Tdh Complaint and Feedback Response Mechanism Procedure

1 April 2019 - Version 0.1 – Guideline CFRM Risk Management Sector and Quality and Accountability Unit

Tdh

Complaint and Feedback Response Mechanism

Procedure

April 2019


Table of Contents 1. Chapter 1 - Background Information ......................................................................................................... 3

1.1 Reference Framework .............................................................................................................................. 3

1.2 Objectives ................................................................................................................................................. 4

1.3 Scope ........................................................................................................................................................ 4

1.5 Guiding Principles ..................................................................................................................................... 6

Developing a Child-friendly mechanism ......................................................................................................... 7

1.6 Specific Considerations on Safety and Protection Concerns ................................................................. 10

2. Chapter 2 - Practical “How-to” Guidance ................................................................................................ 13

STEP 1 - DEFINE THE PURPOSE AND SCOPE ................................................................................................. 13

STEP 2 - DEFINE THE MODALITY FOR RECEIVING FEEDBACK & COMPLAINTS............................................. 14

STEP 3 - STAFF CAPACITY ............................................................................................................................. 17

STEP 4 - INFORMATION SHARING & AWARENESS RAISING ......................................................................... 18

STEP 5 - PROCESSING & RESPONDING TO FEEDBACK & COMPLAINTS ....................................................... 19

3. Roles and Responsibilities ............................................................................................................................ 23

3.1 Tdh Country Delegation ......................................................................................................................... 23

3.2 Quality and Accountability Sector .......................................................................................................... 23

3.3 Risk Management Sector ....................................................................................................................... 23

3.4 Transversal protection Sector ................................................................................................................ 24

3.5 Zones ...................................................................................................................................................... 24

List of Resources:.............................................................................................................................................. 25

List of Annexes ................................................................................................................................................. 27

Annex 1 : Glossary ........................................................................................................................................ 27

Annex 2 : Communication Tree .................................................................................................................... 29


1. Chapter 1 - Background Information 1.1 Reference Framework

Tdh and the Core Humanitarian Standard:

The Core Humanitarian Standard for Quality &

Accountability (CHS) sets out nine commitments that

organizations and individuals involved in development

and humanitarian interventions can use to improve the

quality and effectiveness of the assistance they provide.

The CHS places communities and people affected by crisis

at the center of development and humanitarian action. As

a core standard, the CHS describes the essential elements

of principled, accountable, and high-quality interventions.

The CHS is fully integrated with widely recognized industry

standards, notably the Sphere Handbook, the Minimum

Standards for Child Protection Humanitarian Action, and

the IASC Principles for Accountability towards Affected

Populations. The CHS is also central to the Grand Bargain

Commitments on Humanitarian Action.1

Tdh has adopted the CHS as its framework for quality & accountability. Adhering to the nine commitments

goes beyond any one policy or guidance. Accordingly, Tdh resources contributing to the nine commitments

are structured in a way to make those links with the CHS and link to each other.

Complaint & Feedback Response Mechanisms and the CHS

The application of this guidance is required to achieve CHS Commitment #4 Communities and people affected

by crisis know their rights and entitlements, have access to information and participate in decisions that affect

them and CHS Commitment #5: Communities and people affected by crisis have access to safe and responsive

mechanisms to handle complaints.

Complaint & Feedback Response Mechanisms and Tdh Engagements

This resource is directly linked to the Tdh Global Code of Conduct (GCC), which summarizes Tdh’s institutional

policies and rules and provides staff with a comprehensive framework that covers all forms of behavior or

action. The GCC applies to relationships between employees and relationships with beneficiaries, as well as

with the members of their communities. All staff and partners are required to strictly abide by the GCC.

Finally, this resource contributes to the standards for Switzerland’s ZEWO label and is complementary to

other Tdh policies that directly contribute to great Quality & Accountability, including: the Policy on the

1 Notably commitment 6.3: Strengthen local dialogue and harness technologies to support more agile, transparent but appropriately secure feedback


Protection from Sexual Exploitation and Abuse (link), the Child Safeguarding Policy and its “my commitment

to Child Safeguarding Annex (link), and the Tdh Policy on Gender and Diversity (Link).

1.2 Objectives

The present Guideline provides a comprehensive Response Mechanism that encompasses two distinct

components handled through two different processes.

- An operational feedback and complaint component

- A complaint component qualifying as a breach of the Global Code of Conduct

Together, these two components create one solid framework to ensure queries of any kind will be addressed

in the most suitable way and will improve accountability towards affected populations as well as all

stakeholders involved with Tdh.

Better responding to queries falling under the feedback component of the system will increase the level of

trust of affected populations and create a safe space when it comes to needing to address issues of a more

sensitive nature.

To be able to do so, all Tdh beneficiaries, delegations, as well as Tdh programs and headquarters, need to be

able to identify quickly and correctly the indicated pathway to address their queries or concerns. They need

to know what rights and obligations they hold when it comes to handling certain types of data and more importantly, they need to know what they can expect from the organizations when raising a particular issue.

In parallel, staff in charge of collecting and handling data need to know what role and responsibility they

have in this system.

1.3 Scope

➢ The “What”: what does include the guideline?

Anything on which Tdh has a direct influence on and control over it, as well as a direct legal link.

A few examples include:

- Programs and activities

- Staff and other stakeholders (volunteers,

consultants, etc.).

- Partners

- Direct suppliers

This response mechanism includes both

operational feedback and complaints , which can

encompass a series of interactions between

individuals Tdh works with and for (e.g.

individuals affected by a crisis, project actors,

partners). While both feedback and complaints

may be received through the same channels, they

will require different responses. The table below

highlights the classification of types of feedback

and complaints that can be received by Tdh.

A Feedback is an information provided by the affected

population or relevant stakeholders about a Tdh

intervention.

A Feedback, complaints and response mechanism relies on

a set of procedures and tools formally established and used

to 1) allow people concerned by Tdh intervention to provide

information on their experience related to our projects, 2)

acknowledges and analyses the information and 3) take

corrective action on the basis of this information and inform

people back (adapted from ALNAP-CDA, 2014).

A complaint is a grievance made by an individual(s) who

believes that a humanitarian agency has failed to meet a

stated commitment.

https://www.alnap.org/system/files/content/resource/files/main/closing-the-loop-alnap-cda-guidance.pdf


CATEGORY DESCRIPTION EXAMPLE Fe

edb

ack

(Op

era

tio

nal

) 0 Informative

interaction

• Request information about activities and services in areas covered by Tdh • Information provided by people about changes in context, emerging

needs or dynamics. • Expression of gratitude Example

- “What can be accessed where?” - “It would be useful to implement this activity - “There are security threats in this region”.

1 Request for Assistance

• Request additional or complementary help related to Tdh activities provided

Example - “I would like my child to benefit from your activities” - Case of domestic violence where Tdh’s staff is not responsible

(protection) - Case of child abuse (protection

2 Dissatisfaction with service delivery

• Lack of quality, communication or delay in service provision Example

- Delay in activities, or other issues related to an untimely response - Missing items in distribution kits - Lack of follow-up

- Discrimination in service provision

Co

mp

lain

ts (

vio

lati

on

s o

f th

e G

CC

)

3 Weak breach The physical impact as much as the psychological impact is low on the employees, beneficiaries, members of the community and third parties. • See matrix of gravity

Example

- Non-respectful conduct by staff - No or very low negative impact on operations and on the institution. - No legal/financial consequence for the author or the institution. - Breach of confidentiality - Breach of CM standards

4 Moderate breach

• Physical and/or psychological impacts are limited /minor wound/light psychological trauma).

• Minor repercussions on the operational implementation of the project.

Legal risk for the author and the institution are low. • See matrix of gravity.

5 Serious breach

Important physical and or psychological impact Important impact on operation implementation expected. • An important legal risk is identified for the perpetrator and the incident

might pose a danger for the institution. • See matrix of gravity.

6 Critical breach • Critical physical and/or psychological impact (death, kidnapping, rape, sexual exploitation...) Operations can be cancelled.

• High legal and/or reputational risk for the organization. • See matrix of gravity.

Oth

er

7 N/A Feedback or Complaints Relating not directly related to Tdh or its interventions

• Incidents of protection committed by members of the community, which should be referred to the relevant agency or department within Tdh.

• Actions committed by staff or parties involved with other agencies, which should be referred to the relevant agency.

➢ What doesn’t include the guideline?


- Safety and security incidents, which should be handled following

the regular hierarchy communication lines – see annex (Tdh

Communication tree).

- Disagreement over policy or management decisions. Such

disagreements should be handled following the regular hierarchy

communication lines.

- Personnel issues where staff have a personal interest in the

outcome

- Feedback and complaints for which a response has already been

provided and is available in the public domain

➢ Whom does it concern?

Tdh will accept feedback and complaints from any individual or other entity as long as it is submitted in good

faith and without malicious intent.2 Parties raising complaints about Tdh may include, but are not limited to:

- Individuals volunteering or under contract with Tdh (i.e. staff, interns, volunteers, consultants)

- Partner organizations

- Individuals officially representing a partner organization

- Any individual member of staff of a partner organization

- Children and other beneficiaries of Tdh-funded activities

- Other stakeholders in Tdh areas of intervention, including members of the community, local leaders,

government representatives, representatives of other NGOs.

Tdh will accept anonymous complaints recognizing that complaints may be legitimate and the complainant

may have good reasons as to why they do not want to disclose their identity. In order to conduct a preliminary

review of anonymous complaints, enough independent data to corroborate the information needs to be

available.

➢ When? Is there a specific time limit for feedbacks and complaints?

Tdh doesn’t set a specific limit in terms of internal statute of limitation, bearing in mind that the concerned

intervention might no longer exist and the longer it takes to raise an issue, the more difficult it will be to

address it. Please also keep in mind that there is normally a statute of limitations on offenses in most of

national legal systems.

➢ Special considerations on malicious reporting

Any employee who falsely reports a breach to harm us or another employee may be reported to the relevant

authority and/or face disciplinary measures, according to relevant national laws and Tdh policies.

1.5 Guiding Principles

2 Bad faith and malicious reporting could constitute a violation of the global code of conduct and will be dealt with according to the appropriate operational and legal context.

Caution:

Feedback and complaints that

may initially match these

descriptions could in some cases

still need to be addressed. When

in doubt, process the feedback or

complaint.

For example, a staff might have a

personal interest in the outcome

or be in disagreement with a

management decision, but still

have a valid complaint.


To ensure that a feedback and complaints mechanism is effective, trusted and therefore used depends

on the following key principles:

➢ The obligation to report suspected breaches of the Global Code of Conduct for Tdh’s staff, regardless of their contractual modalities, partners or suppliers

As stated in Tdh’s Global Code of Conduct, there is a duty to report all suspicions of a breach of the same

code. Individuals who report such cases in good faith are entitled to protection against retaliation in

accordance with the provisions of this policy. Whistleblowers internal to Tdh will be protected. Under no

circumstances will they be dismissed, demoted or discriminated against for reporting in good faith a breach

of one of the principles stated in the Global Code of Conduct.

➢ Accessibility

An effective mechanism must be accessible to all individuals within a stakeholder group in the intervention area, regardless of their age, gender, or diversity. Stakeholder consultations will help identify the most appropriate modalities for receiving feedback and complaints, appropriate for the local context. However, it is still important to consider what barriers may exist and the set-up alternative/targeted arrangement for population groups that cannot access the CFRM.

Developing a Child-friendly mechanism Tdh is the leading Swiss organization for children’s aid and provides aid for over 3 million children and their relatives each year. Our programs and projects target children’s rights and their best interests. The Participation of Children is a right enshrined in Article 12 of the Convention on the Rights of the Child. It is therefore only logical that our mechanisms would specifically target children in a way that is both age and culturally appropriate.


➢ Participation and Empowerment

People have a right to have their voices heard in judging the quality of our intervention and whether / how

we are contributing to sustainable changes in their lives. Asking for the views of the people is our

responsibility and will help us understand the difference we are making during the course of the response,

and timely adapt our intervention.

This guideline presents the comprehensive framework for handling feedback and complaints, but unless the users of the mechanism are included in the process of design and implementation of such, in any

context, it is unlikely that it will be used. A successful and effective mechanism will only be achieved if it is developed in a highly participatory way with representatives from all stakeholder groups and if it is integrated into program activities, through appropriate methodologies, communication tools and channels.

3 Child Protection Good Practice Framework. A guide to promoting quality child protection programming across all standards. 4 Tdh, Using focus groups discussions with children and adolescents. A practical guide for maximizing their effectiveness, 2019 5 Ibidem, p. 17.

The CRC and Humanitarian standard and practice clearly underlines the importance of having mechanisms in place that allow the voices of children to be heard and for them to be involved in decision-making by providing feedback. It is however recognized that accessing such mechanisms is often difficult for children. In spite of a lack of available data, key elements to take into account when developing a child-friendly mechanism (and actually not limited to children) include age and gender, literacy and language, disability, culture, status, etc. Any mechanism should be established considering Tdh general principles for child participation3. Other relevant advice includes the following:

➢ Include children in the design of communication

material and work with them to develop their own version of the Global Code of Conduct and Commitment to Child Safeguarding.

➢ Use appropriate methods to engage children for collecting their feedback (games, radio shows, puppet shows, colorful leaflets and comics, songs, paintwork, focus groups with child-friendly techniques4, awareness festival, billboards, etc.). Involve staff members who have suitable experience and confidence in facilitating consultations with children, and who is skilled in communicating with children.

➢ Share information about the existence of a mechanism from the beginning of an activity and raise awareness on the importance of children to express what they feel or want5.

➢ Perhaps even more importantly than for adults, make sure you acknowledge the importance of

the information shared by the child and reassure the child on confidentiality

Explain what the objectives of collecting their views are, in a way that is understandable to them, make sure that you get their informed consent in addition to their parents.

Tdh Principles on child participation.

Participation :

1. Is ensured by professionals having the

minimum required competencies

2. Is Safe

3. Reflects both individual and collective

participation

4. Is inclusive

5. Is a process and not as one-off event

6. Developmentally appropriate, gender

sensitive and culturally relevant

7. Done in ways to support and contribute

to other important aspects of children’s

wellbeing, development and life skills

8. The purpose is clear and relevant for

children

9. Information is provided in appropriate

and meaningful ways

10. Is voluntary


Establishing a participatory and efficient mechanism will entail that we engage in genuine empowerment process.

➢ Do no harm and Best interests

All interventions should avoid causing harm as a result of its actions or inactions. Harm includes physical or psychological harm to individuals or groups, as well as harm to the environment (economic, social, political, climate, etc.) that might otherwise affect individuals or groups. CFRMs are an essential part of continuous monitoring and analysis to track potential risks arising in an area of intervention. In the same line all actions taken and decisions made should always be centered on what is the children best interest, in accordance

with the Convention on the Rights of the Child.

➢ Impact oriented management

Tdh does not implement interventions for the sake of implementing projects, but to contribute to sustainable changes in the lives of the children, their families and communities. Establishing a feedback, complaints and response mechanism is consistent with the Result Based Approach and is connected to the

broader Project Cycle Management methodology. It is generally embedded in a broader project Monitoring and Evaluation framework, which will collect, analyze and use information about the project quality, context, outputs, outcomes and impact. It must contribute to the purpose of project steering, by enabling the teams to take corrective action, improve our intervention and contribute to positive impact for the communities.

➢ Safety & Dignity

A safe mechanism will consider potential physical and psychological dangers and risks to all parties involved in each process, including Tdh staff and partner staff, complainant, witnesses, author and other parties involved. The mechanism should be designed to incorporate ways to prevent reprisals, harassment, injury or harm to those wishing to raise an issue or complain. Tdh will do its upmost to ensure confidentiality, providing physical protection and psychological assistance if necessary and when possible, and to address the possibility of retaliation against those wishing to raise concerns or stand in witness.

➢ Confidentiality6

Confidentiality helps create a safe space in which people are more likely to raise concerns, complain or stand in witness to bad practice or incidents of abuse. People might not raise concerns or complaints if they are in fear of reprisal of retaliation from Tdh or partner staff or other community members or any other stakeholder in doing so. Confidentiality assures that any information given is restricted to a limited number of people on a need to know basis and that it is not disseminated wider, therefore offering an element of protection and security to the complainant.

In a way to ensure confidentiality, Tdh employees acknowledge the confidential nature of the information they receive and undertakes to keep absolute secrecy over all documents transmitted during whistleblowing procedure. Under no circumstances may the information transmitted by the issuing individuals be used for any purpose other than that specified in the reference of this document.

➢ Transparency

An efficient mechanism is one that is widely known by all relevant stakeholders, who should know its

purpose, the way to access it and what to expect. Information about a complaint mechanism should be freely available and people with concerns should be able to speak regularly and openly to Tdh or partner staff about the operation of the mechanism itself. Mechanisms need to be in place so that a response can be provided to the individual or other entity submitting the feedback/complaint. Tdh must make clear who is responsible for handling complaints and communicating outcomes in any situation, be it Tdh staff directly or partner staff.

6 For further guidance on confidentiality, see annex 1.


➢ Timeliness

Timeliness of reporting and related follow-up measures must be ensured.

➢ Documentation

The importance of objective, reliable documentation is critical. For any complaint in violation of the GCC, an incident report will be saved in a secure database.

1.6 Specific Considerations on Safety and Protection Concerns

Protection of the parties involved in a case As stated at the beginning of the present guideline, safety and protection are paramount to when it comes

to ensuring a good complaint and feedback response procedure. Especially for cases qualified as breaches of

the Global Code of Conduct, remedies to face potential dangers must be anticipated through a risk

assessment and limits to how we are able to respond to a case identified as early as possible in the process.

A survivor-centered approach7 The way we respond to a case of safeguarding will not only need to ensure the safety of the victim/survivor,

but also that we base our actions on a survivor-centered approach. The following principles should be kept

in mind when dealing with a sensitive case, especially with a case of sexual and gender-based violence: 1.

Consent 2. Confidentiality 3. Safety 4. Respect 5. Non-discrimination. - Does the Complainant need and want

medical assistance or has s/he sought treatment and, if so, where and from whom? - Which other services

has the Complainant already received assistance from or would need help accessing? - Who is responsible

for ensuring a safety plan for the Complainant? - Describe any security measures put in place for the

Complainant - Describe any referrals and advice about assistance, provided to the Complainant, including

health, psychosocial, police and safe house.

Protection of whistleblowers and witnesses in the organization Tdh has a duty of care to safeguard the interests of and protect whistleblowers and witnesses from retaliation

at any time form the moment the whistleblower comes forward. Protection measures are recommended

with the consent of the involved parties and can include without being limited to the:

- Temporary reassignment

- Transfer to another office or function for which the whistleblower is qualified;

- Placement on special leave with full pay; or

- Any other appropriate action on a case-by-base basis, including security measures

- To keep anonymous the whistleblowers and witnesses while and after processing the case?

Particular care will be taken during staff performance appraisals, vacancy selections and reassignments to

ensure that whistleblowers and witnesses suffer no adverse consequences in connection with their original

report of a breach of the GCC.

In cases where a whistleblower or witness fears that the relationship with their supervisors may not be

conducive to a meaningful performance appraisal, extraordinary measures can be taken by Human

7 See PSEA p. 6 and GCC p. 6.


Resources, such as appointing a new or additional supervisor or requesting senior management to conduct

the review directly.

Protection of whistleblowers and witnesses outside of the organization Tdh will take all appropriate measures in order to ensure the safety of whistleblowers and witnesses

outside of the organization, within the scope of its power.

Temporary measures taken against an alleged perpetrator

When it is considered that continued performance of the alleged perpetrator employed by Tdh is likely to

prejudice the interests of the organization, the staff member may be placed on administrative leave pending

a conclusion of the internal process. Such administrative leave may be with, or exceptionally without pay, in

accordance with relevant labor law.

Data protection considerations for personal data8 Data protection is the process of safeguarding important information from corruption, compromise or loss. Rules dictating best practices in data protection should always be a balance between the two fundamental human rights: the right to a private life and the right to freedom of expression.

Data collection planning

Ensure all data collection processes apply the principle of data minimization (data are adequate, relevant and not excessive for the purposes for which it is collected). The tool or instrument used for data collection must be appropriate in respect of age, gender, ethical and cultural norms and needs to be approved by the Q&A team. Child friendly, participatory tools are required for use with children. The tools need to allow the application of the data subjects9 rights (right of access, right to rectification, right to erasure, right to restriction of processing, right to object the processing, right to portability, right to not be subject to automated processing).

During the collecting

The whistleblowers and witness need to get the information about:

- Their rights regarding their own personal data

- Where they can apply those rights (an email address?)

- Identity of the person(s) who will access to their data

- The intention to transfer the data to another country or party (partners?)

- The storage periods (the data must be stored for the shortest time possible)

If the data subject is a child, the information will be given to him or her in a way that he or she will perfectly

understand it.

8 Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural

person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification

number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic,

cultural or social identity of that natural person. Depending on the context other information could also be considered Personal data

(identifiable information). 9 adult or child whose personal data is subject to processing


Tdh implement appropriate technical and organizational measures to ensure the application of the

whistleblowers and witness rights on their personal data and can demonstrate that the processing is

performed in accordance with the national law on data protection.

Concerning the personal data of the accused, Tdh will decide based on a balance of his or her best interest

and the whistleblowers and witness whether it will inform the processing of his or her data in the case in

question. If there is no reason to not informed the accused, Tdh will notify him or her on the information

mentioned above.

The application of the rights will always be decided in function of the best interest of the individuals

concerned and Tdh in the context affected.

Security

Tdh take appropriate physical, organizational and technical security measures to protect the personal data

transmitted during the whistleblowing procedure against the unauthorized use, dissemination or

publication, loss misuse, access, disclosure, processing, alteration and accidental destruction or unauthorized

use:

- All the personal data concerning the Complaint and Feedback Response Mechanism are stored on

an internal server or at least on a server based in EU

- Any hardcopies of data collected needs to be processed and converted to within 48 hours, and both

the hard and softcopies must be stored securely

- All electronic personal data must be password protected, and the password changed on a regular

basis. Information should be transferred by encrypted or password protected files whether this is by

internet or memory sticks. Memory sticks (USBs) should be passed by hand between people

responsible for the information and be password protected, and the file erased immediately after

transfer. Ensure that the file is also permanently erased from the recycle bin file of your computer.

Emails containing personal data regarding a case must be encrypted too.

- All hard copies containing personal information should always be concealed and stored in a lockable

filling cabinet. The rooms containing paper or electronic information must be kept securely locked

when the person responsible for the information leaves the room.

- All tools used must guarantee the security of the data processed

- All the personal data processed in the aim of the whistleblowing procedure must be deleted when

no longer needed or must be anonymize

- Personal data that could lead to any risk of beneficiaries or employees or any other individuals should

be encrypted or anonymized, whenever the data source is transferred.

Data protection is directly related to security. It is in the best interest of the whistleblowers and witness

because it prevents the misuse of information about them for purposes beyond their control, including for

purposes that could lead to their exploitation, stigmatization and abuse – either intentionally or

unintentionally. It also helps to ensure that their views and opinions are heard and respected at all steps of

Tdh work.

13

2. Chapter 2 - Practical “How-to” Guidance

This practical section highlights 5 key steps to guide the design and the implementation of a CRFM. Each step

includes a section on methodology, Tdh Resources available to apply said methodology, and Additional

References illustrating good practice.

STEP 1 - DEFINE THE PURPOSE AND SCOPE

Methodology: Before beginning a discussion on the mechanisms for receiving feedback and complaints, it is important to clarify

the scope of what the mechanism will cover. This could just be a matter of confirming the scope as described in

Section 1.3. However, it is still important to review and discuss these categories and other factors to confirm the

scope. For example:

1. What types of feedback & complaints will be received or not received? (see resource 1.1)

2. Who should be able to access the CFRM?

3. Will the CFRM cover one project? All Tdh interventions?

4. Are there any existing CFRMs setup by peers, inter-agency mechanisms, or other stakeholders? If yes, it

is important to consider how the Tdh CFRM will work in coordination with those and how duplication

can be avoided.

5. How the CFRM is connected to the wider M&E system of the delegation

/ projects (see resource 1.2)

Tdh Resources:

# Resource Description

1.1 Categories of Feedback & Complaints This document captures all the default categories of feedback and complaints that would be received through.

1.2 M&E planning template This document guides the teams for undertaking M&E

planning from the definition of the scope and objective of the monitoring system to practical tools that support M&E management. The CFRM must form part of all M&E plans

1. DefinePurpose and scope

2. Choose Modality for receiving feedback & complaints

3. Ensure staff capacity

4. Information sharing and awareness

5. Processing & responding to feedback and

complaints

Caution

The CFRM must form part

of all M&E systems!

14

STEP 2 - DEFINE THE MODALITY FOR RECEIVING FEEDBACK & COMPLAINTS

Methodology:

There are multiple possible methods, channels and tools that can be used to gather feedback as part of a CFRM.

The most commonly used are however not always the most efficient! The chosen modalities should ensure

inclusive communication, promote two-way communication, and not be exclusively oriented toward “extracting”

information from people. Modalities can be both passive (i.e. where the information comes to Tdh) and active

(i.e. where Tdh seeks out information from stakeholders):

Passive Modalities:

• Boxes (for suggestions, feedback, complaints)

• Telephone Hotlines & SMS

• Feedback Desks

• Open-door policies

• Email

• Ad-hoc informal discussions

Pro-active Modalities

• Focus Group Discussions,

• Key Informant Interviews,

• Community Consultations

• Surveys

• Participatory Monitoring Activities (e.g. Post Distribution Monitoring)

• Ad-hoc informal discussions

In order to identify what modalities work, it is essential to consult the relevant stakeholders through pro-active

modalities. This will give a good indication of the preferred modality that is accessible to the majority of the

population. The modalities can be also established with different degrees of formalism. In certain

circumstances, informal discussions are very important to reach the relevant stakeholders, a good balance of

informal-formal approaches is key. Consulting children requires child-friendly methods (see Resource 2.4)

However, it is important to go a step further and consider who might not be able to access the CFRM and what

risks it might entail. This is important because those individuals are groups could very well be the most

vulnerable or marginalized, and consequently be most at risk of rights violations.

This can be achieved by:

1. Analyzing the demographic makeup of the intervention are and making a list of beneficiaries and other

stakeholders who could use the CFRM

2. Conducting follow-up consultations with potentially vulnerable or marginalized groups (e.g. persons with

disabilities, ethnic minorities)

3. Consulting the Tdh list of advantages and disadvantages common feedback channels (Resource 2.1).

4. Reviewing preferred modalities in light of the guiding principles (see section 1.5). All guiding principles

should be considered, but two are especially important:

15

CAUTION: It is important to use several different modalities and connect the feedback mechanism to the

broader M&E system, in order to ensure all individuals and groups are able to access them, and that all

categories of feedback or complaints can be submitted in a manner that respects the safety and the dignity of

the individuals or groups concerned.

- For example: In the context of distributions, this would involve multi-level monitoring activities:

o During the distribution: information desk, face-to-face discussion

o Immediately after the distribution: FGD to understand perception of the quality and relevance

o Longer after the distribution: household surveys, FGDs to understand the longer-term effects

DO NOT:

- Label complaint feedback and complaint boxes with a specific type or category of feedback/complaint:

Meaningful access : Who is able to access the CFRM and what barriers might be preventing other

individuals or groups?

Safety & Dignity: If it is not safe or dignified to use the CFRM. Physical: If the CFRM is too far (i.e. distance), or inaccessible for the chronically ill or persons

with disabilities. Education: If the CFRM requires writing or reading, in an area where the level of education is

low. Gender: If the CFRM requires a cell phone, in an area where women don’t have access to

cellular phones. Age: (see Child-Friendly Mechanism Box. Section 1.5) Discrimination: If the CFRM is handled by an individual or groups who discriminate against

other individuals or groups (e.g. based on ethnicity, religion, sexual orientation, sex, age, political background, etc.).

Financial: If it is required to pay transport costs to reach the CFRM. Culture/Tradition/Religion: If submitting a complaint goes against a cultural practice or belief.

Safety & dignity : Does accessing or using the CFRM put individuals at physical or psychological risk?

Examples:

A FGD does not ensure confidentiality, so cannot be used for collecting individual and sensitive information a complaint about sexual exploitation or abuse in an FGD would put the individual at risk of relation by the perpetrator.

If providing feedback or complaints is culturally frowned upon, passive modalities might not respect the dignity of the stakeholders.

If a suggestion box is labeled “PSEA”, everyone can know that the person submitting a note is likely to be a victim or is in some way related to a case of PSEA.

Whenever confidentiality is not ensured, there is the potential for the concerned stakeholder to be exposed and their safety or dignity threatened.

16

Special note on violations of the GCC:

➢ Normal supervisory line In order to honor their duty to report potential breaches of the GCC, individuals who suspect such a breach and who are not concerned that their supervisor may be involved, nor fear for retaliation, should inform either their direct supervisor through their normal supervisory line, the Country Repetitive, or the relevant Focal Point. In all cases, supervisors or managers who receive a report of a suspected breach of the GCC must act to address it fully and promptly and liaise as soon as possible with the Country Representative and/or the Focal Point.

➢ Concern e-mail address If there is a loss of trust, fear for someone’s safety, or any conflict of interest, using the email address [email protected] allows any party to bypass the hierarchical line and guarantees the confidentiality and safety of all parties. This e-mail address is under the sole responsibility of the internal case manager and the head of the risks sector.

➢ Security number

For urgent security matters, the number + 41 58 611 06 00 should be reached. Please note that charges will apply.

Referrals: Section 1.3 describes actions that fall out of the scope of the CFRM, including feedback or complaints outside the influence of Tdh. Regardless of the limits of the CFRM, Tdh staff will almost certainly at one point be confronted to a case that needs to be referred either to an external actor or a department of Tdh with the capacity to deal with the issue. In order to prepare for this eventuality, it is helpful to be ready with a list of potential referral services/organizations. See Resource 2.3 for a template.

Tdh Resources:

# Resource Description

2.1 Advantages and disadvantages of common Feedback channels

17

2.2 Referral Contacts Template Template for listing services to which individuals or groups can be referred to when service is not available within Tdh.

2.3 Inter-Agency Referral for Case

Management Form Pre%20final%20refe

rral%20form%20for%20CM.docx

2.4 Focus Group Discussions with Children

190409 Technical

Note FDG with children - Final draft_PDF.pdf

External Resources: ALNAP- CDA. Closing the loop. Effective feedback in humanitarian contexts Practitioner Guidance

IASC AAP Task Team - Best Practice Guide Inter-Agency Community-Based Complaint Mechanisms -

Protection against Sexual Exploitation and Abuse (Page 51 – Creating Safe & Accessible Reporting

Channels)

Interagency Study on Child-Friendly Feedback and Complaint Mechanisms within NGO Programmes

SAVE - listening to communities in insecure environments, 2016.

STEP 3 - STAFF CAPACITY

Methodology: Tdh staff need to have the capacity to manage the CFRM. There are two aspects to consider (Core Competencies

& Training):

1. Core Competencies

This should be sought during recruitment and monitored through regular performance evaluation, and

General10

- Solicits and listens to feedback and others’ perspectives:

o Listening skills: Actively listens to others’ ideas and viewpoints

o Curiosity: Stays interested in and seeks out others’ ideas and values others’ perspectives. Learns

from the beneficiaries.

o Facilitation skills: Guides discussions and encourages others to share their opinions and gain

clarity in their ideas. Giving feedback is not easy.

o Inclusiveness: Works with colleagues, partners and beneficiaries from diverse backgrounds and

levels of seniority. Gives equitable treatment to different people’s viewpoints.

o Culturally sensitive: Adjusts ways of communicating and interacting according to the context and

literacy level; is aware of existing power structures in the community and acts in an appropriate

manner that does not reinforce them.

o Gender & Diversity Sensitive: Is aware of biases and considers how these might impact

interaction with beneficiaries or other stakeholders.

10 Adapted from IRC’s Client Responsivness – Staff Management Guide. Further details on how to measure the core competencies included in the full guide.

https://www.cdacollaborative.org/publication/closing-the-loop-effective-feedback-in-humanitarian-contexts-practitioner-guidance/

http://www.pseataskforce.org/uploads/tools/1490964201.pdf

http://www.pseataskforce.org/uploads/tools/1490964201.pdf

https://www.wvi.org/sites/default/files/Child%20friendly%20feedback%20mechanisms%20report.pdf

https://www.gppi.net/media/SAVE__2016__Listening_to_communities_in_insecure_environments.pdf

https://www.rescue.org/resource/guide-client-responsive-staff-management

18

o Capacity to acknowledge and manage/mitigate their own bias

- Responds to feedbacks with maturity and sensitivity:

o Empathy: Possesses a willingness to relate to others’ perspectives; is open-minded when

receiving criticism or listening to others’ frustrations.

o Optimism: Stays positive in the face of criticism and what may be unreasonable or unrealistic

demands.

o Humility: Reflects on personal behavior, capacity and practice.

- Take appropriate decisions and make changes to behavior or actions in response to feedback:

o Learning and adaptation: Seeks to be capable of and works towards change and improvement

based on feedback and learning.

o Accountability: Holds themselves and others accountable for their decisions and actions.

- Confidentiality:

o Upholds the highest standards of confidentiality and privacy, respecting procedures for handling

feedback and complaints.

Safeguarding Focal Points

- See Responsibilities of the Safeguarding Focal Point (Resource 3.1)

2. Training:

Staff should be trained for the modality chosen for receiving feedback and complaints (see Step 2) and the

procedure for handling the feedback and complaints (Steps 6 & 7), including all required confidentiality measures.

In addition to this, staff should be sensitive to Gender & Diversity, and ideally have gone through the Gender &

Diversity 101 training of Tdh (see Resource 3.3).

Tdh Resources:

# Resources Description

3.1 Roles and Responsibilities of the Safeguarding Focal Point

List of recommended criteria to select a Focal Point who should be able to play an active role throughout all the axes of the safeguarding policies – Community Engagement, Prevention, Response and Coordination.

3.3 Gender & Diversity 101 Half-Day introduction to core concepts and terminology of Gender & Diversity in Tdh, as well as the commitments taken onboard by the organization.

External Resources: IRC - A Guide for Client Responsive Staff Management

STEP 4 - INFORMATION SHARING & AWARENESS RAISING

Methodology: The best CFRM modalities are useless if the affected population and relevant stakeholders do not know of their

existence. It is essential to conduct and awareness raising campaign to inform beneficiaries and other

stakeholders of:

1. The existence & goals of the CFRM

2. The modalities for receiving feedback or complaints (& how to use them)

https://www.rescue.org/resource/guide-client-responsive-staff-management

19

3. How responses will be provided

Note: Awareness raising will also be a good opportunity to solicit initial feedback on the chosen modalities. Be

ready to revisit Step 2 if any gaps appear at this stage.

CAUTION: It is essential to raise awareness about the CFRM and how it functions. However, awareness raising

will also create expectations. It is imperative when providing this information to be prepared to fully follow

through with the implementation of he CFRM. Failing to meet these expectations would have detrimental

effects and go against the guiding principles.

External Resources: ALNAP-CDA - Closing the Loop. Effective feedback in humanitarian context., page 25

STEP 5 - PROCESSING & RESPONDING TO FEEDBACK & COMPLAINTS

Methodology:

Sorting of Received Feedback & Complaints

Whatever the modality, Tdh will not be able to control what comes through. A feedback or complaint might fall

into any of the categories described in Section 1.3. Staff receiving or reading initial complaints should have been

trained on confidentiality procedures and be aware of the process below in order to appropriately handle the

information.

Operational Feedback (Categories 0-2)

Category 0 – Information Request or Giving of Information

Key Actions:

Information Received Directly (e.g. in-person, on the phone, FGD)

Information Received Indirectly (e.g. suggestion box)

1 Provide information response on the spot.

If Tdh is being given information, acknowledge information reception.

If the specific individual or group is known, contact them directly to provide information. If specific individual or group

is not known, include provide the information through a public information activity (e.g. community sensitization)

2 Log Information (see Resource 5.3)

Timeline: Immediate if possible, 1 Month if feedback is provided indirectly

Category 1 – Service Request

Key Actions:

Information Received Directly Information Received Indirectly

1 Request basic information about where, type of problem,

geographical zone, how to get back in touch. Inform them of when you will be back in touch.

2 If service requested is provided by Tdh, refer the individual to the relevant service.

3 If it is a protection issue (e.g. violence, abuse, exploitation, and neglect) that Tdh does not have internal

capacity to deal with, refer the individual to external services (see Resource 5.2)

4 Log Information (Open)

20

5 Follow-up that the case has been handled.

6 Contact the individual to provide follow-up information If contact information is available, contact

the person directly. If not contact information is available, see next step.

7 If Tdh is receiving multiple requests of the same type or in the event that it is not possible to follow-up

individually, conduct a public information activity to inform the population of the type of requests being received and whether or not Tdh can respond.

8 Log Information (Close)

Timeline: 1 week if individual contact information is available, 1 month if public information activity is required.

Category 2 – Dissatisfaction with Service Delivery

Key Actions:

Information Received Directly Information Received Indirectly

1 Request basic information about where, type of problem, geographical zone, how

to get in touch.

2 Log Information (Open)

3 Contact the Tdh lead for the service concerned and request information on this case.

4 If information is inaccurate, skip to step 6

5

If information is accurate, request from the Tdh lead a response. Responses can fall into two categories11:

(1) Practice Change: An acknowledgement of the validity of the complaint, a demonstrable change of Tdh or partner practice in the future, and reassurance to the complainant that there is a change in practice. Examples: Erroneous/misleading information in a campaign or advocacy message. Poor staff attitude and behavior in contact with partner, community. Unintentional misinformation or lack of information about eligibility for a service or goods distributed.

(2) Making Good: Repairing/replacing the damage or omission. “Re-doing” the activity correctly or providing and adequate substitute. i.e. ‘making good’ to the complainant(s). Examples: Constructed facilities fail to meet their stated design criteria due to use of poor quality materials. Listed beneficiaries fail to receive goods/services of an appropriate quality.

6 Contact the individual to provide follow-up

information

If the specific individual or group is known, contact them directly to provide information. If specific individual or group

is now know, include provide the information through a public information activity (e.g. community sensitization)

7 Log Information (Close)

Timeline: 1 Month

Violations of the GCC (Categories 3-6)

Category

Action Who Timeline

11 Adapted from CAFOD Complaints Handling Policy and Procedures

21

3 - Acknowledge reception and thank the person who lodges

the complaint.

If the case is reported by an alleged survivor/victim: - Take all relevant remedies in order to make sure that the

person is okay and always keep in mind the well-being and

best interests of the person.

- Request basic information about where, type of problem,

geographical zone, how to get in touch with all parties

involved and log the complaint template used at field

level or the excel incident report form.

- Log the request through the Excel incident report form12

- Transmit the incident form to the relevant Focal Point and

Country Delegate, which should then be sent to the head

of the zone/desk and the risks management sector.

- The Focal Point or yourself should make sure the person

is re-contacted to provide follow-up on the case within

the limits of confidentiality.

Incident managed at base level Information sent to HQ (zone/desk + risks).

First contact established with whistleblower or victim (72h) Preliminary analysis (5 days) Decision (Within 3 months)

4 For cases of integrity, or cases that do not generate an impact on the safety or security of a party, follow the same procedure as for incidents considered as weak.

For cases involving a victim/survivor, please follow the following procedure: - Acknowledge reception and thank the person who lodges

the complaint.

- Take all relevant remedies in order to make sure that the

person is okay and always keep in mind the well-being and

best interests of the person.





- Reach out to the Focal Point or country representative as

early as possible for further guidance on how to

accompany the survivor/victim.

- Log the request through the Excel incident report form.







- The actions taken to protect and assist the

victim/survivor, should be carefully monitored.

- See “external resources” below for list of actions to take

and not to take in case of GBV.

Incident managed at local level with support from HQ. Information sent to HQ (zone/desk + risks). Case management protocol can be activated if reprehensible behavior identified.


12 See hereby attached

22

5 For cases that do not generate an impact on the safety or security of a party, follow the same procedure as for incidents considered as weak.

- Reach out as soon as possible to the Focal Point or the

Country delegate

- See SOP on Victim’s assistance





- Log the request through the Excel incident report form.







- The actions taken to protect and assist the

victim/survivor, should be carefully monitored.

Incident cannot be managed only at local level. HQ support is necessary (zone/desk + Risks). Case management protocol is activated in case of reprehensible behavior identified.


6 - Reach out as soon as possible to the Country

representative

- See crisis management plan

Incident cannot be managed at local level.

HQ intervention is necessary (zone/desk + Risks)

Crisis management plan is activated.

ASAP

Feedback or Complaints Relating not directly related to Tdh or its interventions (Category 7)

Incidents of protection committed by members of the community or parties external to Tdh (including peer

organisations) should be referred to a competent external actor or department within Tdh using the Tdh Referral

form (see Resource 6.2). Referrals need to be conducted with the consent of the party involved.

Tdh Resources:

# Resources Description / Link

5.1 Processus de gestion de cas

Processus gestion

de cas V0.18_cam.xlsx

5.2 Tdh Referral Form

Pre%20final%20refe


23

5.3 Tdh Database Template

Copie%20de%20CR

FM%20Database_v1.xlsx 5.4 Informed Consent & Children

Informed%20conse

nt%20and%20children.docx 5.5 Incident Report Template

Incident

report_en_V2.0.xlsx 5.6 Confidentiality Guidance for

breaches of the GCC Annex%20confiden

tiality.docx

5.7 Data protection starter kit : - SoP : working

collaboratively on sensitive document

- Sharing sensitive data internally and externally

- How to encrypt sensitive data

3.06. (version 0)

_SOP_template_Working collaboratively on sensitive documents.pdf

3.05. (version 0)

_SOP_template_Sharing of sensitive data internally and externally.pdf

2.03. (version 0)

Tutorial_How to Encrypt Files and Folders that contain sensitive data.pdf

External Resources: CAFOD - Complaints Handling Policy and Procedures for International Programmes

Global Protection Cluster – Protection Mainstreaming Toolkit – Annex 4 (Protection Cases Referral)

GBV Pocket Guide (Dos and Do Nots!)

3. Roles and Responsibilities

3.1 Tdh Country Delegation Each Country Delegate is responsible for ensuring that CFRMs are in place covering the entirety of Tdhs

interventions. The responsibility for setting up a CFRM lies with the Country Delegate, who may delegate this

responsibility to the M&E Lead and/or Safeguarding Focal point. The CFRM lead is responsible for establishing

one or more CFRMs according to the guidance in this document. Further support can be obtained from HQ

through the Quality & Accountability Unit or the Risk Management Sector.

3.2 Quality and Accountability Sector The Quality & Accountability Unit maintains the Project Cycle Management approach of Tdh, and as such is

responsible for ensuring CFRMs effectively link back to the project cycle. The Q&A Unit provides Job Descriptions

and Onboarding guidance for M&E staff that include roles and responsibilities with regards to CFRMS. Finally,

the Q&A Unit provides support on conducting evaluations, which should systematically look at the effectiveness,

appropriateness and efficiency of CFRMs.

3.3 Risk Management Sector The Risk Management Sector is responsible for disseminating and communicating the GCC and the Risks policies (CSP, PSEA, DMWP and Fraud). It ensures that the tools and mechanisms that comply with best practice are developed and disseminated and supports teams in adapting them for the field. It also assists operations in setting up and monitoring the implementation of tools, mechanisms and policy. The Risk Management Sector plays a key role in preventing cases of breach of the GCC at headquarters and in the field.

https://www.alnap.org/system/files/content/resource/files/main/cafod-complaints-handling-policy-en.pdf

https://gbvguidelines.org/wp/wp-content/uploads/2018/03/GBV_PocketGuide021718.pdf

24

The risks management is responsible of the storage of all cases of breach of the GCC through a secure database and guarantees institutional memory of past breaches.

3.4 Transversal protection Sector The transversal Protection Sector is responsible to develop guidance and provide technical support to strengthen protection response, including Case Management practices and solutions. The sector provides opportunities for capacity developments, develop Case management toolbox and packaging online, and is involved in sector strategic discussion around the topic. Protection Staff have key responsibilities regarding complaints and feedback that relate to protection cases and may be involved in CFRM management according to their category/type.

3.5 Zones Are responsible to ensure that one CFRM per project is designed and implemented in full compliance with the present procedure.

January 2019 - Version 0.1 – SOP CFRM Risk Management Sector and Quality and Accountability Unit

List of Resources: # Resource Description / Link

Step 1 – Define the Purpose & Scope

1.1 Categories of Feedback & Complaints

This document captures all the default categories of feedback and complaints that would be received

through.

1.2 M&E planning template This document guides the teams for undertaking M&E planning from the definition of the scope and objective of the monitoring system to practical tools that support M&E management. The CFRM must form part of all M&E plans

1.1 Categories of Feedback &

Complaints This document captures all the default categories of feedback and complaints that would be received through

1.2 M&E planning template This document guides the teams for undertaking M&E

planning from the definition of the scope and objective of the monitoring system to practical tools that support M&E management

Step 2 – Define the Modality for Receiving Feedback & Complaints

2.1 Advantages and disadvantages of common Feedback channels

2.2 Referral Contacts Template Template for listing services to which individuals or

groups can be referred to when service is not

available within Tdh. 2.3 Inter-Agency Referral for Case

Management Form Pre%20final%20refe


2.4 Focus Group Discussions with Children

190409 Technical

Note FDG with children - Final draft_PDF.pdf

Step 3 – Staff Capacity


3.1 Roles and Responsibilities of the Safeguarding Focal Point

180921 National

Safeguarding Focal Point - JD + Evaluation questions_v.2.0.pdf

181010 National

Safeguarding Focal Point - Role Description_v.2.0.pdf

180429 Base

Safeguarding Focal Point_v1.1.pdf

3.3 Gender & Diversity 101 Half-Day introduction to core concepts and terminology of Gender & Diversity in Tdh, as well as the commitments taken onboard by the organization.

Step 4 – Information sharing & awareness

4.1 XXX

Step 5 – Processing & Responding to Feedback & Complaints – Define the Purpose & Scope 5.1 Case management process

Processus gestion

de cas V0.18_cam.xlsx

5.2 Incident Communication tree

Incident

communication tree Field-HQ.V1.0.pdf 5.2 Tdh Referral Form

Pre%20final%20refe


5.3 Tdh Database Template

Copie%20de%20CR

FM%20Database_v1.xlsx

5.4 Informed Consent & Children

Informed%20conse

nt%20and%20children.docx

5.5 Incident Report Template

Incident

report_en_V2.0.xlsx 5.6 Confidentiality Guidance for

breaches of the GCC Annex%20confiden

tiality.docx

5.7 Data protection starter kit : - SoP : working

collaboratively on sensitive document

- Sharing sensitive data internally and externally

- How to encrypt sensitive data

3.06. (version 0)

_SOP_template_Working collaboratively on sensitive documents.pdf

3.05. (version 0)

_SOP_template_Sharing of sensitive data internally and externally.pdf

2.03. (version 0)

Tutorial_How to Encrypt Files and Folders that contain sensitive data.pdf

5.8 Directive on data protection

201805_DirDataProt

_v1_En.pdf 5.9 Minimum Standard Procedure on

Data Protection in case management

Minimum Standard

Procedure on Data Protection_v1.0_en.pdf


5.10 Data Protection SOP

1904_Template_Dat

a Protection SOP.doc

List of Annexes

Annex 1: Glossary

Annex 1 : Glossary

➢ Feedback

Information provided - positive or negative - by the affected population or relevant stakeholders about

a Tdh intervention.

➢ Complaint

A complaint is a grievance made by an individual(s) who believes that a humanitarian agency has failed

to meet a stated commitment. This commitment can relate to a program or project plan, beneficiary

selection, an activity schedule, a standard of technical performance, an organizational value, a legal

requirement, or any other point.

Tdh distinguishes between operational complaints (category II) and Serious complaints, which are

breaches of the Global Code of Conduct (Category 1 to 4).

➢ Victim or survivor

A person who is, or has been, physically, sexually, or psychologically exploited or abused. For the

purposes of this policy, this is a person who has been targeted and impacted negatively by an action

which is contrary to Tdh’s Global Code of Conduct by a person bound by a contract with Tdh.

A person may be considered a victim regardless of whether the perpetrator is identified, the object of

an internal procedure, prosecuted or convicted.

➢ Whistle-blower

Individuals who report suspected breaches of Tdh’s Global Code of Conduct and/or a risk to Tdh that

could be harmful to its interests, reputation, operations or governance.

➢ Retaliation

Retaliation is defined as a direct or indirect adverse action and/or action that is threatened,

recommended or taken against an individual who has:


- Reported a breach to the Global Code of Conduct and/or wrongdoing that implies a significant

risk to Tdh; or

- Cooperated with a duly authorized audit or an investigation of a report of a breach of the

Global Code of Conduct.

Either by Tdh or any stakeholder from the community.


Annex 2 : Communication Tree

Tdh Complaint and Feedback Response Mechanism Procedure

Documents

Transcript of Tdh Complaint and Feedback Response Mechanism Procedure