporting scheme and what are its objectives?

The SEAH harmonised reporting scheme is an initiative led by the CHS Alliance and the Steering Committee for Humanitarian Action (SCHR), funded by the Foreign Commonwealth Development Office, aiming to support NGOs and private sector organisations to collect and report SEAH incidents in a uniform way in a harmonised SEAH data collection and reporting framework, currently being piloted. This system will support trends analyses and effective learning from aggregated data, which will inform policies and strategies aimed at improving victims/survivor’s outcomes and prevention interventions.

The scheme aims to introduce a harmonised framework for SEAH data collection and reporting based on existing best practice, with the following mid- and long-term objectives:

• Increase transparency and accountability on SEAH
• Reduce under-reporting of SEAH by facilitating reporting by NGOs and the private sector, through a single and simple system
• Support trend analysis and effective learning from aggregated data to inform policies and strategies aimed at improving victim/survivor outcomes and prevention

You can read more about the project rationale and details here.

Why do we need harmonisation on SEAH data collection and reporting?

Organisations today capture widely varied and incomparable SEAH data, often due to the multiple and distinct requirements they have from various stakeholders, and due to the absence of global consensus and guidelines on which data should be collected and reported. Although the data collected is similar, the data fields or categories in each data fields are often different, which makes joint data analysis impossible. This results in little data or trends being available on SEAH, giving the aid community a limited knowledge and understanding of the problem beyond each organisation’s experience, hindering learning. A harmonised reporting framework would allow us to have global trends on SEAH to better understand the intricacies of the problem, and therefore improve policies and strategies for risk mitigation, prevention, and response based on evidence from the field.

How was the scheme designed and who was consulted to inform the design?

Consultations were undertaken in 2021-22 with around 60 diverse organisations (INGOs, NNGOs, private sector organisations, etc), with the objective of mapping the data currently being collected and reported by organisations, and consulting stakeholders on their perspective and suggestions on the creation of harmonised framework for SEAH reporting. The report from the consultations can be found here. Results informed the design of a draft framework, which was submitted to the project’s Steering Committee for review and adoption (more information on the Steering Committee can be found here). The framework will be piloted over a year (from October 2022 to September 2023) with a group of INGOs, NNGOs and private sector organisations, and adjusted based on their feedback before scale up.

Who can sign up to the SEAH harmonised reporting scheme?

The scheme is open to all types of organisations – international non-governmental organisations, national or local non-governmental organisations, private sector organisations as well as donors. Participation in the scheme is voluntary and free for any organisation. All types of organisations can join the scheme, regardless of their size at any time during the pilot – we have a mix of organisations, with the smallest having less than 10 employees and the bigger ones having tens of thousands of employees. For the United Nations, a harmonised reporting system for SEAH already exists, called UN iReport, which is why they aren’t included in this scheme. However, the scheme does not aim to substitute or duplicate the UN iReport, but rather complement it by harmonising data from non-UN entities. Special attention will be given in staying harmonised with the iReport, to ensure comparable top-level data, which could allow for some joint analysis in the future.

What should I do before signing up to the harmonised scheme?

Make sure that your organisation can meet the Scheme’s requirements in practice:

• Internal agreement to adopt the proposed SEAH harmonised framework and to use it to collect data on SEAH incidents;
• Appointing within your organisation a specific focal point to collect and report SEAH incidents on a quarterly basis (January, April, July, October);
• Having processes in place allowing your organisation to safely collect and share information about SEAH incidents on a quarterly basis using the Scheme’s reporting processes to enable anonymized analysis of trends and patterns.

How can I join the SEAH harmonisation reporting scheme pilot?

To sign up to the Scheme and become an implementing organisation, you must contact the scheme’s project officer from the official email account of the head of your organisation (usually the CEO, President or Secretary-General) confirming that they formally endorse the SEAH harmonised Scheme and that your organisation commits to implementing it. Detailed information on joining is accessible here.

Is there a membership/subscription fee to join the scheme?

There is currently no subscription fee or other cost to sign up to the SEAH harmonised reporting scheme.

If I join, do I have the right to withdraw at any time?

The participation in the SEAH harmonised reporting scheme is voluntary and you can withdraw at any time. To withdraw from the Scheme, the head of your organisation must contact the Scheme project officer confirming their decision to withdraw.

What information should I report on a quarterly basis?

You should report quarterly using the harmonised SEAH data reporting template which includes the data fields listed below, to be filled out for closed cases only. We encourage you to fill as many of the data fields as possible, using the categories available in the template.

If you do not have data for a specific data field, you may use the “unknown” option. More information on the rationale and guidelines per data field can be found in the data reporting template’s first tab called “rationale & instructions.”

My organisation already has a system in place and uses a specifical template/system to collect and report SEAH incidents. Can I still join the scheme and if so, how should I proceed?

Even if your organisation has a system in place, you can still use our framework to report every 3 months. Often the data fields we collect data on are already covered in your system so you should be able to use the reporting template, and if not, you can decide not to fill out some data fields if deemed too difficult for the organisation. However, we encourage organisations to try and fill out as much of the data fields as possible to allow for better quality of analysis.

My organisation uses different definitions of sexual misconduct than other organisations, which may lead to misunderstandings. How does the SEAH harmonised reporting scheme address this issue?

The harmonised data framework defines the main categories of sexual misconduct (sexual exploitation, abuse and harassment) to ensure harmonisation and common understanding on definitions. The scheme uses definitions of SEAH as set out in the latest CHS Alliance guidance, including the SEAH Investigation Guide (2022) and the PSEAH Implementation Quick Reference Handbook (2021), which in turn have their basis in the UN Secretary General bulletins ST/SGB/2003/13 and ST/SGB/2019/8. The definitions used are the following:

• Sexual exploitation: “any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes. It includes profiting momentarily, socially, or politically, socially or politically from the sexual exploitation of another. Under UN regulations it includes transactional sex, solicitation of transactional sex and exploitative relationships.”
• Sexual abuse: “the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual assault (attempted rape, kissing/touching, forcing someone to perform oral sex;/touching) as well as rape. Under UN regulations, all sexual activity with a child (under the age of 18 years) is considered to be sexual abuse”.
• Sexual harassment: “unwanted conduct of a sexual nature. It can happen to any gender and be physical (e.g., touching), verbal (e.g. offensive comments or phone calls), or non-verbal (e.g. display of offensive materials). It can involve a pattern of behaviour or a single incident.”

How will reporting work in practice?

Only closed cases should be reported for the moment. You will report SEAH closed cases on a quarterly basis using the SEAH Harmonised Reporting Scheme template. The filled template will be sent by your agreed focal point or alternates to a protected email address (only shared with participating organisations piloting the scheme) on the second Monday of each quarter (January, April, July, October). More information on data protection processes to ensure safe reporting can be found here.

Who from my organisations should report the cases?

The person who will do the reporting should be the person already or specifically appointed within an organisation to manage or oversee SEAH incidents. The specific title or role of this person may vary from organisation to organisation (Safeguarding Advisor, PSEAH coordinator, Ethics Officer, PSEAH focal point, etc). Organisations are free to choose who within their organisation will be responsible for this task. It is recommended that you identify one or two alternates to ensure continuity in case of leave. You should share the contacts of the focal point and its alternates to the Scheme project officer prior to reporting so they can be briefed on the reporting process.

When should I report open cases?

You will only report closed cases, as requested during the consultations. Any case still open at the moment of reporting should be reported in the following quarter when the case is closed. The question of reporting open cases will be revisited during the pilot phase with scheme partners to determine whether the final framework will only include closed cases or also include open cases. The decision will be taken based on feedback from participating organizations and only with the approval of the Steering Committee.

If I work with partners, should I report their cases?

Each organisation should report the cases internal to their organisations only, to prevent double reporting. Therefore, you shouldn’t report cases from your partners and these should be reported by your partners to CHS directly. For this reason, if you work with partners you are encouraged to support them in joining the Scheme so that their SEAH incidents can be included in the reporting and analysis.

Should I report cases that were reported to me on another organisation?

No. You should report cases internal to your organisations, to prevent double reporting of cases. If you receive a case about another organisation, you are nonetheless responsible for systematically referring this case to the concerned organisation.

Is the SEAH harmonised reporting framework uploaded on a publicly available centralised database like the UN iReport?

At the moment, no. The SEAH data collected through the SEAH harmonised framework, which allows organisations to collect and report SEAH incidents in a uniformed way, are not reported in their disaggregated state to a public centralised database system such as the UN iReport. Cases from different partners organisations are compiled and stored on a secure CHS server, without any mention of organisation names (more information on data protection can be found here). The database is NOT made public and will only be used to produce aggregated and anonymised trends analysis.

The phase 3 of the project (2023-2024), following the validation of the harmonised framework at the end of the pilot, will assess the willingness of organisations and feasibility of shifting to a secure online centralised platform for reporting with real time analysis. The degree of information made public will be decided in concertation with scheme partners and the Steering Committee.

How will data protection be guaranteed?

A thorough analysis of risks for data protection was conducted by the CHS Alliance, following the DPIA process, which in turned informed the development of a Data Protection Protocol. The Protocol outlines the process and steps for reporting, detailing the data protection measures which will be guaranteed at each step. It also examines the levels and severity of identified risks, and outlines the mitigation measures to reduce or eliminate those risks. Data Protection is guaranteed through three key steps, creating multiple layers of security, with each phase of the system created as a separate entity, with no way to link the entities to one another to ensure maximum data security. With this three level process, no file linked to a specific organisation is ever hosted on the server, only aggregated and anonymized data on SEAH cases from multiple organisations is stored. All servers hosting data are protected by double authentication (MFA) with access restricted to the CHSA Scheme lead and PSEAH Manager. The data stored on the server includes absolutely no personally identifiable data for the organistions, victim/survivor or alleged perpetrator, as none is collected as part of the scheme in order to preserve confidentiality. As such, the risks for organisations who report are very low.

If you are interested in knowing more about how data is protected in the PSEAH Harmonised Reporting Scheme or in accessing these two documents, please contact Mathilde Belli (mbelli@chsalliance.org). The Data Protection Impact Assessment & Data Protection Protocol will only be shared on request.

How is the SEAH harmonised reporting scheme meeting GDPR’s requirements?

Your organisation retains ownership of your own data and determines what can be shared based on the internal procedures of your organisation. The CHS Alliance will only retain and store data in a way that will not allow to identify any individuals or organisations, in accordance with GDPR retention policies. The data stored will only be aggregated data, meaning it will not be identifiable or linkable to your organisation, and will only be stored and used for purposes of data analysis and learning in line with the objectives of the pilot phase of this project.

Only the SEAH Harmonised reporting scheme Officer and CHS Alliance PSEAH Manager responsible for the implementation of the scheme will have access to the data.

How will data be analysed and shared?

Once the data from all participant organisations is received, the data will be made anonymous and aggregated, meaning that cases can no longer be linked to a specific organisation. The SEAH Harmonised Reporting Scheme project officer will then use the aggregated data to conduct an analysis to identify trends and patterns on the main data fields as well as key learning from the data.

The trends analysis will be shared in a report to organisations piloting the Scheme and the Steering Committee’s members. A public report with only top-line data and learning will also be shared externally. Both reports will not contain any identifiable information on victims/survivors, alleged perpetrators, or reporting organisations.

Which organisations are already implementing the SEAH harmonised reporting scheme?

The list of organisations piloting the scheme is regularly updated on the webpage of the SEAH harmonised reporting scheme on the CHS Website.

Will donors also be encouraged to join the scheme to facilitate reporting and ensure this isn’t an additional reporting layer for organisations?

Donors will be actively encouraged to endorse the scheme and align their reporting requirements with those of the scheme. During the pilot, donors will be approached and encouraged to assess the feasibility of aligning their reporting requirements to those of the scheme, and to provide feedback for this to be feasible. They will play a key role throughout the pilot. Once the framework is finalized taking into consideration their feedback and those of implementing organisations, donors will be expected to align their mandatory requirements for grantees on SEAH with those of the harmonised scheme, which would enable organisations to share their SEAH incidents to donors and the public in a confidential and transparent manner.

Information on the scheme specifically tailored to donors has been developed and is available. The project team is also actively advocating for donor commitments. Please contact the Scheme’s project officer for more information on the role of donors in the scheme.

How does the framework relate to the work being done on the SCHR Misconduct Disclosure Scheme?

The Misconduct Disclosure Scheme and the SEAH harmonised reporting scheme are separate interagency initiatives that are closely interlinked in their effort to address SEAH in the Aid sector. The MDS aims specifically at stopping perpetrators of sexual misconduct moving between organisations undetected, by facilitating the sharing of misconduct data between employers, improving reference checks and safer recruitment processes. It is currently implemented by over 160 organisations.

While the two schemes have different approaches and areas of focus, they both look at creating a more transparent and collaborative environment among organisations in the Aid and development sectors, recognising that SEAH is an existing and ongoing problem that requires collective and coordinated answers, at different levels and from different entry points, as well as a shift in the dominant culture.

Is an expansion of data fields planned in the future, to strengthen trends analysis on the incident, victim/survivor and alleged perpetrator?

Collecting and reporting too many details on the nature of the incident, profile of the victim/survivor and the alleged perpetrator creates a high risk for identification, therefore compromising confidentiality and anonymity. Organisations who took part in the consultations which informed the design of the scheme expressly requested that only top-line data was collected to ensure confidentiality and to ensure all SEAH data remains totally unidentifiable. As part of their case management, each organisation can decide what data to collect and if they wish to collect more in-depth data. Nonetheless, only top line data should be reported through the scheme to maintain confidentiality and ensure we do no harm. Nevertheless, the pilot phase gives organisations and donors an opportunity to share regular feedback about the scheme and the harmonised framework. If you feel a specific data field should be added, we encourage you to submit this request as part of the feedback phases in the pilot and this request will be examined by the steering committee.

If I participate, will I have the opportunity to provide feedback?

Yes, you will have the opportunity to provide feedback on the implementation of the scheme on a quarterly basis using a feedback form which will be developed by the CHS Alliance. This will be an opportunity to report on progress, highlight any challenges being faced and suggest improvements to the SEAH harmonised framework or the scheme in general. Feedback will be collected through the following process:

• You will be asked to fill in the feedback form on a quarterly basis
• You will send the form to the CHS SEAH Harmonised reporting scheme Officer by email
• The SEAH Harmonised reporting scheme Officer will review the feedback and provide a consolidated summary for the Steering Committee to consider.
• The Steering Committee will review the feedback and decide on any necessary amendments in the framework or follow-up.
• The decision and response of the Steering Committee will be documented, and all the organisations implementing the scheme will be informed.

Will learning be shared when the pilot comes to term?

Yes, a pilot report will be produced and shared on the CHS website just like all other reports on consultations. The report will share the results and learnings from the pilot, participants experience and feedback, as well as the recommended ways forward.

If my organisation has limited capacity on PSEAH and limited resources, would I be able to join the scheme?

Yes, all organisations, regardless of their capacity, can join the scheme if they commit to reporting SEAH data using the harmonised framework. Relying on an already functioning and technically sound SEAH collection and reporting system with strong data protection measures in place can be helpful your organisations if you have limited capacity and resources to develop their own. This saves you from having to create a system internally for reporting. Additionally, you will be able to learn from the data analysis and subsequent discussions with peers, helping you to better target fund requests or adapt their program. Technical support will also be provided to National and Local NGOs with limited resources to build their capacity and guide them to in successfully implementing the scheme (for more information, contact the Scheme’s project officer).

Our current members are very diverse and their capacity vary, so we encourage all organisations to join, regardless of their capacity and resources, if they wish to commit to harmonising their collection and reporting of SEAH data with the scheme.

How is the scheme governed?

The initial phase of the project adopted a participative and collaborative approach by developing the harmonised framework with the input from 60 participants organisations collected throughout a survey. Once a draft framework was developed following consultations, a Steering Committee was created and members were appointed on a voluntary basis and representative of organisations part of the pilot. The Steering Committee is composed of 17 organisations (NNGOs, INGOs, private sector, funders and donors, CSOs). The Steering Committee is the forum where concertation on the design of the framework were undertaken and decisions validated, but also a group responsible for actively promoting the scheme externally to ensure new members join the pilot. The current Steering Committee’s mandate will cover the period of the pilot from October 2022 to September 2023. The membership will be reviewed during the third phase of the project to allow for new members of the scheme to join. The overall management of the scheme and project is led by the CHS Alliance and the Steering Committee for Humanitarian Action (SCHR).

Will technical support be provided to my organisations if I participate in the scheme?

Yes, participating organisations, through the feedback channels, will be able to engage actively with the Steering Committee and team managing the scheme. They will have the opportunity to participate in events related to the project and meetings organised by the Steering Committee.

Virtual “workshops” or “webinars” will be specifically organised and held to technically support smaller participating organisations in implementing the harmonised reporting framework during the pilot phase. This will also serve the purpose of sharing information and practices and building the capacity and mutual understanding of those involved.

The scheme will also propose opportunities for implementing organisations to build their capacities with the following activities:

• National and local NGOs implementing the harmonised framework will be offered tailored support in participating in the scheme.
• Information will be provided on available resources and sources of information relating to PSEAH. This will take the form of guidance notes and links or sign posting to relevant websites and material.
• Good practices and learning across the scheme will be documented and shared with all organisations participating in the scheme. Organisations that have developed and gained benefits from establishing an internal data reporting system will be invited to share their experiences through blogs or presentation during webinar.

Can I speak with another member to learn from their experiences?

Yes. We encourage our members to connect with each other, exchange information and learn from their peers. The objective of having harmonised data on SEAH is also to create a community of practice where peer-to-peer learning is encouraged based on the evidence collected. You can contact our project officer to ask to be connected with other members.

If my organisation can only share aggregated data on SEAH, can I still participate in the scheme?

The purpose of the SEAH harmonised reporting scheme is for all partners to report data on individual cases using a harmonised template. We therefore ask organisations to report their data using the harmonised framework in order to be part of the scheme, rather than their aggregated data from their annual reports. This allows for us to compile all the data we receive from different organisations, and do joint analysis, which would not be possible with aggregated data only, particularly if the data isn’t exactly the same. If you are concerned about sharing aggregated data, please do remember that data will never be shared externally disaggregated, and no organisation’s name will ever be mentioned in the data analysis.

If my organisation already has a data collection system in place that differs on some data fields but aligns with others, can I still participate in the scheme?

Yes, as long as you are able to report SEAH data using the harmonised template we encourage you to participate in the scheme. We recognize that organisations may already have reporting systems in place which are difficult to change, and some data is better than nothing to begin with, so we encourage organisations to participate regardless of how much data they can provide. The pilot will also be an opportunity for you to tell us how you collect and report data and provide suggestions on how to improve the system based on your experience and on the data that you collect.