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1. Introduction to data collection framework

This data collection framework is designed to help non-governmental organisations collectively understand, monitor and address issues caused by sanctions and counterterrorism measures (SCTM). Using the framework will demonstrate the tangible impacts that SCTM have on humanitarian operations and needs. It provides NGOs with a systematised approach to gather evidence concerning the impacts of SCTM on their operations as well as on the broader expanse of humanitarian space. In essence, the framework is geared toward accomplishing four specific objectives:

  1. Collecting Meaningful Information: The consequences of SCTM on humanitarian action can encompass a vast array of implications, making it challenging and time consuming to measure in a pertinent manner. This framework aims to pinpoint the most impactful information components impacting operations and that hold significant potential for influencing key advocacy stakeholders. 
  2. Ensuring Regular and Consistent Data Contribution: Frequently, a notable disparity exists between the information required by an advocacy team and how operational teams convey it. This framework is dedicated to elucidating the rationale, content, and methodologies behind the intended data
    collection to each participant. By integrating data collection tools into established organisational processes, as well as pre-existing tools, it streamlines data collection and analysis across relevant departments. 
  3. Enabling Versatile Utilization of Gathered Information: Simultaneous operation and advocacy endeavours often tackle diverse facets of the SCTM' impact. This framework incorporates the distinct data requirements of these efforts and simplifies the integration of data into multiple aggregation platforms, all
    sourced from a singular origin.
  4. Promoting a participative process: Within the project, there is a provision for testing the framework through collaboration with co-lead organisations. It is also open-source and unbranded, thus enabling its full appropriation by other NGOs. This constitutes the initial version of the SCTM data collection framework (1.0). Subsequent to pilot iterations and feedback, revised and refined versions will be published.

Why is collecting data important?


Data collection on SMCT impacts is important to inform better programming and planning. 

The indirect nature of SCTM’ effects makes them sometimes hard to identify and measure. For example, they may lead to increased operational costs, decreased access, or changes in local communities' attitudes towards NGOs, which are not immediately noticeable.

At country level, most teams are focused on their operational activities. As a result, they might lack the bandwidth, resources or capacity to thoroughly analyse the broader political or legal implications of measures such as SCTM. Additionally, SCTM vary widely between different jurisdictions and contexts and make difficult for teams to fully understand the implications for their work. Therefore, the feedback from country teams should focus on directly observable elements or those impacting their work, supported by a well-defined framework for information requests. 

At HQ level, teams are typically more aware of the broad impact of these measures. However, the departments and services most affected are often accustomed to handling and navigating multifaceted constraints daily, without delving into their specific root causes. Establishing an inventory of incidents can simplify the task of isolating – on the medium term – the impact of SCTM.

This framework is dedicated to data collection and analysis, for advocacy purposes, and should not be approached as a troubleshooting guidance. However, investigating the details of SCTM-related issues through improved data can support solving problems in a maximised way, by:

  1. Informing better decision-making: NGOs can make decisions that directly address hidden underlying factors, rather than simply dealing with the symptoms or immediate impacts.
  2. Strategic Planning: NGOs can focus on changes that provide lasting solutions.
  3. Resource Allocation: By better understanding the issue, NGO can often achieve the same with less.


When advocating for generalised humanitarian exemptions with their Member States interlocutors, advocacy teams are often told that more evidence is needed. This evidence should pertain to the specific problems arising from SCTM, the authenticity and significance of their impact on the organisation and beneficiary populations, and the limitations of ad hoc derogations and specific licenses. The following key considerations should be kept in mind.

  • Illustrating the scope of the problem, helping our interlocutors grasp its magnitude.
  • Factualising its consequences, emphasising the reality of the situation.
  • Informing relevant solutions by indicating who and what is most affected.

Ultimately, this approach strengthens the credibility of the entire case, even for issues where the evidence is more difficult to present, by demonstrating the seriousness of the overall approach to documentation.

Policy makers and related administrations heavily rely on figures, as they offer the factual basis to justify their decisions to their peers, their hierarchy or their constituencies. In theory, data also support their prediction on the future impacts of policy
changes. More importantly, advocacy teams or senior leadership typically engage with counterparts who need to persuade other administrative entities or ministries on these issues. By offering reliable figures, these counterparts can demonstrate the extent of the issue and the need to take action, and streamline complex topics such as this one, enabling clearer communication with other stakeholders involved in decision-making.

Demonstrating the complex interaction between SCTM and humanitarian action can become overly technical, potentially diluting the sense of urgency. Using real-life examples can capture attention, reinforce the arguments’ memorability, and
stimulate emotional engagement. This not only promotes further discussion with our counterparts but also simplifies their own efforts in conveying the issue to audiences less familiar with it.

Most data collection initiatives concerning SCTM have been ad hoc, often sanction-specific, and dependent on NGOs' immediate ability to capture field-based issues. In contrast, country-led processes, mostly by HCTs, hinge on local SCTM
issue prominence, hindering global benchmarking. By rooting this framework in the organisation's global programming, data collection becomes more efficient and can support various information requests (refer to other “data collection mechanisms” paragraph below).

What do we want to demonstrate?

To develop a successful change and mitigate the negative consequences of SCTM, it is essential to identify the key priority areas. Some seemingly urgent issues might not be addressable from a humanitarian standpoint or may pose challenges in effectively demonstrating an impact.

Priority 1: 

The disproportionate financial and transactional costs incurred 
Several state counterparts view humanitarian aid as a potential indirect conduit for covert terrorist activities, necessitating stringent compliance rules for NGOs. Thus, presenting accurate data and trends concerning recorded aid diversion and unintended benefits becomes vital, alongside highlighting the robust mitigation measures that organisations have implemented. Furthermore, by thoroughly and quantitatively demonstrating the adverse effects of SCTM on NGOs’ operations, we can reveal the extent of the problem and underline the urgent need for mitigation.
Their severe and extended impact on humanitarian aid and beneficiary populations
Providing an idea of the recurrence of incidents, the number of people affected at the end of the chain and the type of impact helps to emphasise the urgency of the problem.

Priority 2: 

The chain of impact of SCTM (causal link)
Proving the causal connection between policies (SCTM framework) and their unintended consequences (humanitarian) is a prerequisite. The complexity here arises from the involvement of multiple actors in the SCTM chain of impact. To address this, gathering humanitarian workers' own perspectives on the root causes of the issues they encounter will help identify clusters of clues, which may later be further substantiated. 

Out of scope: 

Most humanitarian advocacy efforts tend to limit their argumentation to the interplay between SCTM and humanitarian aid. Extending its scope to socio-economic impacts quickly falls outside our mandate.

The framework and its associated methodology are designed with the primary objective of data collection. Although they may facilitate the identification of key pain points and contribute to more effective troubleshooting, it's important to note that they should not be regarded as standalone risk management tools, nor should they be perceived as offering guidance for risk mitigation. The present guidelines include links to relevant external tools and resources to address these needs.

This framework focuses on the impacts of Sanctions and Counter-Terrorism Measures (SCTM) only. Prior to implementing it within your organisation, it is advisable to assess your existing toolkit.

The data collection tool was developed and designed by Action Against Hunger, Médecins du Monde, and Humanity & Inclusion. 

Christopher Mungai, a meteorological technician at the Kenya Meteorological Department in Taita Taveta adds weather data collected from the station into a global system. Observations must be uploaded to the system immediately after being registered.

2. How to use the framework

Start by reading these guidelines. They provide all the necessary background information on the scope of sanctions and counterterrorism measures, the operational issues and concrete impacts they bring...
Learn more