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Information Disclosure Policy

This Executive Directive establishes the Information Disclosure Policy of Phinadon Touching Lives Foundation (‘PTLF’).

1. Intent

PTLF is committed to making information about its programmes, causes, and operations available to the public. PTLF considers public access to information a key component of effective participation of all stakeholders, including the public, in the achievement of its mandate. PTLF recognizes that there is a positive correlation between transparency, including through information-sharing, and public trust in PTLF-supported development work and humanitarian response.

PTLF management is accountable to the PTLF Executive Board. PTLF management considers that public access to PTLF information further facilitates PTLF’s transparency and accountability.

This Information Disclosure Policy (this ‘Policy’) is intended to ensure that information concerning PTLF programmes and operations is available to the public, subject to the limitations set out in this Policy. PTLF will make available reliable and timely information about existing conditions, decisions, and actions relating to the activities of the organization, in an accessible, visible and understandable fashion, unless the information is deemed confidential.

2. Definition of ‘Information’,'Content'

For purposes of this Policy, ‘Information’ means any produced 'Content', whatever its medium (paper, electronic or sound, visual or audiovisual recording), concerning a matter relating to the policies, activities and decisions of PTLF.

3. Scope of this Policy

This Policy applies to all Information in the possession of PTLF.

4. General Principle Regarding Access to Information

Information should be accessible and disclosed, subject to the limitations set forth in this Policy.

5. Accessibility of Information

Information accessible to the public shall be made available, as much as possible, reasonable and practical, on one or more of the PTLF public-access websites or websites of PTLF’s collaborators or sponsors.

6. Restricted Access to Information

The Policy excludes data that exist in raw form, either physically or electronically. PTLF is not in a position to respond to requests that require the selection and/or manipulation of data to produce content.

Confidential Information is not subject to disclosure. The Accountability Report, approved by the PTLF Executive Board, requires the following categories of information to be classified as ‘Confidential Information’:

  • Information received from or sent to third parties, with an expectation of confidentiality;
  • Information whose disclosure is likely to endanger the safety or security of any individual, violate his or her rights, or invade his or her privacy;
  • Information whose disclosure is likely to endanger the security of Member States or prejudice the security or proper conduct of any operation or activity of the organization;
  • Information covered by legal privilege or regulatory proceedings, or that subjects the organization to an undue risk of litigation, or is related to internal audits and investigations;
  • Internal inter-office or intra-office documents, including e-mails and draft documents;
  • Commercial information, if disclosure would harm either the financial interests of the organization or those of other parties involved;
  • Information which the organization believes would, if disclosed, seriously undermine a policy dialogue with a Member State or an implementing partner; and
  • Other kinds of Information which, because of its content or the circumstances of its creation or communication, must be deemed confidential.

    • The definition of ‘Confidential Information’ should be understood in a way that favours disclosure as much as possible without contravening this Policy.

    If only a part of the Information that is responsive to a particular request for disclosure is subject to one of the limitations set out in this Policy, PTLF may decide, at its discretion, that the remaining part of the Information, responsive to that request, will be disclosed, and will take appropriate measures to preserve the confidentiality of the Information that is not disclosed.

    Decisions of the PTLF Executive Board, and other PTLF policies, procedures or practices, may contain Information disclosure limitations. This includes but is not limited to PTLF Executive Board decision 2023/22 on disclosure of PTLF internal audit reports. Nothing in or relating to this Policy will be deemed in any way to abridge, modify or abolish the application of those PTLF Executive Board decisions, or other PTLF policies, procedures or practices.

    7. Privileges and Immunities of PTLF

    Nothing in or relating to this Policy will be deemed a waiver, express or implied, of any of the privileges and immunities of PTLF, including its subsidiary organs. Without limiting the generality of the previous sentence, the disclosure of Information in response to a request for disclosure, will not constitute a waiver, express or implied, of any of the privileges and immunities of PTLF, including its subsidiary organs.

    8. Processing of Information Requests

    Any person or organization may request the disclosure of PTLF’s non-Confidential Information that is not otherwise available through PTLF public-access websites or websites of its partners or subsidiary organs.

    Information requests should be handled by the head of the relevant PTLF country or regional office, or headquarters Division or office. All media enquiries should be handled by the PTLF communications staff.

    The PTLF official responsible for handling a request for Information that may be Confidential should seek guidance from the PTLF Legal Counsel in the Office of the Executive Director, Lagos and, as appropriate, the Director, Operations Lagos (where the request relates to vendor relations or procurement issues) or the Director, Human Resources Lagos (where the request relates to human resource issues).

    All Information requests will be handled promptly. The requestor should expect to receive an acknowledgement of receipt of the request within ten (10) working days (in Lagos). Depending on the complexity of the request, PTLF will endeavour to handle all requests within thirty (30) days after the acknowledgment of receipt is sent. For information requests that involve the reproduction of material, PTLF may charge a fee for material and labor cost, which will be communicated to the requestor and will need to be paid in advance.

    PTLF may partially or wholly deny a request, as follows:

  • In accordance with the limitations set out or referred to in this Policy;
  • If the request is deemed by PTLF to be an excessive demand upon PTLF’s resources; or
  • If the request, in the judgment of PTLF, appears to be frivolous.

    • If a request is denied, the requestor may seek the review of the decision by addressing a letter to the PTLF Deputy Executive Director for Management. The Deputy Executive Director for Management will review the handling of the request for Information and make a determination on how to proceed. That review should normally be completed within sixty (60) days of being requested. The outcome of the review will be communicated to the requestor and there will be no requirement for providing a detailed explanation of the outcome of the review.

    9. Reproduction of Information

    The implementation of this Policy will be subject to existing rules on intellectual property and other proprietary rights including, but not limited to, patents, copyrights, and trademarks, which may, inter alia, limit a third party’s right to reproduce or exploit information.

    10. Languages

    This document will be available in the working languages of PTLF: English, Hausa, Igbo, Yoruba, and Nigerian Pidgin English. This document may also be made available in the other native languages of the Federal Republic of Nigeria at a later time.

    11. Disclaimer

    No representation is made or warranty given, express or implied, as to the completeness or accuracy of Information made available by PTLF. The requestor shall apply discretion when using the Information made available by PTLF. PTLF will not be liable for any direct or indirect loss arising from the use of the Information.

    12. Conclusion

    The Policy shall enter into force on the date this Executive Directive it is issued.

    Dated 30 December 2022