Staff Operational Guidance on The Dissemination of Capacity Development Information

The Staff Operational Guidance on Dissemination of Capacity Development Information sets forth procedures on the dissemination of capacity development information, based on the objectives of wider, more active, and timelier sharing of information while safeguarding the Fund’s candor and role as trusted advisor. The guidance draws from internal consultations and Executive Directors’ views on the Updated Framework on the Dissemination of Capacity Development Information.

Abstract

The Staff Operational Guidance on Dissemination of Capacity Development Information sets forth procedures on the dissemination of capacity development information, based on the objectives of wider, more active, and timelier sharing of information while safeguarding the Fund’s candor and role as trusted advisor. The guidance draws from internal consultations and Executive Directors’ views on the Updated Framework on the Dissemination of Capacity Development Information.

Introduction

Capacity development (CD) information should be disseminated more widely to capitalize on these benefits:

  • Coordination and synergies. Sharing CD information with other CD providers and financing partners mitigates the risk of siloed CD delivery, improves coordination, exploits synergies, and enables the Fund to prioritize and leverage its limited resources. Dissemination to Fund staff supports CD, lending, and surveillance integration, and enhances outcomes.

  • Knowledge as a global public good. Through publication, the membership and the public at large benefits from the Fund’s best practices in key policy areas and capacity building body of knowledge. Publication also showcases the Fund’s contribution to the global public good.

  • Accountability. Dissemination facilitates the Fund’s accountability to financing partners and the membership more broadly. Financing partners have a legitimate interest in receiving timely information on CD they are funding to satisfy their own domestic accountability requirements. Similarly, broader and timelier dissemination of CD information, helps garner support for the Fund’s work and helps manage potential funding risks by supporting fundraising efforts.

  • Ownership. Within CD recipient countries, wider and timely dissemination of information among different government agencies mitigates the risk of uncoordinated implementation of CD recommendations and strengthens ownership. More generally, publication of information may also help muster domestic social and political support for reforms.

At the same time, this policy recognizes the need for balance and weighs the benefits of increasing dissemination with the potential risks. This guidance was designed to safeguard the Fund’s role as a trusted advisor, preserve staff candor, and address the risk of increased reluctance among CD recipients to seek assistance for much needed capacity building.

Scope of the Operational Guidance

A. Temporal Scope

1. The new procedures set forth in this guidance will apply to information produced as a result of CD activities that start after May 1, 2022. This may include new activities (e.g., missions that start after May 1, 2022) taking place within the context of ongoing CD projects, which may have started prior to May 1, 2022. The production of high-level summaries will only be required for strategic final CD output resulting from new CD projects that start on or after May 1, 2022.

B. Substantive Scope

2. This guidance applies to the dissemination within and outside the Fund of all CD information (excluding the ones covered under paragraphs 4 and 5). Table 1 shows the non-exhaustive categories of CD information that are subject to the guidance. These categories may be specific to a country or CD recipient or not specific to a country or CD recipient.

Table 1.

Categories of CD Information

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3. The guidance applies to the dissemination of CD information to the following non- exhaustive list of recipients:

  • (a) CD recipients. For purposes of the guidance, the term “CD recipient” or “recipient” means the governmental or inter-governmental agency or instrumentality that is the direct recipient of Fund CD within member countries, nonmember countries and international agencies.1 CD may be delivered to multiple countries or recipients (e.g., multi-country training). Non-members and international agencies are included in this definition since, under Rule N-16(d) of the Fund’s Rules and Regulations, the Fund may provide CD to them upon the prior approval of the Executive Board.

  • (b) Fund staff.

  • (c) Direct financing partners. Official sector agencies or instrumentalities and vetted private sector entities who directly fund the project(s) (in whole or in part) associated with the information in question. This includes all contributors to multi-donor subaccounts for regional capacity development centers (RCDCs) or thematic funds.

  • (d) Executive Directors and members of their staff.

  • (e) World Bank staff.

  • (f) Other parties with a legitimate interest. This includes a development partner providing assistance in the CD recipient country in the subject matter of the relevant Fund CD, or in the case of training, other training provider who would use Fund materials to support or supplement the learning objectives of the Fund’s training delivery in that country or region. The authoring department, in consultation with the area department, makes the determination of legitimate interest.

  • (g) Other agencies or instrumentalities within the CD recipient member country or non-member or international agency.

  • (h) General public.

4. This guidance does not apply to the following types of information:

  • (a) Financial Sector Assessment Program (FSAP) Reports. The guidance does not apply to the dissemination of information derived from FSAP, since the handling of such information is subject to a separate regime reflecting understandings reached between the managements of the Fund and the World Bank.2 More information on this regime for FSAP reports is available in the Guidance Note on the Fund’s Transparency Policy.3

  • (b) Report on Standard and Codes (ROSCs). The guidance does not apply to the dissemination of these reports since the Executive Board has decided that, as documents circulated to the Board, the dissemination of these reports shall be governed by the Transparency Policy Decision.4

  • (c) Safeguards Assessment Reports. In certain contexts, safeguards assessments conducted by the staff constitute the provision of technical assistance. However, the guidance does not apply to the dissemination of safeguards reports, which are subject to a separate disclosure regime under the safeguards assessment policy.

5. The guidance does not apply to the dissemination of CD information that is governed by the Board-established transmittal and open archives policies.

  • (a) Transmittal Policy. The transmittal policy governs the routine transmittal (i.e., on a regular basis) of certain types of reports (including technical assistance (TA) reports) to certain international agencies that meet specified criteria (i.e., commonality of operational interests, reciprocal transmittal of comparable documents to the Fund, and confidentiality safeguards).5

  • (b) Open Archives Policy. TA reports over 20 years old are available to outside persons, provided that reports originally classified “Strictly Confidential” may not be released if the Managing Director finds that the material remains highly confidential or sensitive.6,7

Policy and Procedures Governing Dissemination of CD Information

6. Dissemination beyond Fund staff generally requires the consent of Fund management and the CD recipient(s). Consent requirements for each information category are laid out in Appendix I.

  • (a) If the information is specific to a country or CD recipient(s) (Table 1, column 4), dissemination requires the consent of both Fund management and the CD recipient. If the information is not specific to a country or CD recipient (Table 1, column 3), dissemination only requires the consent of Fund management.

  • (b) The below guidance assumes content is CD-recipient specific. Generally, in the case of content that does not list details specific to a CD recipient, recipient consent is not required for sharing outside Fund staff. All other instructions related to sharing the CD information category apply.

  • (c) Except in the case of information forming the basis of final CD output, the below guidance assumes all information categories outlined below, regardless of country/recipient-specificity, are in their final rather than draft form.

  • (d) With respect to consent from Fund management, this authority has been delegated to the head of the authoring CD department. With respect to consent from the CD recipient, in some instances, this consent may be obtained on a non-objection basis or may be assumed, given the subject of the information. Except as otherwise stated below (Box 1, bullet 3; paragraph15, bullet 4), CD recipients may withdraw consent at any time before the information is disseminated.

  • (e) Further, in line with (d), in scenarios not specifically envisaged in the guidance, dissemination of information specific to a CD recipient or country may be authorized to specific parties, such as the private sector, with the explicit consent of the CD recipient and the approval of Fund management.

  • (f) The dissemination of non-public information may only take place with the explicit commitment of the receiver of information that such information shall be kept confidential.

  • (g) Where information has been received from a third party, the explicit consent of such party will also be required prior to the dissemination of the relevant information.

  • (h) In determining whether to provide consent to dissemination of CD information in a scenario not explicitly envisaged in these guidelines, management should take into account, inter alia, the impact of disclosure on the CD project, whether disclosure presents any reputational risks for the Fund, and whether disclosure furthers the underlying objectives of the CD being provided.

Dissemination of CD Information to Fund Staff

All CD information may be disseminated to Fund staff in accordance with the classification of the document and the procedures set forth in General Administrative Order (GAO) No. 35, Rev. 2. The following specific rules apply:

  • CD information, including assessment and final CD output, generated by the Fund and transmitted by the authoring department to a CD recipient(s) can generally be shared across Fund departments, depending on its classification.1 This includes cases where technical advice is based on confidential information provided by the CD recipient to the CD department, so long as the technical advice does not disclose underlying information that may not be shared (see third bullet).

  • Information provided to an authoring department in the course of CD delivery (e.g., information forming the basis of final CD output) can generally be shared across Fund departments, depending on its classification. This includes confidential information provided by the CD recipient(s) to the CD provider (authoring department).

  • In rare cases, the CD recipient(s) may explicitly ask that the sharing of confidential information across departments be further limited. In all CD activities initiated after this policy becomes effective, CD will be provided on the understanding that CD recipients have provided irrevocable consent that information considered critical for program or surveillance purposes by Fund management (“critical information”) may be shared with the relevant area department. CD departments may not reach ex-ante understandings that non-public information will be withheld from area departments if a determination of criticality is made by management.

  • A CD recipient(s) may explicitly request that information only be shared across departments if a determination of criticality has been made. In such case:

    • ➣ The staff member or team providing CD will consult with supervisor(s), up through department management; and the authoring department will inform the concerned area department that such a request has been made.

    • ➣ If the authoring department believes that the information may be critical for program or surveillance purposes, the authoring department shall consult with management. If management deems this information critical for program or surveillance purposes, it can decide to share the information with relevant staff in the area department.

    • ➣ Regardless of management’s determination of criticality, staff and management may not share confidential information with the Executive Board that has been provided on the understanding that it would not be shared with the Board. Where management is of the view that confidential information needs to be disclosed to the Board (for example, in order for the Board to make an informed decision on a program review or to conduct effective surveillance), the appropriate course of action would be for management not to recommend Board action unless the information provider consents to disclosure.

    • ➣ The authoring department shall inform the CD recipient(s) of this policy before the commencement of CD delivery that takes place after May 1, 2022, including for existing projects with respect to information provided going forward as part of new activity. Information from missions or activities that started after May 1, 2022 are covered by the policy, even if the project started prior to May 1, 2022.

  • Fund staff is responsible for applying the appropriate security classification pursuant to GAO No. 35, Rev. 2 prior to sharing information internally. The authoring department is responsible for making determinations on what constitutes a “need to know” on a case-by-case basis. In making this determination the authoring department should take into account the express or implied understandings reached with the CD recipient, as well as the surrounding circumstances, including the nature of the information contained in the final CD output.

  • Final CD output classified as “Confidential” are reclassified automatically “For Official Use Only” after two years, unless the authoring department or the relevant area department considers that the sensitivity of the information has not sufficiently diminished.

1 For example, in line with Section 3.01 of GAO No. 35, rev. 2, advice classified as “For Official Use” may be shared with all staff, without restriction; advice classified as “Confidential” is sensitive and should be distributed on a “need to know” basis; advice classified as “Strictly Confidential” is very sensitive and distribution should be strictly limited.

A. Information Related to the Fact of CD Provision and Subject Matter of CD

7. The fact of provision of Fund CD in response to a particular CD request and the general subject matter of that CD is not considered non-public information, unless the CD recipient(s) specifically indicates otherwise at the time of the request for CD.

  • Information in this category would be made available to Executive Directors, including in staff reports. In addition, and upon request, this type of information may be made available to direct financing partners and other parties with legitimate interest.8 The information may also be made available to the general public, upon request or proactively.

  • In those cases, expected to be rare, where the CD recipient(s) explicitly advises Fund staff that it does not want such information to be made available, particularly to the general public, the recipient’s wishes shall be respected.

B. Information Related to the Administration of CD Projects

8. Information dealing with the administration of a CD project is not considered non- public, unless the CD recipient specifically indicates otherwise at the time of the request for CD.

  • Since this type of information is not considered non-public unless so specified by the CD recipient, it may be shared with Executive Directors and members of their staff upon their request.

  • In particular, given the high demand for this information and its importance for coordination, this information would be made readily available to direct financing partners and other parties with legitimate interest upon their request. This information may also be made available to the general public.

  • However, Fund staff would not disclose information about third parties (i.e., parties other than the CD recipient and the Fund), including direct financing partners who are funding projects, that such third parties would normally regard as non-public (e.g., information on the terms of employment of an expert).

  • Administrative information shall only be shared outside Fund staff with accompanying context or narrative to ensure proper interpretation. For instance, a table of project budget information should be shared with definitions of all terms, fields, and notes used in the table. Raw or unprocessed administrative information extracted directly from internal systems, such as Capacity Development Management and Administration Program (CDMAP), may not be shared outside Fund staff.

C. Fund’s Assessment of CD Provision

9. Information produced during the assessment of the Fund’s CD provision is considered non-public information. This information category includes results-based management (RBM) data, internally and externally (e.g., donor) funded evaluations, project risk assessments, and project assessment reports.

  • Generally, this type of information should be classified as For Official Use Only.

  • In requesting Fund CD, CD recipients are assumed to have implicitly consented to sharing Fund assessment information related to the CD they received with the full Executive Board, direct financing partners, and World Bank staff upon request. While it is expected practice for the delivering department to inform recipients of this policy at the start of the project, CD recipients are considered notified once the policy goes into force and is circulated to member countries. As such, unless the CD recipient specifically indicates otherwise9:

    • ➣ The Fund’s assessment of provision which is country- or CD recipient-specific will be made available to the Executive Directors and their staff.

    • ➣ Direct financing partners and World Bank staff will have access to the Fund’s assessment of CD provision which is country- or CD recipient-specific.

    • ➣ Recipients may explicitly withdraw consent for sharing country- or CD recipient-specific assessment information with the Executive Board, direct financing partners, and World Bank staff at any time before the assessment information is disseminated.

  • The Fund’s assessment of CD provision which is country- or recipient-specific could be shared with other parties with legitimate interest in circumstances where such sharing is considered necessary to facilitate coordination with other parties with legitimate interest and to exploit synergies. The consent of the department(s) providing CD and the CD recipient(s) is needed.

    • ➣ The head of the department(s) providing CD in consultation with the relevant area department(s) may consent to the dissemination of the information, upon request of other parties with legitimate interest, when the CD recipient has consented to such dissemination.

    • ➣ The CD department(s) will transmit the request for dissemination to the CD recipient. Consent will be deemed given if the CD recipient does not object within 30 business days from transmitted request.

  • The Fund’s assessment of CD provision which is country- or CD recipient-specific requires the approval of the department(s) providing CD as well as the CD recipient’s explicit consent to be shared with the general public.

10. Specific rules for disseminating the Fund’s assessment of CD provision are outlined below:

  • Evaluations. Internally or externally funded evaluation reports should place all content with project- and country-specific assessment information into an annex. The main evaluation report, holding the key findings and aggregated information, is considered non-CD recipient-specific assessment information. Therefore, the report, without the annex, can be published without recipient consent. The annex may be published with explicit CD recipient consent. If the report contains recipient- and/or country-specific assessment information, then it and the annex may be published together, if the CD recipient explicitly consents. Internally and externally funded evaluation reports should be uploaded to the Institutional Repository.

  • RBM. RBM data, when generated in their raw form, meaning log frame elements and their ratings (typically in the form of excel or dashboard view) can be difficult to interpret without sufficient context or awareness of how RBM is implemented in the Fund. To ensure appropriate interpretation, RBM data should only be shared outside Fund staff with appropriate context, regardless of whether these data are country- or non-country-specific. In practice, this means RBM data may be shared in reports (e.g., mid-year or annual steering committee reports) or with accompanying narrative (e.g., Board presentation on RBM, with supplementary notes), but may not be generated directly from internal operational systems, such as CDMAP, and shared in their unprocessed form.

  • Other assessment documents. Final versions, including annexes, of the Fund’s assessment of CD provision should be saved in the Institutional Repository. This includes reports which contain RBM data or provide information related to CD progress toward CD objectives, such as CD project assessments, funding program assessments, Steering Committee reports, and RCDC annual reports.

D. Information Forming the Basis of Final CD Output

11. Information provided to Fund staff by a CD recipient or a third party, or that is generated by Fund staff in the context of the provision of CD, constitutes information that forms the basis of final CD outputs.

  • Within this category there are two different types of information:

    • (a) Information provided by the CD recipient(s) or third parties in the context of the provision of Fund CD; and

    • (b) Information generated by Fund staff in the course of provision of CD before the output is finalized.

  • Information forming the basis of final CD output is presumed non-public and shall only be made available beyond Fund staff, management, and the CD recipient in certain circumstances where such sharing is considered necessary to facilitate coordination with direct financing partners and other parties with legitimate interest and to exploit synergies.

  • Specifically, the head of the authoring CD department in consultation with the relevant area department may consent to the dissemination of the information referred to in (a) and (b) above, upon request of World Bank staff, direct financing partners or other parties with legitimate interest, when the CD recipient has also explicitly consented to such dissemination. Where information has been received from a third party, the explicit consent of such party will also be required prior to the dissemination of the relevant information.

  • In determining whether to consent to the dissemination of information referred to in (a) and (b) above, the head of the authoring CD department in consultation with the relevant area department will take into account the following considerations:

    • ➣ The likelihood that the sharing of such information outside of staff, management, and the CD recipient could undermine the Fund’s ability to obtain all necessary data and information from country authorities and third parties.

    • ➣ The impact that the disclosure of such information might have on the candor of discussions during a project’s execution, whether they be in the form of exchanges with country authorities and third parties or internal deliberations among Fund staff.

    • ➣ The potential reputational risk of draft or non-final materials being misinterpreted or misconstrued, even in the case of non-recipient-specific information forming the basis of final CD output.

  • This information will generally not be published.

E. Final CD Output

12. Final CD output is considered non-public information and its dissemination outside Fund staff requires the consent of the CD recipient.10 Final CD output can be categorized as:

  • (a) TA reports. TA reports continue to be the main form of delivering final TA advice to CD recipients. All TA reports shall include a disclaimer summarizing the Fund’s policy for dissemination of this type of information according to the guidance as set forth in Appendix III and IV.

  • (b) Final training output. The authoring department determines whether output from training, such as presentations or recorded events, is final. In some cases, the output could be training aides, such as slides and worksheets, that need accompanying context and instructor explanation to be considered final. As such, these training aides would be considered information that forms the basis of final CD output.

  • (c) High-level summaries. Authoring departments should produce high-level summaries of strategic final CD output. The purpose of the high-level summary is to enable the Fund to communicate to the broader public and less technical audience more about the broad objectives, findings, and recommendations of the CD delivery in a digestible and accessible format.

    • A strategic final CD output is defined as output that reflects broad recommendations from a project, often aimed at significant reforms, as opposed to more specific, operational, and technical advice. The authoring department determines which final CD output is considered strategic.

    • CD projects are generally expected to have at least one strategic final output, although this may not always be applicable (i.e., in the case of one-off or shorter-term engagements). Authoring departments are encouraged to engage the area departments when determining the general parameters of department-specific strategic output. Examples of strategic final output include general diagnostic of the tax system and recommendations strengthening the legal framework for deposit insurance and bank resolution, establishing a macroprudential policy toolkit, and rebasing GDP.

    • High-level summaries should generally be limited to two pages and provide the broad objectives, findings, and recommendations. High-level summaries should be produced in English, regardless of the language of the full final CD output. See template in Appendix V.

    • Departments may also choose to produce high-level summaries of final CD output that has not been identified as strategic.

  • (d) Other final CD output. This category covers all other final CD output not included in the three preceding categories. They include documents containing finalized Fund staff advice including draft legislation, final aide memoires, or presentations; and final advice by Fund staff to a CD recipient(s) through emails or orally.

13. Dissemination of final CD output, including high-level summaries, to Executive Directors and members of their staff is governed by the following procedures:

  • Access to final CD outputs, including high-level summaries, by Executive Directors and members of their staff, requires consent from the CD recipient(s). Consent will be deemed obtained unless the CD recipient(s) objects to such dissemination within 30 business days of the transmittal letter or other transmittal document.11,12 The transmittal letter or other transmittal document must expressly refer to this 30-business day period.13 Explicit CD recipient consent is required for sharing of confidential and strictly confidential final CD output.

  • The CD recipient(s) is put on notice when this policy is circulated and at the start of any CD engagement that their consent for sharing final CD output with the Executive Director for the country of the CD recipient is implicit. The CD recipient(s) should explicitly state otherwise at the start of the engagement or before the output has been disseminated.

14. Dissemination of final CD output, including high-level summaries, beyond the CD recipient(s), but within the member country, non-member or international agency that has requested Fund CD, as the case may be, is subject to the following rules:

  • The duty of confidentiality is owed to the CD recipient(s), which is understood to be the direct recipient of the technical services provided by Fund staff. Direct CD recipient(s) means the specific agency or instrumentality within the member country, non-member or international agency, as the case may be, to whom the CD is directed. Accordingly, final CD output should be disseminated to the direct CD recipient(s) and should be addressed to the head of that agency or instrumentality.

  • The Fund encourages the direct CD recipient(s) to share this information with other agencies or instrumentalities of the member country, non-member, or international agency, as the case may be. In addition, Fund staff may share final CD output with other agencies or instrumentalities of the member country, non-member, or international agency, as the case may be, with the consent of the direct CD recipient(s). For these purposes, the consent of the direct CD recipient(s) shall be obtained on a non-objection basis. Consent will be deemed given if the direct CD recipient(s) does not object within 30 business days after the transmittal of the high- level summary and final output.14

15. Dissemination of final CD output, including high-level summaries, to direct financing partners and other parties with legitimate interest, other than the World Bank, is governed as outlined below:

  • With the consent of the CD recipient(s), final CD output may be shared with direct financing partners and other parties with legitimate interest, upon their request. Consent will be deemed given if a CD recipient does not object within 30 business days from the transmittal letter.

  • The authoring department in consultation with the relevant area department must determine that the other party with legitimate interest has a legitimate interest in the final CD output in question, as defined in paragraph 3(c) and (f). Direct financing partners are assumed to have legitimate interest.15

  • The dissemination of final CD output to direct financing partners and other parties with legitimate interest may only take place on the understanding with these information recipients that such information shall be kept confidential.16 Direct financing partners will have access to final CD output through Partners Connect. By logging into Partners Connect to access documents and accepting the terms, direct financing partners are acknowledging and accepting the confidentiality agreement.

  • Some direct financing partners require, as a condition for their funding a Fund project, that final CD outputs produced in connection with that project be shared with them. In these cases, Fund management reserves the right to approve such a CD request only if the CD recipient(s) provides its ex-ante irrevocable consent to share all final CD output from that project with the applicable direct financing partner(s), as a condition for receiving the requested Fund CD. In contrast to the general rule allowing CD recipients to revoke consent, in cases involving ex ante irrevocable consent, the CD recipient(s) would not be able to withdraw its consent once CD provision has begun.

16. Dissemination of final CD output, including high-level summaries, to World Bank staff shall be handled in the following manner:17

  • (a) Dissemination to World Bank staff of final CD output provided to Fund members:18

    • With respect to CD provided to Fund members, under a special procedure stemming from the Concordat on Bank-Fund collaboration, Fund staff may share final CD output, including high-level summaries of such final CD output as well as TA reports, with World Bank staff upon request, without the need for obtaining the CD recipient’s explicit consent.19,20 In this regard, it is understood that Fund members have been placed on notice that final CD output, including TA reports, will be shared with Bank staff and, in requesting Fund CD in full knowledge of these rules, are presumed to have implicitly consented to such disclosure.

    • However, as with other documents shared with Bank staff pursuant to the Fund-Bank Concordat, for example Use of Fund Resources (UFR) or Article IV consultation documents, Fund staff retain discretion as to whether any particular CD output should be shared with Bank staff. In this regard, it is always open for authoring departments to consult the CD recipient(s) prior to sharing final CD output with Bank staff. To the extent a CD recipient(s) objects to the sharing with Bank staff of a particular final CD output, Fund staff should respect those wishes.

    • Staff should also keep in mind the Joint Management Action Plan (JMAP) for Enhancing Bank-Fund Collaboration, which encourages information sharing and collaboration and contains general guidance on the sharing with Bank staff of documents, including those related to CD.21

  • (b) Dissemination to World Bank staff of final CD output, including high-level summaries, provided to non-members and international agencies:

    • With respect to Fund CD provided to non-members or international agencies, there is no existing understanding that final CD output may be shared with World Bank staff. Accordingly, staff would need to obtain the consent of the CD recipient(s) on a 30-business day lapse-of-time basis before any disclosure to the Bank staff.

17. The rules for dissemination of final CD output, including high-level summaries, to the general public (i.e., publication) are set forth below:

  • The publication by the Fund of any CD recipient-specific final CD output, except for the high- level summaries of strategic final CD output, requires the explicit consent of the CD recipient(s) and the approval of head of the authoring department, in consultation with the relevant area department.22 As noted earlier, the CD recipient(s) may withdraw its consent to publication at any time prior to publication.

  • The Fund is expected to publish high-level summaries of strategic final CD output, which requires CD recipient consent. Consent will be deemed given if the CD recipient(s) does not object within 30 business days from transmittal.

  • There is no time limit for receiving explicit consent from CD recipients to publish full CD output. However, consent from CD recipients obtained one year after transmittal requires that the authoring department reviews its consent to publish to ensure recommendations remain relevant for publication.

  • CD recipients who initially object to publishing high-level summaries may reverse their position at a later time. If such consent is provided after one year, the authoring departments must review its consent to publish to ensure recommendations remain relevant for publication.

  • Publication by the CD recipient(s) of any final CD output or high-level summary of final CD output on its own website or in another form requires the authoring department’s consent, in consultation with the relevant area department, and should reflect the same version published by the Fund. Fund consent should be given unless there are strong reasons for objecting. When disseminating, CD recipients may append a disclaimer to the published final output that notes the findings and recommendations of the output do not necessarily reflect the views of that government.

  • Recordings of training are to be treated as full final CD output and require the CD recipient’s consent before publication (in the case of training provided to participants from multiple countries, participants who provided information would need to consent). In the case of training that is announced ex-ante as available to the public and recorded, participation in the training implies recipient consent for dissemination and publication. This would include any discussion that takes place as part of Q&A. As a general best practice, the hosting department should remind participants and speakers not to share or discuss country-specific non-public information without ensuring that the relevant authorities have explicitly consented.

18. The rules for the finalization of final CD output, including high-level summaries, are set forth below:

  • Before the final CD output is transmitted to the CD recipient(s), staff should ensure proper internal clearances. Internal clearances for high-level summaries should reflect the same processes used for full final CD output. The head of the authoring department should approve the output. The head of the authoring department may however delegate review and approval of final CD output.

  • As a general norm, authoring departments should complete the pre-transmittal consultations with the CD recipient over the CD output and high-level summary within 45 days of developing the initial draft.

  • Final CD output, including high-level summaries, may not be modified after final transmittal to the CD recipient(s), with one exception: corrections for typographical errors post-transmittal may be made with approval of the head of the authoring department.

  • All final CD output should be transmitted to the CD recipient with information about the dissemination policy and consent requirements. For TA Reports, this is typically done through a transmittal letter, though one is not required. Information that should be communicated when final CD output is delivered to CD recipients can be found in Appendix IX.

  • Authoring departments are required to ensure that all final CD outputs (including training materials), with the exception of digital video and audio file formats, are stored in the central document management system and marked as final. This allows the document to be picked up by enterprise search and surfaced in the Fund intranet. In addition, all final CD output, including TA reports, high-level summaries and training materials, (regardless of GAO classification) should be forwarded to the Institutional Repository or the succeeding system within three business days of final transmission to the CD recipient (with the exception of digital video and audio file formats).

Implementation of the Guidance

A. General Issues

19. Under the relevant GAO, management has generally delegated decisions on dissemination of information to heads of departments.23 In this regard, unless as otherwise specifically indicated in the guidance, CD-providing departments shall be responsible for implementation of the procedures specified in the guidance.

20. In implementing these guidelines, departments should keep in mind the broader context from which these procedures flow, i.e., that, as a general legal principle, Fund management and staff may not disclose information that a member or other party has provided to them in confidence, unless that party consents to such disclosure. A determination that particular information has been provided in confidence is based upon an examination of all the surrounding circumstances, including the nature of the information provided; at issue is the question whether there was an understanding between staff and the other party that such information would not be disclosed without that other party’s consent. This understanding can be explicit or implied.

21. Departments should consult ICD and LEG whenever issues concerning the implementation of the guidance are unclear.

B. Reference to Guidance Upon Requests for CD

22. This guidance on dissemination should be highlighted to potential recipients whenever staff discuss the possibility of CD. In this regard, in responding affirmatively to a request for Fund CD, staff should either attach the CD dissemination policy factsheet and a copy of the guidance or include a link to the Fund’s external website in the response, underscoring that in certain cases, final CD output (as well as other information, such as the Fund’s assessment of CD provision) can be shared within and outside the Fund in accordance with the procedures set forth in the guidance. This is particularly important in cases in which the request for Fund CD comes from a non-member or an international agency that may not be appraised of the content of the guidance in the same way as member countries are. Further reminders to the CD recipient(s) of the existence and content of the guidance should be provided at the start and end of missions, and in documents transmitting final CD output and any other information that could be disseminated.

C. Categorization of CD Information and Recipients of Information

23. Upon receiving a request to disseminate particular information, staff should categorize the requested information according to the categories of information listed in Table 1 above. To the extent that particular information is difficult to fit within any of the listed categories, resulting in lack of clarity as to how the information should be treated under the guidance, staff should consult ICD and LEG for further guidance.

24. On occasion, staff may be faced with requests for dissemination from external parties other than the most common possibilities listed in paragraph 3 above. These may include academics and researchers, nongovernmental organizations and private sector entities providing technical assistance, or various entities in civil society. If staff is unsure of how to handle such requests, ICD and LEG should be consulted.

D. Joint Products

25. With respect to CD information (e.g., final CD output, assessments, etc.) produced jointly with the World Bank (or other agency), and where dissemination rules in the Bank (or other agency) and the Fund differ, the information should be treated based on the more stringent dissemination rules. Joint information products should include the following disclaimer:

The contents of this document constitute capacity development information produced by the staff of the International Monetary Fund and the [World Bank Group (WBG)] and provided in response to member country request for capacity development. With the written authorization of the CD recipient, the [document] (in whole or in part) or summaries thereof may be disclosed to IMF and [WBG] Executive Directors and their staff, and to capacity development providers and financing partners outside the IMF and the [WBG]. Disclosure of this [document] (in whole or in part) or summaries thereof to parties outside the IMF and the WBG other than CD providers and financing partners shall require the written authorization of the CD recipient.”

E. Coming into Force of Guidance

26. This guidance becomes effective on May 1, 2022. The policy will apply to CD information produced as a result of CD delivery taking place on or after May 1, 2022, including any new activities (i.e., new HQ missions, desk reviews, workshops, etc.) associated with existing or ongoing CD projects initiated before May 1, 2022. The requirement to produce high-level summaries for strategic final CD output will be phased in during FY 2023 and will only be required for strategic final CD output resulting from new CD projects that start on or after May 1, 2022. In FY 2024, all strategic final CD output will require a high-level summary, regardless of when the associated CD project started.

27. To aid in bringing the guidance to the notice of potential CD recipients:

  • A communication will be sent to all Fund members notifying them of the guidance and attaching thereto a copy of the guidance. A similar notice was sent to the World Bank and other international organizations and agencies with which Fund documents are shared underthe Fund’s Transmittal Policy.

  • The guidance will be posted on the Fund’s external website following its circulation to the Executive Board for its information.

  • A factsheet outlining the Fund’s dissemination policy and application to the different information categories will be shared with CD recipients, partners, and the Executive Board.

  • In discussing possible CD requests, departments should inform the member, non-member or international agency requesting Fund CD of the dissemination procedures.

Appendix I. Policy Application by Information Type and Non-Fund Staff Audience

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Compared with other parties with legitimate interest, World Bank staff have greater access to Fund CD-related documents. The Concordat on Bank-Fund collaboration has been applied to permit Fund staff to share final CD output, including high-level summaries, and assessments of CD provision, with World Bank staff upon request without obtaining CD recipient’s explicit consent. Members request Fund CD with the full knowledge of these rules and are presumed to have implicitly consented to such disclosure.

Appendix II. Model Transmittal Letter (Ex-Post)—Fund Assessment of CD Delivery1

[Date]

 

Mr./Ms. ---:

[Position]

[Ministry of -- / Central Bank of ---/ other]

[Address]

 

Dear Mr./Ms. ---:

Please find enclosed [evaluation report name or RBM data] prepared by the [authoring department]. The IMF produces information associated with its assessment of Fund CD delivery, including evaluations and results-based management (RBM) information. Such information will be produced routinely in association with CD delivered through [project name.]

Under IMF policy, country-specific assessment information is made available to the IMF’s Executive Directors and members of their staff as well as directly financing partners. Your consent to share assessment information with the Executive Board and directly financing partners is deemed to have been provided, unless you stated otherwise at the start of the engagement.

Under IMF policy, the Fund may also share assessment information with other TA providers with legitimate interest, unless you expressly object. Specifically, if we have not received your objection within 30 business days of sending this transmittal letter, you will be deemed to have consented to sharing assessment information associated with your country produced during the provisio n of CD through the [named project]. After the expiration of the 30-business day period, you may still object to the dissemination of any assessment information, which have not been yet disseminated.

The IMF does not publish country-specific assessment information without explicit consent from member countries. However, publication is encouraged on the IMF website or other external communication media. If you agree to publication of RBM data associated with your country resulting from the delivery of CD under this project, I would be grateful for your explicit consent.

Sincerely yours,

Appendix III. Model Disclaimer

1. All Fund TA reports should include the following disclaimer:

The contents of this document constitute technical advice provided by the staff of the International Monetary Fund to the authorities of [name of the agency of the member country][name of the agency of the non-member][international agency] (the"CD recipient") in response to their request for technical assistance. This document (in whole or in part) or summaries thereof may be disclosed by the IMF to the IMF Executive Director for [insert name of the country of the CD recipient], to other IMF Executive Directors and members of their staff, as well as to other agencies or instrumentalities of the CD recipient, and upon their request, to World Bank staff, and other technical assistance providers and donors with legitimate interest [if applicable only] members of the Steering Committee of [name of RCDC) or Thematic Fund)], unless the CD recipient specifically objects to such disclosure (see Operational Guidance for the Dissemination of Capacity Development Information—[add hyperlink]). Publication or Disclosure of this report (in whole or in part) to parties outside the IMF other than agencies or instrumentalities of the CD recipient, World Bank staff, other technical assistance providers and donors with legitimate interest [if applicable only] members of the Steering Committee of [name of RCDC or Thematic Fund] shall require the explicit consent of the CD recipient and the IMF’s [authoring] department.”

2. In disseminating other types of final CD output, staff may use this disclaimer if the circumstances so require.

Appendix IV. Model Disclaimer—Expectation of Limited Disclosure

1. Where the understandings reached with CD recipients prevent dissemination absent the explicit consent of the CD recipient and authoring department, the following disclaimer may be used. It is expected that this would largely be appropriate only for a subset of Fund TA reports classified as Strictly Confidential.

The contents of this report constitute technical advice provided by the staff of the International Monetary Fund to the authorities of [name of the agency of the member country][name of the agency of the non-member][international agency] (the "CD recipient") in response to their request for technical assistance. Due to the [Strictly Confidential] classification of this report, Publication or Disclosure of this report (in whole or in part) or summaries thereof to parties outside the IMF shall require the explicit consent of the CD recipient and the IMF’s [authoring] department.”

2. In disseminating other types of final CD output that is classified as strictly confidential, staff may use this disclaimer if the circumstances so require.

Appendix V. High-Level Summary Template

A high-level summary template will be available in Microsoft Word under IMF templates. A sample is shown below. The document should not exceed two pages, excluding the cover page.

A. Disclaimer to be used:

“The contents of this document constitute a high-level summary of technical advice provided by the staff of the International Monetary Fund to the authorities of [name of the agency of the member country] [name of the agency of the non-member][international agency] (the "CD recipient") in response to their request for capacity development. Unless the CD recipient specifically objects within 30 business days of its transmittal, the IMF will publish this high-level summary on IMF.org (see Staff Operational Guidance for the Dissemination of Capacity Development Information [add hyperlink]).”

B. Required sections:

  • Background. Why did the CD project take place? What did the project do? Why does the project matter? Provide description of the technical assistance or training, high-level objectives, connection to previous or ongoing Fund CD projects, and connection to surveillance and program priorities, particularly how recommendations would benefit policy analysis, formulation, execution, and/or monitoring.

  • Summary of findings. What did the CD project find? Present findings, that to the extent possible would be linked to recommendations in the next section.

  • Summary of recommendations. How should capacity be improved? Communicate the [three] most relevant recommendations.

Appendix VI. Model Transmittal Letter1

[Date]

 

Mr./Ms. ---:

[Position]

[Ministry of --/ Central Bank of --Other]

[Address]

 

Dear Mr./Ms. ---:

Please find enclosed the final technical assistance (TA) report entitled [Title of the TA report] prepared by the [date of mission and authoring department] led by [name of mission chief]. Enclosed is also a high-level summary of the report, which has been drafted with the intention of being published. The report’s recommendations are based upon the mission’s findings [at the time of its visit to] [place in which the mission took place]. I understand these recommendations were discussed with [you/ members of your staff] during the mission.

Under IMF policy, TA reports are shared with the IMF’s Executive Directors and members of their staff and, upon their request, with direct financing partners and other parties with legitimate interest, unless you expressly object. Specifically, if we have not received your objection within 30 business days of this transmittal letter, you will be deemed to have consented to sharing the enclosed TA report with these recipients (see Staff Operational Guidance on Dissemination of CD Information [insert link] for more information). Your consent to share the high-level summary and report with the Executive Director for your country is deemed to have been provided, unless you stated otherwise at the start of the engagement. This report may be shared with World Bank staff, upon their request, unless you explicitly withdraw your consent.

Under IMF policy, high-level summaries of strategic CD output, such as this report, are made available to the public unless you expressly object. Specifically, if we have not received your objection within 30 business days of this transmittal letter, you will be deemed to have consented to publication of the enclosed high-level summary of the TA report.

The IMF also encourages the publication of full TA reports. If you agree to publication of the enclosed report on the IMF website, I would be grateful if you could sign and return the authorization set forth below since your explicit consent is required to publish the TA report. You can also decide to publish the report through your own outlets with IMF approval. In both cases, we will undertake the needed procedural steps as soon as we hear back from you.

I hope the recommendations of the report will be helpful to [ briefly describe the purpose of recommendations].

Sincerely yours,

[Head of Authoring department / RCDC Director]

We hereby authorize the IMF to publish the report entitled [Title of the TA report] on the IMF external website.

Signature:                       Date:

 

Enclosures: [#]

cc:           Executive Director

Appendix VII. Model Transmittal Letter— Expectation of Limited Disclosure1

[Date]

 

Mr./Ms. ---:

[Position]

[Ministry of --/ Central Bank of --/Other]

[Address]

 

Dear Mr./Ms. ---:

Please find enclosed the final technical assistance (TA) report entitled [Title of the TA report] prepared by the [date of mission and authoring department] led by [name of mission chief]. The report’s recommendations are based upon the mission’s findings [at the time of its visit to] [place in which the mission took place]. I understand these recommendations were discussed with [you/members of your staff] during the mission.

This report will be made available to the pertinent Executive Director, unless you object. Additionally, this report may be made available to World Bank staff, upon their request, unless you object. Under IMF policy, and given the understandings reached regarding the confidentiality of this TA report, it will not be disseminated further without your explicit consent.

I hope the recommendations of the report will be helpful to [briefly describe the purpose of recommendations].

Sincerely yours,

 

[Head of Authoring department / RCDC Director]

 

We hereby authorize the IMF to publish the report entitled [Title of the TA report] on the IMFexternal website.

 

Signature:                       Date:

Enclosures: [#]

cc:           Executive Director

Appendix VIII. Model Transmittal Letter—Direct Financing Partner/Other Parties with Legitimate Interest

A. Model Institutional Communication on Confidentiality for Direct Financing Partners (including members of a Steering Committee of regional technical assistance centers or topical trust funds) and CD Providers other than the World Bank Requesting CD Information.1

“[Date]

 

[Direct Financing Partner/Other CD Provider]

[Address]

 

Dear Mr./Ms. ---:

In accordance with the IMF policies and procedures on dissemination of CD information (see Operational Guidance [add hyperlink]), for purposes of releasing such information, recipients need to explicitly agree to treat that information as confidential. Accordingly, we hereby request [your organization / the Ministry of Finance of [member], as part of the Steering Committee of [name of RCDC / Thematic Fund] / the Central Bank of [member], as part of the Steering Committee of [name of RCDC / Thematic Fund]] or any future RCDC, or thematic fund to confirm that it agrees that any information contained, or referred to in any CD information it may receive from the IMF, shall be treated by [your organization / the Ministry of Finance of [member] / the Central Bank of [member]] as confidential and will be solely for the internal use of [your organization / the Ministry of Finance of [member] / the Central Bank of [member]].

Unless the express authorization of the IMF and the CD recipient is granted, the information referred to above shall not be disclosed either orally or in writing outside [your organization / the Ministry of Finance of [member] / the Central Bank of [member]]. These understandings will become effective on the date on which this letter is returned to the IMF duly signed and dated by an authorized representative of [your organization / the Ministry of Finance of [member] / the Central Bank of [member]].

 

Sincerely yours,

 

[Division Chief, ICDGP / TAO / Center Director [name of RCDC]]

         [name of Organization/Ministry of Finance/Central Bank]

         [signature / date]”

B. Confirmation of Understandings on Confidentiality.

In accordance with the IMF policies and procedures on dissemination of CD information (see Operational Guidance [add hyperlink]), and for purposes of releasing the requested document, [your organization / the Ministry of Finance of [member] / the Central Bank of [member]] has agreed that any information contained, or referred to in the requested document, shall be treated as confidential and will be solely for the internal use of [your organization / the Ministry of Finance of [member] / the Central Bank of [member]]. Unless the express authorization of the IMF and the CD recipient is granted, the information referred to above shall not be disclosed either orally or in writing outside your organization.

Appendix IX. Required Dissemination Components in Final Transmittal

When transmitting final CD output to the CD recipient(s), regardless of transmittal method, Fund staff should communicate the below details related to the dissemination of the final CD output. This language can be used when transmitting any final CD output. For TA Reports, staff may also choose to use the model transmittal letter provided in Appendix VI and VII.

When transmitting full final CD output:

Under IMF policy, final CD output [insert link to Operational Guidance on Dissemination of CD Information]:

  • Is shared with the Executive Director for your country, based on the understanding that your consent is provided, unless you stated otherwise at the start of the engagement.

  • May be shared with the IMF’s Executive Directors and members of their staff and, upon their request, with direct financing partners and other parties with legitimate interest, unless you expressly object. If the Fund does not receive your objection within 30 business days of this communication, you will be deemed to have consented to sharing the enclosed output with these recipients.

  • May be shared with World Bank staff, upon their request, unless you explicitly withdraw your consent.

  • Will not be published without your explicit consent. We encourage publication and request your written authorization. You can also decide to publish the report through your own outlets with IMF approval. In both cases, we will undertake the needed procedural steps as soon as we hear back from you.

When transmitting high-level summaries:

Under IMF policy, high-level summaries of strategic CD output are made available to the public unless you expressly object. You will be deemed to have consented to publication of the enclosed high-level summary if we have not received your objection within 30 business days of this communication.

1

Instrumentality refers to a division or subdivision of an official sector or institution.

2

See Confidentiality Protocol—Protection of Sensitive Information in the Financial Sector Assessment Program, Selected Decisions, Forty-first Issue, p. 106.

3

See International Monetary Fund, 2014, Updated Guidance Note on the Fund’s Transparency Policy (Washington).

4

Decision No. 13564-(05/85), adopted October 5, 2005, as amended.

5

The Transmittal Policy, Decision No. A-9786-(93/20), February 11, 1993, as amended, has rarely been used for routine transmission of TA reports because, unlike use of Fund resources (UFR) and Article IV consultation reports, TA reports are not produced on a regular basis. In addition, some TA providers and donors may not qualify a s “international agencies” within the meaning of the policy, and the criterion on commonality of operational interest may be difficult to meet.

6

Dissemination of TA reports that are classified as “Strictly Confidential” shall follow the rules set forth in General Administrative Order (GAO) No. 35, Rev. 2 (“Information Security—Policies Regarding Classified Documents of November 1, 2007) for dissemination within the Fund, and the Fund’s Open Archives Policy for sharing outside the Fund. According to GAO No. 35, Rev. 2, access to a TA report classified as “Strictly Confidential” shall be limited to addressees who meet the “strict need to know criterion.” Outside the Fund, persons may have access to “Strictly Confidential” non-Board documents under the Open Archives Policy upon their request, if the documents are over 20 years old, provided, however, that access to those documents will be granted only upon declassification by the authoring department in consultation with ITD. The head of the authoring department, in consultation with ITD and with the consent of the CD recipient, may also approve the sharing of TA reports classified as “ Strictly Confidential” outside the Fund prior to the 20-year period. In these cases, such sharing may be subject to understandings between Fund staff and the outside recipient of the information that such information shall be treated by the latter as strictly confidential.

7

Open Archives Policy, Decision No. 14498-(09/126), adopted December 17, 2009, as amended.

8

A request, as defined in this document, can be made orally, in writing, or by electronic means, i.e., a click on a secured website of the Fund.

9

See Appendix II for a model transmittal letter containing the standard language to be used for obtaining cons ent from the CD recipient to disseminate information related to the Fund’s assessment of CD provision.

10

Final CD outputs may be referenced or cited in staff reports regardless of whether they have been published. Authorities will have the opportunity to object to the reference during their review as part of the Transparency Policy.

11

As mentioned above, staff should note that except for cases where ex ante irrevocable consent may be required for externally financed CD, CD recipients may withdraw their consent to disseminate any time prior to actual dissemination of a final CD output.

12

After the expiration of the 30 business-day period, the CD recipient may still object to the dissemination provided the final CD output has not yet been disseminated.

13

See Appendix VI for a model transmittal letter containing the standard language to be used for obtaining consent from the CD recipient to disseminate TA reports on a non-objection basis. See Appendix VII for a model transmittal letter to be used when there is an expectation of limited disclosure.

14

For final TA reports, the consent of the CD recipient, on a non-objection basis, will be obtained by Fund staff through the transmittal letter. See Appendix VI for a model letter with standard language. An objection must be received by the Fund within 30 business days from the transmittal letter. Alternatively, the CD recipient can give explicit consent to disseminate before the end of the 30 business-day period, when there is a need to speed up the process of sharing the final TA report. As regards the dissemination of other types of final CD output, the objection must be received within 30 business days from the date on which Fund staff request consent from the CD recipient. After the expiration of the 30-business day period, the CD recipient may still object to the dissemination provided the TA report has not been yet disseminated.

15

Member countries of RCDCs are deemed to have legitimate interest, as they are part of steering committees.

16

See Appendix VIII for a model institutional communication on confidentiality for direct financing partners.

17

“World Bank” refers only the International Bank for Reconstruction and Development and does not include other institutions of the World Bank Group.

18

IMF and the World Bank, Guidance Note on Information Sharing Between IMF and World Bank Staff, February 2022.

19

See Bank-Fund Collaboration in Assisting Member Countries (SM/89/54, 3/9/89).

20

If nonpublic information is disclosed to Bank staff (including information other than final CD output), such information is shared on the understanding that the Bank will take practical steps to safeguard its confidentiality, in particular, by treating it within the Bank in the same way that the Fund treats that information within the Fund. In particular, information classified as “Confidential” is disclosed to the Bank on the understanding that it will be made available within the Bank only to those with a “need to know.” Information classified as “Strictly Confidential” is disclosed to the Bank on the understanding that it will be made available within the Bank only to those with a “strict need to know.” In any event, Bank staff shall not disclose classified information shared with it beyond the Bank.

21

See Enhancing Collaboration—Joint Management Action Plan (SM/07/335, 9/24/07).

22

The process for obtaining consent for publication differs from that for other forms of dissemination, i.e., for publication, a communication is required from the CD recipient that it agrees to publication.

23

See General Administrative Order No. 35, Rev. 2 on Information Security—Policies Regarding Classified Documents.

1

This transmittal letter should be used when transmitting a report or document ex-post. This letter is not expected to be transmitted at the start of a CD engagement.

2

The language in this letter should be used as a model for the transmittal of finalized TA reports to the TA recipient. The language in this letter may also be used in the transmittal of other typ es of final TA advice if the circumstances so require.

3

This model may be used when the CD provider has been told in advance that the final CD output should not be disseminated. This is likely to be used for reports labeled as Confidential and Strictly Confidential, though these labels are related to the GAO No. 35, Rev. 2. and used for internal dissemination purposes.

4

This communication will be sent to donors and CD providers other than the World Bank to obtain their prior and explicit confirmation of the confidentiality understandings. The text should be modified according to the type of partnership (i.e., RCDC/Thematic Fund SC member or bilateral partner, CD provider, etc.).

Staff Operational Guidance on The Dissemination of Capacity Development Information
Author: International Monetary Fund. Institute for Capacity Development and International Monetary Fund. Legal Dept.