EVALUATE & MONITOR:

 

Information on how to : understand collecting data on people differs from products, determine what information to collect on human and labor conditions in supply chains, and collect information on working conditions

STEP 1:
understand THAT collecting data on people differs from  products
BUYER & EMPLOYER STEPS:
  • Learn about the unique aspects of data collection on worker well-being in supply chains. This involves recognizing key distinctions between the collection processes for environmental sustainability data and social responsibility information. 

Action:

Collect data on human and labor rights conditions in supply chains

supporting guidance
Data on products helps companies to: 
  • Understand product attributes and where risks may exist.
  • Make informed choices about products to purchase. 
  • Determine improvements to be made for currently sourced products.
  • Understand where greater transparency is needed.
 
Data on people is different than data on products:
  • Tracing people and tracing products are different matters, requiring different tools and different expertise.
  • Data alone cannot detect all labor abuses. Even accurate and robust data requires interpretation and analysis.
 
Keeping workers in mind:

 
 
 
 
 
 
 
 
 
Including safeguards to protect the privacy and safety of people is of the utmost importance when collecting data related to workers and labor conditions.
When workers share sensitive information, those collecting the data should disclose how data will be used and take responsibility for what will be done with the data, including the risks and benefits to workers. Collecting data is only the first step- just as critical is what is done with the data and how it is used to improve the lives and working conditions of workers.

 
  • If a company is in the early stages of the journey, without mechanisms or a commitment for driving remediation if exploitation is found in its supply chains, the company should be aware that collecting information directly from workers may actually place workers at further risk.

  • Instead, focus on the comprehensiveness and quality of information collected through due diligence efforts to minimize the potential of collecting false positives or exposing workers to risks of reprisal. At the same time, work to establish mechanisms for safe, effective remediation if signs of risk are detected so ethical supply chain management becomes possible. 

Critical information to know about data collection

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STEP 2:
determine what information to collect on HUMAN AND LABOR RIGHTS conditions in supply chains
BUYER & EMPLOYER STEPS:
  • Identify what data to collect within supply chains in order to assess working conditions.
 
supporting guidance

As a first step, data that should be captured and tracked in the information system include, but are not limited to:

 

Sourcing data:

  • Countries where products are sourced

  • Specific products sourced from each country

  • (If applicable) Vendors/agents that place orders in specific production facilities

  • All production facilities from which products are sourced

  • The specific products sourced from each production facility

  • Countries and production facilities under consideration for product sourcing

 

Social compliance information (sources):

  • Risk assessment data for countries where products are or may be sourced

  • Data gathered from stakeholders through ongoing consultation regarding countries, labor issues, or other relevant topics

  • Grievances and complaints received through established mechanisms, and how they were resolved

  • Audit results

  • Independent verification results

  • Remediation models for use in specific situations involving code violations

  • Programs and services available in communities to assist victims of labor abuse, including children

 

Source: Comply Chain, Social Compliance Data Management

Social compliance information (categories of information): To assess labor conditions and risk for human rights violations, companies need to collect information from supply chains on the following categories:

  • Labor recruitment: terms, conditions, and contracts

  • Document retention

  • Wages, working hours, and payment

  • Benefits allowed by law

  • Threats of violence and intimidation

  • Abusive working conditions

  • Safe, functioning, accessible grievance mechanisms for workers

Learn more about what data to collect or provide:
RISE: Collecting data on people in seafood supply chains
This document provides an introduction to the categories of information companies should collect to understand labor conditions in supply chains, and examples of specific information sources. 
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Verité: Sample Seafood Supplier/Subcontractor Self-Assessment
This sample self-assessment tool provides information on the types of information that should be collected or provided from members of company supply chains to identify potential human trafficking risks.
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U.S. Customs and Border Protection: Reasonable Care: An Informed Compliance Publication
This publication, prepared by the Border Security and Trade Compliance Division, RR, is entitled Reasonable Care. It provides guidance on the use of reasonable care in entering merchandise. It is part of a series of informed compliance publications advising the public of CBP regulations and procedures.
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FishWise: Social Responsibility Information for Seafood Supply Chains: A Compilation of Resources

This compilation can provide companies with a better understanding of the types of information to collect and understand from supply chains. It compiles social responsibility information that is relevant to monitoring, assessing, and/or collecting important information regarding social responsibility, worker well-being, and human rights in seafood supply chains. It is gathered from publicly available reports, regulations, and guidelines developed by various stakeholder groups, including certification and standards bodies, government and intergovernmental organizations, and non-governmental organizations with expertise in human rights.  

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Verité: Sources of Information to be Sought in the Verification Process
This document, an appendix of the report “An Ethical Framework for Cross-Border Labor Recruitment” provides direct guidance on the types of information companies should seek to verify recruitment practices in supply chains. This includes guidance on the following: information to collect from job-seekers and employees, from recruitment-company management, from business documents, and information from employer-clients and other stakeholders.
STEP 3:
collect information on working conditions 
BUYER STEP:
  • Request and collect information on human and labor rights conditions from all suppliers, and work to implement data collection processes that involve worker participation. 
    • Make sure suppliers are aware of information that will be requested. To do this, extend this requirement to all segments of supply chains, by including data collection requirements in supplier expectations letters and supplier codes of conduct.

 
 
EMPLOYER STEP: 
  • Collect information on working conditions within own operations, and work to implement data collection processes that involve worker participation
    • Use worker engagement mechanisms to regularly collect information about human and labor rights conditions directly from workers.

    • Maintain updated documentation about working conditions and labor rights in supply chains. Employers should communicate with upstream business operations to determine what data/information needs to be provided.

 
supporting guidance

When collecting data on working conditions, it is critical to seek the opinions and perspectives of workers themselves. Direct worker engagement provides the most accurate information of conditions and worker experience. 

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Verité: Conducting Migrant Worker Interviews
This tool provides a set of sample interview questions to use when conducting targeted migrant and foreign contract worker interviews. Companies can use this tool to help shape their own worker interview questionnaires, thus improving their auditors’ ability to identify possible cases of abuse or recruiter-induced human trafficking at company, supplier and subcontractor facilities.
  • If a company is in the early stages of the journey, without mechanisms or a commitment for driving remediation if exploitation is found in its supply chains, the company should be aware that collecting information directly from workers may actually place workers at further risk.

  • Instead, focus on the comprehensiveness and quality of information collected through due diligence efforts to minimize the potential of collecting false positives or exposing workers to risks of reprisal. At the same time, work to establish mechanisms for safe, effective remediation if signs of risk are detected so ethical supply chain management becomes possible. 

For a companies with a commitment to remediation, it is essential that data collection processes involve gathering information directly from workers - Learn how here.

Technology platforms that can help: 

Issara Institute: Transformative Technology for Migrant Workers 
 
This report provides information on: 
  • mapping the current platform landscape,
  • digital tools that enable businesses to engage with migrant workers in their supply chains; and
  • migrant worker engagement functions outside of the supply chain context.
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Resources to support:
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Verité: Integrating Social Data into Product and Vessel Traceability Systems
There are several recent and current initiatives examining how social data might be integrated into systems that support seafood product traceability. Traceability itself is a crucial step in mitigating the risk of human trafficking in seafood supply chains and to eliminating IUU fishing. This brief presents some considerations for these efforts.
FishWise: Open Water - Guidance on Vessel Transparency for Seafood Companies
 
This paper will provide recommendations for how companies can improve vessel monitoring and transparency both within their operations as well as globally. Recommendations for increasing the global ratification and enforcement of key international agreements are also included to support the ultimate goal of strengthening vessel safety and labor protections for crew.
Issara Institute: Understand the ethical issues with data collection 
Sourcing electronic data from vulnerable populations is an ethical issue, and it is important to weigh the benefits and risks to target populations. Issara Institute: Updated Guide to Ethics and Human Rights in Anti-Human Trafficking: Provides ethical standards and approaches for working with migrant workers and trafficked persons in the digital age.