Information, accountability & impact: Luminate’s new Financial Transparency strategy

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It’s been great to see a number of the members of the Transparency and Accountability Initiative publish updated strategies over the last couple of years, with these strategies helping to shape the evolution of the transparency and accountability agenda. We’ve been happy to provide feedback on DFID’s “Open Aid, Open Societies” strategy (here), on the Open Society Foundations’ “Fiscal Governance” strategy (here), and on various elements of the Hewlett Foundation’s “Transparency, Participation and Accountability” strategy (here), and associated learning strategy (here). So we welcome the opportunity to provide feedback on Luminate’s (the spin-off of the Governance and Citizen Engagement arm of the Omidyar Network) new Financial Transparency strategy (Strategy here; blogpost from Ory Okolloh, here).

There is much to say about Luminate’s new Financial Transparency strategy, and more to explore as regards the inter-connections with Luminate’s other focus areas on Civic Empowerment; Data and Digital Rights; and, Independent Media. Below, after some general reflections, we focus on three more specific areas: joining the dots across various elements of the financial transparency system; giving greater emphasis to accountability and enforcement as regards corruption; and, last but not least, the value of collaborative learning and action.

Challenges, reflections and questions

We’re pleased to see Luminate retain a strong focus on challenges around the use and abuse of public resources. Work on these challenges, under the Fiscal Governance label, was a strong suit of the Omidyar Network’s Governance and Citizen Engagement program, is central to the governance and development agenda, and is the focus of Global Integrity’s work on themes including integrity and anti-corruption, fiscal governance, and multi-stakeholder governance initiatives.

So it’s super-interesting to see Luminate reflecting on past experience and setting out to explore what is perhaps the key question for an evolving agenda: how to better link information disclosure with social and political action that drives accountability and impact, and avoid the “informed disenchantment” that can grow when transparency fails to meet citizens’ needs. This is not a question with easy answers, but by posing the question clearly, and through careful reflection on what went well and what did not go so well in the earlier Fiscal Governance strategy, Luminate sets the stage for more collaborative learning and action, to explore how data can make a difference.

Total Resource Flows – or, the “follow the money” agenda

Luminate’s assessment is that their efforts to promote greater transparency about “total resource flows” – based on the assumption that full visibility as regards resources flowing into a nation’s purse would go a long way towards ensuring that those resources are spent wisely – did not go so well. On this, we are largely in agreement, but with some important caveats.

Yes, we agree that there has been too much focus on disclosing data in line with global norms, and on the technicalities of data interoperability, with the focus sometimes being on promoting and measuring aspects of transparency that can seem rather disconnected from citizens’ needs. (See our piece on Open Budgets: Backsliding and the use of budget data). And we are pleased that the idea that “transparency alone is not enough” is now very widely accepted, with, for instance, the Open Contracting Partnership’s forthcoming strategy which explicitly states that they are not interested in transparency just for its own sake

We also agree that the particular approach that was taken to understanding and addressing total resource flows – an approach that focused on norms, disclosure and technical data standards – failed to get traction, in part because it was somewhat disconnected from country-level work and citizens’ needs. [Full transparency: The idea of joining the dots across the fiscal governance landscape, or the “follow the money” system, including aid, extractives revenues, illicit financial flows, budgets and contracts, was something I helped to promote while I was at the ONE Campaign from 2011 to 2014, with Omidyar Network funding for that agenda provided to the ONE Campaign from 2014.]

However, while the particular approach did not deliver on its promise, we still feel that an approach which makes connections across work on tax and extractives revenues, public participation in the budgeting process, contracting, and expenditure tracking – and which helps to build the financial transparency ecosystem – has a lot of potential. Data, stories, advocacy and policy that focuses on the constituent parts of a wider fiscal governance system are likely to be more meaningful, persuasive, powerful and effective – and more effective in terms of making the jump from information, to social and political action and accountability, and change – if they take account of the wider system, including the results that public resources deliver, or fail to deliver, in terms of service delivery and sectoral outcomes. On this, there have been some encouraging efforts to link up work – whether this is data, stories, advocacy or policy-focused work – on aid and budgets, on extractives revenues and budgets, on extractives revenues and contracts, on contracts and beneficial ownership, and on resource flows and service delivery results, for example.

To fulfill the potential of silo-busting approaches, the agenda needs to be rebalanced and to be built from the bottom-up, with less emphasis on norms, disclosure and technical data standards, and more emphasis on supporting and learning from practical and problem-focused country-level and sub-national efforts to use financial data – and data about results – to shift the political dynamics and incentives that are at the heart of sectoral and service delivery challenges that citizens care about.

This is an approach that we have taken in our work with national and state level access to information commissions, and civil society organizations, on fiscal governance in Mexico, initially supported by the Omidyar Network and most recently by the Open Society Foundations. That work has been challenging, but has clearly demonstrated the value of starting with problems that people care about, and then supporting local partners as they try to use data to follow the money, to hold governments to account, and to further improve the data landscape (see here and here for impact stories). We think that applying this sort of approach – our “Treasure Hunts” methodology – in other contexts, has considerable potential and have begun exploring this possibility with partners including BudgIT Nigeria.

Corruption: Accountability and enforcement

Luminate’s new strategy on Financial Transparency correctly identifies the risk of “scandal fatigue” if citizens feel that corruption is an intractable problem, and that even when it is exposed there is no enforcement or accountability. As such, the increased emphasis given to accountability and enforcement, including through increased focus on strategic litigation, and legislation, policy and institutional reform, is welcome.

However, we would encourage some additional attention to the “implementation gap”. This is a concept that has been at the heart of Global Integrity’s work for many years, from our work on assessing policies on paper and in practice in countries around the world, to our problem-focused support for local partners seeking to address complex governance-related challenges. The concept of the implementation gap remains hugely relevant, including as regards transparency and corruption, because while many countries have made encouraging commitments to promote transparency and better governance – for instance, through the Open Government Partnership – there is often a gap between commitments, policies and laws, and their effective implementation (see here for OGP’s take on why too many OGP commitments fail, and here for an argument that the design gap matters more than the implementation gap).

Just as data may not make a difference (the impact gap) unless it shifts the political dynamics and incentives that are at the heart of governance-related challenges, policy may not translate to practice and accountability, unless the reasons (power dynamics, vested interests and incentives) why policy is often not implemented effectively (the implementation gap) are addressed.

We have been pleased to see other organizations, including the Natural Resources Governance Institute, giving greater attention to the implementation gap, and were thrilled to see this notion picked up in the World Bank’s World Development Report for 2017. As with the impact gap – the fact that data doesn’t necessarily make a difference – closing the implementation gap is far from easy. But facing up to the gap, as NRGI are doing, and working out how to support local actors as they try to ensure that commitments turn into action, enforcement and accountability, is the only way to go. Grappling with this issue is central to much of what we do at Global Integrity, including through our leadership of the Global Integrity Anti-Corruption Evidence Programme, the sister programme to the SOAS Anti-Corruption Evidence Centre which has a very strong focus on power, incentives, and the political economy of corruption in particular sectors, and the role that these issues play in shaping the space for effective, and feasible, reforms.

Collaborative learning and action

As Luminate’s new Financial Transparency strategy correctly notes, ensuring that information disclosure leads to social and political action, which in turn increases accountability, and drives impact, is not an easy challenge. But there is no doubt that it is a key challenge for the transparency and open government agendas.

We do not claim to have the answer, but our multi-year collaboration with Mexican partners, at national and sub-national level, suggests some ways forward. And the efforts of other organizations, including the International Budget Project, the Natural Resource Governance Institute, Publish What You Pay, Publish What You Fund, the Open Contracting Partnership, the Open Data Charter, and – most importantly – many organizations, including Luminate grantees, working in the global south to follow the money and improve the use of public resources, provide a great basis for collaborative learning and action.

As such, we were pleased to see Ory Okolloh’s post emphasize the value of collaboration – “If you want to go fast, go alone. If you want to go far, go together” – and commit to supporting initiatives that share data and learning across regions, to encourage collaboration and to invest in coalitions and platforms. As the learning partner on the Transparency & Accountability Initiative’s Data for Accountability Initiative in Nigeria and Colombia, we’re currently supporting learning and collaboration on just these lines (see here for some reflections on the process that led to that initiative).

We have also been pleased to participate in OSFs’ efforts to foster learning amongst their fiscal governance grantees, reflect on the potential value of a common learning agenda across grantees, and provide input on a new fiscal governance indicators project. We’re also encouraged by similar efforts led by the Hewlett Foundation, including in Kenya and Mexico. And, we continue to do what we can to support the Follow the Money network, which has struggled in recent times, but could – if it were designed to support and learn from practical experience of using financial data to illuminate and address governance-related challenges in particular places, and if organizations were able to see the value of learning and collaboration across geographies and issues – be a useful forum for collaborative learning.

We see real value in supporting collaborative learning amongst Luminate grantees – or maybe a wider group of T/AI members’ grantees – about different approaches to linking information disclosure to social and political action (See our 2017 post on Exploring How Data Can Make a Difference: A call for collective action). Such collaborative learning and action could help to meet grantees’ needs, identify synergies, improve effectiveness, maximize impact, build the evidence base and inform the field.

So what?

Addressing the “so what?” question that Ory Okolloh identifies in her blogpost – “what does transparency and accountability mean for the citizen”, or, put differently,  “how can transparency and accountability be leveraged to deliver outcomes that citizens care about?” – is key. Efforts to address this all-important question can be strengthened through an approach that centers on collaborative learning and action amongst organizations – at global, national and local levels – who are innovating, testing and adapting their approaches to increasing transparency across different parts of the fiscal governance landscape, and crafting approaches which better link information disclosure to social and political action. We would love to help!

Alan Hudson
Executive Director

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