1.4 Digital Accountability to Affected People in the MENA Region An internal survey on Communication with Communities and Outreach conducted by UNHCR in the MENA region in 2020 indicated that the digital tools most used by UNHCR and partners in their work with forcibly displaced and stateless persons are hotlines (80 percent), WhatsApp trees (70 percent), and Facebook (65 percent). The increasing use of mobile phones and smartphones, including in situations of displacement, can facilitate Two-Way communication with affected people, including with hard-to-reach populations.8 In these contexts, understanding and overcoming digital divides is of paramount importance. Context-specific barriers related to coverage, accessibility, affordability, literacy, or digital skills can exacerbate existing inequalities associated with age, gender, and diversity characteristics, such as disability or language. This may result in the most vulnerable individuals being excluded from information and participation, impacting on their ability to contribute to enhancing their lives and wellbeing.9 UNHCR and partners must be mindful of these constraints and risks when introducing or expanding digital service delivery, particularly if this is to replace face-to-face service delivery. Digital engagement methods and channels cannot be applied with a “one-size fits all” approach as certain approaches may be applicable and appropriate only for some population groups. Before introducing digital strategies, it is therefore necessary to systematically assess the Information and Communication Needs of different population groups to adjust and adapt to the given operational context. 1.5 Data Protection and Privacy When implementing digital tools, UNHCR and partners must consider a range of potential data protection and privacy risks that could impact forcibly displaced and stateless persons as well as UNHCR and partner staff. In case of misuse, risks faced by affected people may include threats to individual security, legal status, financial situation, access to essential services and the right to privacy.10 Where digital literacy is low, risks may also relate to a lack of understanding about online presence, privacy and confidentiality concerns, terms of use, and how their data will be stored and used. Data Protection Impact Assessment (DPIA) UNHCR operations are required to design digital communication and AAP tools with privacy and confidentiality in mind and undertake a DPIA for any systems or projects where personal data is processed. By undertaking to identify, assess, mitigate, and communicate data protection risks and their impact to the people we work with, we fulfill our responsibility to be more accountable towards them and safeguard their rights. UNHCR’s 2015 Policy on the Protection of Personal Data of Persons of Concern to UNHCR, commonly referred to as the ‘Data Protection Policy’ (DPP), lays out rules and principles on the processing of the personal data of persons for whom UNHCR works. The DPP is complemented by Guidance on the Protection of Personal Data of Persons of Concern to UNHCR, or ‘Data Protection Guidance’ (DPG), which provides further details on the DPP’s implementation, supervision, and accountability provisions. Where UNHCR and partners introduce digital services, accountability inevitably extends from face-to-face to the digital space. UNHCR and partners must ensure adherence to corporate and interagency data protection frameworks, and foster inclusion and access to personal data to the extent possible. To mitigate and manage risks associated with the use of digital tools, UNHCR and partners must address security vulnerabilities which are inherent in digital systems, networks, devices, and technologies, but also ensure that affected people understand the risks relating to them and are supported in protecting themselves against those risks. In addition, UNHCR and partners must support affected communities to exercise their rights as data subjects accurately and effectively when using digital tools. 8 Price, R.A. ‘Improving beneficiary feedback mechanisms for refugees’ K4D Helpdesk, Brighton, UK: Institute of Development Studies, 2018. 9 See ICRC, The Engine Room and Block Party, Humanitarian Futures for Messaging Apps. 10 For additional information on online threats and digital risks – including online censorship, cyber threats, data protection risks, disinformation and privacy harm, see UNHCR, ‘Connecting With Confidence: Managing Digital Risks to Refugee Connectivity’. MENA AAP TOOLKIT: STRENGTHENING INCLUSION AND ACCOUNTABILITY TO AFFECTED PEOPLE 3