Led by UNHCR’s Innovation Service, the Digital Inclusion programme aims to ensure that refugees and the communities that host them have the right, and the choice, to be included in a connected society, and can have their voices heard in the design and implementation of humanitarian response. The Digital Inclusion programme brings together efforts of UNHCR’s Connectivity for Refugees initiative, which focuses primarily on access to digital channels (messaging services, online applications, online platforms, digital communications) and internet connectivity (through different means like mobile connectivity, Wifi provision or other models), and UNHCR’s Innovation Service’s work on Communicating with Communities. It also underpins efforts around the inclusion of refugees in national frameworks and tackling barriers to equal connectivity access as outlined in the Global Compact on Refugees.
Through the Digital Inclusion programme, UNHCR has made significant progress in understanding the legal and regulatory barriers that refugees and other displaced populations face to register SIM cards and personal devices under their names due to a lack of required ID credentials. With advances in the digitalization of aid, ID-related barriers hampering access to flexible banking modalities by UNHCR’s persons of concern, such as mobile wallets and bank accounts, are also of interest. In this regard, UNHCR has published a series of reports, ¨Displaced and Disconnected¨, aiming at mapping the roadblocks to legal access to mobile connectivity, digital financial services and bank accounts in numerous priority countries.
This research strengthens our evidence-based approach to carry out targeted advocacy interventions with relevant national and international stakeholders aimed at the digital and financial inclusion of the most vulnerable groups, such as displaced populations. One example of such advocacy interventions was in Uganda in 2019, where alongside the GSMA, UNHCR convened multiple stakeholders to explore the issue, resulting in the Uganda Communications Commission (UCC) issuing a directive to greatly improve access to SIM cards for refugees in the country.
UNHCR is extending this research to Pakistan. Research completed here will contribute to a wider review of legal and regulatory barriers to mobile connectivity, digital financial services and bank accounts for displaced populations in the Asia Pacific region. This consultancy will look at the specific context and regulatory environment in Pakistan along with how barriers are addressed, either through different options identified by displaced people or local initiatives for change. It may also have to consider wider regional dynamics.
UNHCR has developed a methodology to undertake desk research, literature reviews, interviews with experts in the humanitarian, development, and identification/registration policy domains; surveys of UNHCR country operations, and ongoing engagement with trade bodies such as GSMA as well as local regulators. It is expected that this methodology will be used by the selected consultant who will be responsible for making the needed adaptations or modifications in collaboration with UNHCR country teams to fit the national operational context.
UNHCR’s Innovation Service is working together with relevant units within the organisation (i.e. Identity Management and Registration Service and Global Cash Operations) to map the legal and regulatory barriers that are impacting the digital and financial inclusion of refugees and other displaced populations. The scope of this project will comprise an analysis of the requirements to legally access and register SIM cards and/or personal devices and meet Know Your Client /Customer Due Diligence (KYC/CDD) requirements to access bank accounts and digital financial services, specifically mobile money or other digital options if relevant, in countries with unfolding population movements and where UNHCR plans to scale up its Cash-Based Intervention (CBI) in Pakistan. Objectives of this research project:
Improve understanding of the legal and regulatory frameworks and their implications in Pakistan that affect refugees, asylum-seekers and stateless populations’ ability to participate in or benefit from opportunities provided by legal access to mobile connectivity, specifically SIM cards and digital financial services, and bank accounts.
- Provide contextual and primary information that can be used by UNCHR to inform future service delivery through mobile channels.
- Develop a contextually specific body of evidence that can contribute to advocacy and stakeholder engagement for addressing regulations that exclude displaced populations from participating in a connected society and create further vulnerabilities.
- Identify if there are success cases, enabling environments and promising approaches in Pakistan to learn from.
- Identify practical and actionable recommendations for governments, service providers and humanitarian organizations on addressing barriers and future provision of services through mobile channels
Duties and Responsibilities:
- To conduct the research into legal and regulatory barriers to mobile connectivity, digital financial services and bank accounts in Pakistan.
- In this undertaking, to apply UNHCR’s ¨Displaced and Disconnected¨ methodology, utilising additional or alternative methods and contextualising tools as appropriate, including other support tools provided by the Innovation Service.
- Liaise with relevant UNHCR staff members in the operation and Regional Bureau of Asia and the Pacific to map known ‘real-world’ barriers to legal access to mobile connectivity and financial services, and opportunities for addressing them.
- Liaise with the UNHCR Pakistan office to organise key informant interviews or other relevant consultations with representatives from affected groups.
- Engage with civil society organizations, academics or other specialists in digital rights or related fields to enrich the knowledge of the local context and develop synergies with their work as applicable.
- If feasible, work with regulators and other government institutions in Pakistan to develop a thorough understanding of the legal and regulatory frameworks governing SIM cards and financial services access for refugees and other displaced populations.
- Explore possible joint pathways with regulators and relevant institutions in Pakistan to enhance digital and financial inclusion of UNHCR´s persons of concern.
- Suggest ways forward/develop a roadmap to tackling and mitigate identified barriers in collaboration with local stakeholders and relevant organisations, such as the GSMA, to achieve a meaningful digital and financial inclusion of refugees and other displaced populations.
- Incorporate feedback and questions from UNHCR staff members in the operational and Regional Bureau to finalise deliverables.
- Inception report drafted with an overview of the final report and work plan to be produced after 2 weeks.
- A draft report in English provided to UNHCR for feedback to incorporate before finalising.
- Final public report in English with top-level findings, including high-level recommendations to Government, service providers and humanitarian organisations as applicable.
- Presentation of results to the UNHCR Pakistan operation, Regional Bureau and other stakeholders as appropriate.
- List of stakeholders consulted during the research (incl. contact details), as well as all background information used during the desk review phase to produce the report, to liaise as required to carry out potential advocacy actions.
- Records of consultations or interviews with displaced populations
University-level qualifications Bachelor's (essential) or Master’s degree (desired) in a relevant area including but not limited to telecommunications law, ICT policy, refugee or humanitarian la
- Demonstrates minimum 4 years of experience in understanding legal and regulatory systems. Specific experience with either refugee and/or telecommunications issues is desirable.
- Demonstrated experience in undertaking research projects similar in nature and level of complexity.
- Experience working for a UN agency or international organization, with a focus on aid and development issues.
- Knowledge of the humanitarian landscape in Pakistan, and exposure to the work done with refugees, migrants, and other displaced populations in the country is an advantage.
- Experience in analysing national legislation and policy frameworks. Understanding of IT/telecoms policy and regulation, or financial regulations is an advantage
- Previous experience with developing/being involved in advocacy platforms with high-level national actors and relevant global institutions is an advantage.
Fluency in Urdu (required)
Fluency in English (required)
- Highly organized and autonomous, able to multitask and prioritize workload when necessary.
- Excellent writing and documentation skills, demonstrating high levels of attention to detail.
- Strong time management skills, including the ability to work quickly and to meet deadlines.
- Ability to work as a team, including remotely.
- Strong interpersonal and communication skills, including across cultural contexts.
- Works well in a multicultural team and has a strong work ethic; strives to deliver high-quality, error-free deliverables potentially targeting different types of users e.g., senior management, fundraising specialists and database managers.
The consultant will be home-based in Pakistan. The consultant should be available for conference calls with UNHCR’s regional bureau office in Bangkok and occasionally with UNHCR colleagues in East Africa and Central Europe Time Zones.
- Duration: 30 working days that can be distributed across 2 months from 15th August to 15th October.
- Project title: Legal and Regulatory barriers to mobile connectivity and digital financial service access in Refugee hosting countries