The U.S. army’s Synchronized Pre-Deployment and Operational Tracker (SPOT) system is a military database that indefinitely stores detailed personnel data of contractors’ employees working in Iraq and Afghanistan. Recipients of federal grants, and their sub-grantees, are required to register with SPOT before beginning their projects. For Nongovernmental Organizations (NGOs) operating relief and development programs in these two countries, meeting the requirements of SPOT is impracticable, and may jeopardize their employees’ safety and the effectiveness of their programs.
To increase oversight of the U.S. government’s contractors in Afghanistan and Iraq, Congress passed the National Defense Authorization Act of 2008 (NDAA 2008) and charged the Department of Defense (DoD), Department of State (State) and the United States Agency for International Development (USAID) to use a shared database for mostly covering defense contracts and contractor personnel. System entries would include:
Additionally, contractor personnelworking in Iraq or Afghanistan, including individuals and subcontractors at any level, were required to include:
In 2009, the National Defense Authorization Act of 2010 (NDAA 2010) expanded the original language to include collecting information about grantees, including NGOs conducting relief or development operations in Afghanistan and Iraq. As the NDAA legislation was an unfunded mandate, DoD presented the interagency charge with their SPOT database as the solution to meet the needs of Congress. DoD, State, and USAID agreed to make SPOT the system of record for contractors in Afghanistan and Iraq.
Why SPOT is Problematic for NGOs
Requiring NGOs to supply intimate personal details about their international and local employees to a military database is both dangerous and impractical. SPOT was designed for military officials to manage their defense contractors and not for NGOs who often employ local civilians. SPOT permanently stores detailed information about a defense contractor’s personnel, including, but not limited to, his/her full name, contact information, email address, passport data, government ID number, addresses for employer and next of kin, and blood type. Another SPOT category specifically asks which military “operation” the grantee is working for.
The majority of NGO staff operating in Afghanistan and Iraq is locally hired and do not possess the information required by SPOT. International NGO staff may be hesitant to provide personal information knowing that it will be stored indefinitely and shared with other agencies and governments for intelligence gathering purposes. In places where both military and NGOs are independently providing relief services, NGO managers forced to collect sensitive personal data for a government database may undermine their relationships with local actors. The security of all NGO employees can be threatened if they are perceived by the local community to be an agent of the military.
Speaking at an event in May 2010[3], Deputy General Counsel for Save the Children USA, Ellen Willmott, shared her concerns about SPOT. “It is a military database. It is owned, operated, maintained, by the Department of Defense, the US Army to be exact. It is a database that is not confidential; it is subject to sharing of information with other U.S. Government agencies, including law enforcement, foreign government agencies, and the like. We are being asked to input personal, sensitive information of our staff, the staff of sub-partners, the staff of sub-sub-partners who are funded through USAID or Department of State into the this database.”
International NGOs have years of experience providing life saving and sustaining assistance to communities devastated by conflict or natural disaster. To address the concerns of NGOs, the three agencies should honor the original language in the NDAA 2008, or design and implement a new database that is appropriate for independent NGOs working in Afghanistan and Iraq.
[1] NDAA 2008 defines private security functions as the “guarding of personnel, facilities or property of a Federal agency, the contractor or subcontractor, or a third party” and “any other activity for which personnel are required to carry weapons in the performance of their duties” under a U.S. government contract in an area of combat operations.
[2] The Memorandum of Understanding between the 3 agencies was originally signed in July 2008, but was finalized in the 2010 agreement, which included the expanded language from NDAA 2010.
[3] http://www.charityandsecurity.org/CSNEvents/Experts_Reviews_Obamas_Cairo_Commitment