The following example illustrates how a humanitarian NGO could apply the HRDD process across the five stages of the PCM.
A food security NGO planning a combined food distribution and livelihoods support intervention in a mixed IDP and returnee settlement in rural Aleppo governorate could apply the stages of the HRDD process as follows:
- Identifying and Assessing Human Rights Risks
During the assessment phase, the NGO should:
1) Conduct a detailed conflict analysis, mapping territorial control, armed actor influence, and explosive ordnance contamination zones that will affect the safety and pattern of delivery of aid;
2) Identify relevant human rights risks associated with the project, including risks related to the right to adequate food, right to an adequate standard of living, labour rights in livelihood activities, and protection risks such as GBV and child labour, as well as potential aid diversion and coercion risks by local power holders;
3) Engage with women, the elderly, persons with disabilities, returnees, and undocumented individuals to identify specific risks, access barriers, and civil documentation gaps that may prevent them from accessing assistance;
4) Assess possible environmental issues related to food packing, waste disposal, and the impact of livelihood activities on natural resources and land use; and
5) Screen local partners and suppliers against SEAH standards, sanctions lists, and human rights abuses, in line with the organisation’s partner due diligence obligations.
- Design (Planning and Preparation) Phase
Based on the assessment findings, the NGO should:
1) Design selection criteria for beneficiaries that are transparent, non-discriminatory, and inclusive of undocumented individuals, ensuring that lack of civil documentation does not constitute a barrier to accessing assistance;
2) Establish a Community Feedback Mechanism (CFM) that is accessible, confidential, and culturally appropriate, with dedicated referral pathways for SEAH complaints separate from general grievance channels;
3) Provide mandatory training to all staff and partner personnel on safeguarding policies, SEAH prevention, data protection, and human rights standards, ensuring alignment and awareness across the organisation and its sub-grantees;
4) Integrate data protection protocols into the project design, ensuring that beneficiary personal data, including displacement status, civil documentation details, and vulnerability indicators, is collected, stored, and shared only with informed consent and in compliance with humanitarian data responsibility standards;
5) Incorporate environmental mitigation measures such as the use of biodegradable packaging in lieu of traditional plastics and a waste management plan; and
6) Establish a written partner agreement that includes explicit human rights obligations, SEAH clauses, data protection requirements, and aid diversion prevention protocols, with clear consequences for non-compliance.
Before the project moves to implementation, the NGO should open an HRDD Decision Log and record all risk assessment findings, agreed mitigation measures, responsible staff, and baseline indicators, establishing the accountability trail that will be maintained throughout the project cycle.
- Implementation (Delivery) Phase
During implementation, the NGO should:
1) Apply the HRDD Tool Matrix systematically across all relevant sectors (Food Security, Early Recovery, and Protection) ensuring that the risk assessment questions and indicators are completed for each PCM phase and each sector before and during delivery;
2) Actively monitor access barriers throughout distribution cycles, particularly for women-headed households, persons with disabilities, ethnic and religious minorities, and individuals without documentation, adjusting distribution modalities accordingly;
3) Implement a Post-Distribution Monitoring (PDM) system that captures beneficiary feedback on aid quality, accessibility, dignity of delivery, and any incidents of misconduct or coercion, with findings reported internally within 72 hours;
4) Conduct monthly coordination meetings with other humanitarian actors, including food security and early recovery cluster members, to share lessons learned and adapt strategies to changing conflict and access dynamics;
5) Document all HRDD decisions, risk flags, and mitigation actions in the HRDD Decision Log, noting the date, responsible staff member, action taken, and outcome, to ensure institutional continuity and accountability; and
6) Ensure that livelihood activities embedded in the project — including cash-for-work and skills training — comply with ILO core labour standards, prohibit child labour, and include gender-sensitive workplace safety measures.
- Monitoring and Evaluation (Tracking Progress and Impact) Phase
During the monitoring and evaluation phase, the NGO should:
1) Develop specific, measurable human rights indicators, including: a) percentage of beneficiaries disaggregated by assessed levels of need, including by sex, age, disability status, displacement status, and documentation status; b) number of reported incidents of aid diversion, discrimination, or SEAH, and percentage resolved within the agreed timeframe; c) percentage of livelihood participants reporting improved food security outcomes, disaggregated by gender and displacement status; d) quantity of waste properly managed or recycled; and e) number of partner due diligence reviews conducted and findings documented;
2) Conduct quarterly human rights impact reviews that assess whether the project has caused, contributed to, or become directly linked to any human rights harm, and whether the original risk ratings remain accurate in light of changing conditions;
3) Verify partner compliance with the human rights obligations established in the partnership agreement — including SEAH obligations, data protection protocols, and aid diversion safeguards — through desk review and field spot-checks;
4) Publish monthly summaries in accessible language detailing the project’s human rights impact assessments, SEAH incident responses, partner compliance findings, and outcomes, in accessible formats for the affected community; and
5) Update the HRDD Decision Log at the close of each reporting period, documenting lessons learned and flagging any unresolved risks for escalation to senior management.
- Exit and Transition (Handover and Closure) Phase
During exit and transition planning, the NGO should:
1) Develop an exit strategy that explicitly considers potential human rights implications, including the risk of abrupt withdrawal creating dependency, reducing access to food, or leaving vulnerable groups — particularly undocumented individuals and female-headed households — without alternative support mechanisms;
2) Conduct a final human rights impact review covering all sectors addressed by the project, assessing residual risks and unresolved harms, and documenting recommended follow-up actions for handover to successor organisations or coordination bodies;
3) Ensure that all beneficiary data is handled in compliance with data protection obligations at the point of exit, including secure deletion, transfer with informed consent, or archiving in line with the organisation’s data retention policy;
4) Share lessons learned — including HRDD Decision Log findings, CFM data, and partner compliance outcomes — with relevant cluster coordination mechanisms and the wider humanitarian community to contribute to collective learning; and
5) Communicate transparently with affected communities about the timeline, rationale, and arrangements for transition, ensuring that referral pathways to other services remain operational and that community feedback on the exit process is recorded and addressed before closure.
VI . Cross-Cutting Obligation: Communicating and Being Accountable to Affected Populations
Transparency and accountability to affected populations are not confined to a single project phase but constitute a continuous obligation running throughout the entire project cycle. The NGO should give practical effect to this obligation as follows:
1) Make the CFM visible and functional. The CFM must be actively publicised — not merely established. Information about how to submit feedback or a complaint should be displayed at all distribution and livelihood activity points, shared through trusted community intermediaries, and communicated verbally during distribution to account for low literacy levels. Dedicated, confidential channels for SEAH complaints must be kept strictly separate from general grievance channels, with female staff available to receive complaints from women and girls.
2) Close the feedback loop. Receiving feedback is insufficient without a visible response. The NGO should communicate back to communities — in appropriate language(s) and through the same channels used to receive the original feedback — on actions taken in response to complaints or suggestions, within an agreed and publicly communicated timeframe. Where a complaint cannot be resolved, the reason should be explained clearly to the complainant.
3) Enable community oversight. A community oversight committee — with balanced representation across sex, age, displacement status, and ethnicity — should meet no less than monthly during active implementation to review distribution quality, raise concerns, and receive updates from project staff. Meeting minutes should be shared with the community in an accessible format and retained in the project file for accountability purposes.
4) Report publicly and accessibly. Monthly project updates should be produced in plain language and shared with the affected community through appropriate channels, covering what was delivered, to how many people, any human rights concerns identified, and how they were addressed. These updates serve a dual function — they fulfil the organisation’s accountability obligation to rights holders and contribute to the evidence base for donor reporting and cluster coordination.
5) Commission independent review. At least once during the project cycle — and again at exit — the NGO should commission a locally-based civil society organisation or protection actor to conduct an independent assessment of the project’s human rights impacts. Findings, including critical ones, should be shared with cluster coordination mechanisms and used to inform adaptive management decisions.
6) Document accountability actions in the HRDD Decision Log. All communication and accountability actions taken under this obligation, including community briefings conducted, CFM complaints received and resolved, oversight committee meetings held, and independent review findings, should be recorded in the HRDD Decision Log. This ensures that accountability to affected populations is not only practised but also evidenced, traceable, and available for review by senior management, donors, and coordination bodies.
7) Document implemented measures. Maintain records of all HRDD assessments conducted, risk flags identified, decisions made, and mitigation actions implemented in the HRDD Decision Log, noting the date, responsible staff member, action taken, and outcome for each entry. Share relevant lessons learned with donors and coordination mechanisms at agreed reporting intervals.