DISCLOSURE POLICY
Summary
The World Bank is proposing a major shift in its approach to disclosing information: to move from spelling out what documents we disclose (a positive list) to disclosing any information that is not on a list of exceptions. The new approach would be more consistent with our expressed presumption in favor of disclosure.
The new approach would rest on four principles.
Principle 1. Maximum access to information
We recognize the fundamental importance of transparency and accountability in the development process. Accordingly, our disclosure policy would give public access to all information in our possession, subject only to a limited set of exceptions. The policy would recognize that certain categories of information need not remain classified for an indefinite period, and would provide clear timelines for releasing certain kinds of information.
Principle 2. A clear list of exceptions, easier to interpret and implement
We would deny access to information only when there is a compelling reason for confidentiality. Examples include personal information about staff, sensitive information that member countries and third parties give to us with the express understanding that such information would not be disclosed, and information subject to attorney-client privilege. We would also reserve the right not to disclose information if we determine that such disclosure is likely to cause serious harm to the interests of the Bank, a member country, a staff member, or third parties—such harm outweighing the benefits of disclosure.
Principle 3. Clear procedures for processing requests for information
In implementing the proposed approach, we would routinely post as much information as possible on our external website. We would adopt clear and cost-effective procedures for processing requests for information, including defined timelines for decision-making and responding to requests. Any fees charged for collating or reproducing information would be fair and reasonable.
Principle 4. The right to appeal
We recognize the right of requesters to an administrative appeals process if they believe that we have unreasonably denied them access to information that should be publicly available under our disclosure policy. An appeals panel would be headed by senior management staff with full authority to interpret the policy and confirm or reverse the decision to deny access (except for classified Board documents, whose disclosure is the prerogative of the Board).
What are the main differences between the new approach and our existing policy?
• Under the existing policy, we spell out the types of documents we disclose; under the proposed approach, we would make all documents publicly available except those on a limited list of exceptions.
• We would disclose more types of information than under the existing policy, and much of the information would be freely available on the Bank's external website. Examples of this additional information are Quarterly Management Reports, Country Portfolio and Performance Reviews, Implementation Status and Results reports (excluding staff comments), mission aide-mémoire, and minutes of Concept Review and Decision meetings.
• The new approach would rely on a rigorous classification of documents as they are created by our staff or received from member countries or third parties— “Public,” “For Official Use Only,” “Confidential,” and “Strictly Confidential.” When we receive information from external parties with the explicit understanding that it not be disclosed, we would continue to be legally and morally obligated to respect that understanding.
• We would declassify certain Bank documents, including most Board documents, upon completion of our deliberative processes or after defined periods of time.
• Some information that we do not currently disclose because it was created or received under the existing or previous disclosure policies would be declassified and made available after defined timelines. A far as possible this declassification would conform to the types of documents and timelines we are considering under the new approach.
• We would introduce an administrative appeals mechanism.
• Bank operational staff at all levels would be trained in the classification of documents and related procedures to improve our services and service standards in making our information as widely available as reasonably possible.
This new approach is consistent with our business model, which recognizes that transparency is critical for enhancing governance, accountability, and development effectiveness. A sound, open policy on the disclosure of information is fundamental to fulfilling our many roles. Our intention is to strike the right balance between maximum disclosure and our legitimate concerns to protect certain types of confidential information.
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PROPOSED REVISION TO THE DISCLOSURE POLICY
QUESTIONS &ANSWERS
1. What are the main differences between the proposed policy and the existing policy in the Bank's approach to disclosure of information?
• The principal difference is that we want to change our basic approach to disclosing information. Under the existing policy, the Bank spells out the information that it makes available to the public, essentially a “positive list” approach. Our proposal now is to make information in the Bank's possession publicly available, subject to a list of exceptions.
• Under the proposed approach, more types of information would become available. Much of this information would be routinely posted on the Bank's external website. We would also provide more clarity on what information is not disclosed.
• We will ensure that all documents created or received by the Bank—including those received from member countries or third parties—will be classified as “Public,” “For Official Use Only,” “Confidential,” or “Strictly Confidential,” according to the sensitivity of their content. This will make it clear how these documents should be handled.
• Under the existing policy, all proceedings of the Board and its committees are confidential unless the Board specifically authorizes disclosure. The proposed policy would define the types of information relating to Board proceedings that would not be disclosed, or would become publicly available after defined time periods. All other information would be publicly available at the end of the Board's deliberative process.
• We would create an administrative appeals mechanism—a panel of senior Management staff with authority to review and uphold or reverse previous decisions to deny access to information (except disclosure decisions taken by the Board).
2. What types of information would become available that have not been available under the existing policy?
• We would provide greater transparency about projects being prepared or projects under implementation by disclosing certain deliberative information at key decision points of the project cycle—for example, Quarterly Management Reports, Implementation Status and Results reports (excluding staff comments), Country Portfolio and Performance Reviews, and mission aide-mémoire.
• The new policy would also provide greater transparency about documents prepared by staff for consideration by the Board and its committees—what we call “Board papers.” All Board papers that are initially classified as “Official Use Only” would be declassified and disclosed at the end of the Board's deliberative process. Some Board documents classified as “Confidential” or “Strictly Confidential” may be declassified and disclosed after defined timelines.
• We would disclose most economic and sector work reports, including Country Procurement Assessments and Country Financial Accountability Assessments.
• We would also declassify and disclose some information that is restricted under the exceptions after the lapse of defined time periods. Examples of such information are: Country Policy and Institutional Assessment ratings, audits conducted by the Internal Audit Department, and internal correspondence filed in the Bank's internal records management system. The timelines we are considering are either a uniform period of 20 years for most historical information, or a differentiated structure of 5, 10, or 20 years for different types of documents (20 years is the standard in most international organizations).
3. What criteria would the Bank use in deciding what types of information should be classified as confidential, i.e., listed as exceptions?
• In deciding the types of information that should fall under the list exceptions, the Bank would adhere to generally accepted norms on confidentiality—for example, confidentiality of personal information about staff, confidential information given to the Bank by outside parties with the understanding that it would not be disclosed, security information, or information that is subject to attorney-client privilege.
• The Bank has a legal and moral obligation not to disclose information that it receives from member governments or third parties on a confidential basis, without the express permission of the owner of the information.
• The Bank also requires the space to have a free and candid exchange of ideas with member countries or other partners, and within the Bank itself, before decisions are reached. Therefore the Bank would not disclose information relating to its deliberations, except for final decision documents on Bank-supported operations at key milestones.
• In addition, the Bank would reserve the right not to disclose information—even information that it would normally disclose—if it determines that the disclosure is likely to cause serious harm to the interests of the Bank, a member country, Bank staff, or third parties, and that this potential harm outweighs the benefits of disclosure.
4. What information on the list of exceptions would remain confidential beyond 20 years?
• Information provided by member countries or third parties on an explicit basis of confidentiality, unless the owner of information has provided express permission to disclose.
• Internal e-mails other than those filed in the Bank's internal records management system.
• Personal information of the World Bank President, Bank staff, or Executive Directors and their staff, as described in para. 13 of the Approach Paper.
• Bank corporate procurement and security information, as described in para. 15 of the Approach Paper.
• Information related to attorney-client relations (under attorney-client privilege), investigations carried out by the Bank's Department of Institutional Integrity, and proceedings of the Bank's Sanctions Board, as described in para. 16 of the Approach Paper.
5. The proposed policy would apply to new information generated or received by the Bank. How will the Bank manage requests to disclose information it now has that was prepared under more restricted versions of the policy?
• We are developing timelines and procedures to declassify and disclose certain categories of existing documents. To the extent possible, these procedures and timelines would conform to those being developed for the proposed policy. For example, the Bank may adopt a uniform 20-year period to declassify most operational information, as the United Nations and other international organizations do. Some types of documents may become available after 5 or 10 years.
6. Would implementation of the proposal involve additional service fees for obtaining publicly available information?
• More information would be available on the Bank's website, where access would remain free of charge.
• Other information that is readily accessible in the Bank in electronic format would also remain available free of charge, upon request.
• We would make hard copy documents available free of charge to a requester on his/her own country. When the request would require the Bank to photocopy, scan, or otherwise extract and collate information, we would continue to charge reasonable fees.
• We are considering a differentiated fee structure for students, academics, and NGOs as opposed to commercial, for-profit entities.
7. Will the Bank strengthen the Public Information Centers and related systems to facilitate the implementation of the new policy?
• Operational staff will be trained in the classification of documents; systems will be developed to acknowledge and track requests for information within defined times; and PIC and InfoShop staff will be trained in new procedures to respond promptly to requests for information.
8. How does the proposed policy relate to the Bank's Governance and Anticorruption (GAC) Strategy?
• A core aspect of the GAC strategy is to increase the Bank's transparency in conducting its business, especially by making available information on project implementation.
• The proposed policy would contribute to such transparency by allowing the disclosure of decision documents at key milestones of the project cycle, during both preparation and implementation.
9. What is meant by disclosure of information?
• Disclosure of information means making available to the public electronic or paper documents or other records in the Bank's possession. Publicly available information may be disclosed by the Bank on its external website, or it may be made available upon request to the Bank's InfoShop, the country Public Information Centers (PICs), or the Bank's Archives unit.
Look Out for a Public Forum on the Disclosure Policy Review
For more information please visit:
www.worldbank.org/disclosure
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