PVS: Flawed Assumptions about Effective Vetting of Humanitarian Activity
The purpose of the Partner Vetting System (PVS) is to vet individuals in nongovernmental organizations (NGOs) who apply for United States Agency for International Development (USAID) or State Department contracts and grants, in order to ensure that USAID-funded activities are not inadvertently providing support to entities associated with terrorism. Under the proposed PVS pilot program, the U.S. government will collect personal data, including name, government identification number, date of birth, country of citizenship, home address, email address, employer information, and job title, from applicants who wish to use federal money for humanitarian purposes overseas. The certification on the form also states that the NGO official signing the form must take “reasonable steps in accordance with sound business practices” to verify the information without defining what those practices are. Numerous NGOs oppose its implementation.
- General Background Information
- Is PVS a Solution in search of a problem?
- PVS Will Increase Safety Risks to NGO workers in the field
- Massive List-checking is an ineffective vetting strategy
- Processing Delays and Undue Burden on Applicants
- Lack of specifics on proposed PVS pilot
- Better Approaches to Vetting
The Partner Vetting System (PVS) was first proposed in 2007 as a way to “conduct screening to ensure USAID funds and USAID-funded activities are not purposefully or inadvertently used to provide support to entities or individuals deemed to be a risk to national security.” It did not define what constitutes a "risk to national security" or provide any criteria used to deem an individual or group to be such a risk.
More recently, State and USAID have said implementing a coordinated PVS pilot program is “consistent with the relevant language in the FY 2010 Appropriations Act, made applicable to FY 2011 activities pursuant to the FY 2011 Continuing Resolution.” In 2011 State and USAID issued additional notices in the Federal Register announcing the pilot program (see PVS overview page for all FR notices), inviting comments on the scope and costs of the burdens PVS would create for NGOs. However, these notices did not been provide specifics about the pilot plan.
"The inevitable result of a data-mining approach to fusion centers will be:
- Many innocent individuals will be flagged, scrutinized, investigated, placed on watch lists, interrogated or arrested, and possibly suffer irreparable harm to their reputation, all because of a hidden machinery of data brokers, information aggregators and computer algorithms.
- Law enforcement agencies will waste time and resources investing in high-tech computer boondoggles that leave them chasing false leads—while real threats go unaddressed and limited resources are sucked away from the basic, old-fashioned legwork that is the only way genuine terror plots have ever been foiled."
- How does USAID define a "threat to national security"?
- What is "derogatory information"?
- Will USAID have deadlines for completion of its vetting process?
- How will the appeal process work?
- Has USAID considered alternative vetting strategies?
- The International Red Cross and Red Crescent Movement’s Principles of Conduct in Disaster Response Programmes
- The Sphere Project’s Handbook, 2011 Edition
- The Do No Harm Handbook: The Framework for Analyzing the Impact of Assistance on Conflict A project of the Collaborative for Development Action, Inc. and CDA Collaborative Learning Projects November 2004
- Principles of International Charity, published by the Treasury Guidelines Working Group in March 2005
- InterAction’s Private Voluntary Organization (PVO)
- Humanitarian Accountability Partnership International’s Principles of Accountability
- Muslim Advocates’ Accreditation Program
- Transparency International's Preventing Corruption in Humanitarian Operations Handbook of Good Practices