Transparency Policy

1. POLICY AIM

The Transparency Policy describes the approach and methodology of the Haklara Destek Programme regarding the matter of transparency. As a project implemented with EU financing, the Haklara Destek Programme takes into consideration the EU Complaints Mechanism Principles and relevant EU project implementation instructions and regulations.

2. OPENNESS

This policy has been set within the framework of openness and transparency including the public sharing of all information regarding actions and activities within the grant program and this program, as long as there is no valid exception. This framework, in turn, is based on the principles of non-discrimination and equal treatment in line with EU legislation and internationally accepted procedures. The Haklara Destek Programme attaches importance to acting transparently regarding its decision-making mechanism, operation principles and implementation methods regarding EU policies. This transparency strengthens the reliability and accountability of the program. Transparency also contributes to the increase of the productivity, efficacy, impact and sustainability of the project. The Haklara Destek Programme defines transparency as the intelligible, accessible and timely sharing of necessary information, decisions and documents, with applicants, potential applicants, the Delegation of the European Union to Turkey and other project partners, in other words, with the public in the general sense.

3. INSTITUTIONAL FRAMEWORK

The Haklara Destek Programme is a grant scheme created with the financing of the Delegation of the European Union to Turkey and in partnership by Hafıza Merkezi (HM) and Heinrich Böll Stiftung (HBS), aiming to increase the capacity of rights organizations in Turkey to contribute to the development and institutionalization of human rights and democracy. The program is a sub-grant scheme implemented within the scope of the grant scheme titled “”Building Resilience, Strengthening Human Rights: Human Rights Support Mechanisms in Turkey”.

Within this scope, institutional grant support will be provided to around 50 rights organizations based in Turkey for a period of one year, and a guidance/training program that will contribute to the development of institutional capacity and contribute to the strengthening of their impact, and will be provided to CSOs that have earned the right to take part in the program.

The Haklara Destek Programme has been designed to contribute to the development and institutionalization of human rights and democracy. For this purpose, in line with the conformity criteria stated in Section 2.1 of the Application Guide, the program is open to all applications and activities striving to contribute to the strengthening of human rights and democracy and are based on the principles of fair competition, equal opportunity and transparency.

The application process for the Haklara Destek Programme will begin in September 2019 with information meetings and implementation will begin following the signing of contracts in May 2020 with CSOs that have earned the right to take part in the program. The implementation process is planned for the period from 1 June 2020 to 31 May 2021.

The Haklara Destek Programme ensures the activities of CSOs receiving grant support are realized within the framework of respect to EU policies and laws, and in cases of exception, takes EU policies and laws as reference. The first article of the Treaty of the European Union[1] beings with a reference to the principle of openness. According to Article 11 of the Treaty on the Functioning of the European Union, the Union’s institutions, bodies, offices and agencies shall conduct their work as openly as possible in order to promote good governance and ensure the participation of civil society. Accordingly, in enlargement countries, public administration and institutions are expected to attach importance to the principles of transparency and accountability. All institutions are also expected to provide transparency in their operations and include specific provisions regarding access to information.

4. PUBLICATION OF INFORMATION

In order to support and encourage the transparency principle, the Haklara Destek Programme shares, in a timely and regular manner, accurate information about its policies and work. For this purpose, a broad set of documents is published during the program. Along with the Transparency Policy, the following are the documents that support the fundamental principles:

  • Application Guideline and Annexes
  • Application Form
  • Frequently Asked Questions
  • Visibility Guideline
  • Document for Rights-Based Organizations
  • Notice and Consent Text Regarding the Processing of Personal Data

The Haklara Destek Programme will also share information regarding the program with information meetings to be held in five cities, and a webinar and other social media applications in digital environment. The main tool used for the dissemination of these documents and information is the Haklara Destek Programme website (www.haklaradestek.org). All information related to the program is provided via this web site in accordance with the principles of fair competition, equal opportunity and transparency.

The names of the CSOs that have earned the right to benefit from the program are shared with the public via the web site. The final decision regarding what information will be shared with the public within the boundaries set by prevailing laws, regulations and EU legislation applicable to the Haklara Destek Programme.

5. INFORMATION FOR APPLICANTS AND POTENTIAL APPLICANTS

Institutions that would like to apply to the program can access the necessary information via the web site using the tools referenced in the fourth section. Applicants that access the system by registering at the web site of the Haklara Destek Programme are given an application tracking number after they have completed their applications. Within the period defined for the application process, demands for information in addition to the questions included in the Frequently Asked Questions section are to be sent to the e-mail address basvuru@haklaradestek.org. New questions from applicants and their answers are published together on the Program’s web site, without indicating the person/institution that posed the question, on the second day of the week following the communication of the questions. In this way, the right to equal access to information is realized.

6. DISCLOSURE OF INFORMATION

All information and documents produced within the scope of the Haklara Destek Programme are subject to sharing as long as there are no acceptable grounds requiring them not to be disclosed. All users applying to the program are asked to give their consent for their personal information to be shared with third parties in an electronic environment. The contract document (Notice and Consent Text Regarding the Processing of Personal Data) at the Program’s web site is related to this policy.

Social media handles are legally dependent on the hosting services of relevant companies (Facebook, Twitter, Instagram, YouTube) including all accounts that are part of these services.

7. EXCEPTIONS

The Haklara Destek Programme adheres to its Transparency Policy, and also is obliged to respect, in accordance with EU legislation, the right to privacy in order to protect personal data and observe the national code. For this purpose, there are a number of limitations regarding the sharing of information/documents. Most particularly, EU legislation on the protection of personal data requires that access to such information is blocked if and when the sharing of information endangers the “public good” and the “protection of the integrity and privacy of the individual.” Information is not shared under the circumstances listed below:

  • If commercial interests of private or legal persons are in question;
  • If said information is within the scope of intellectual property, court procedure documents or legal advice;
  • If the information is subject to inspection, investigation and/or audits;
  • If the applicant has not given consent.

8. CONDITIONS FOR FILING COMPLAINTS

Applicants or other private/legal persons who believe they have been negatively affected by the Haklara Destek Programme and its actions, or who believe they have suffered damages due to a mistake or irregularity during the selection process may send a complaint email to the address: sikayet@haklaradestek.org. Complaints must be sent within 10 working days after the date of the events the claims are based on are confirmed by the complainant to have taken place. Complaints received within the designated period are responded within 15 working days.


[1] https://eur-lex.europa.eu/resource.html?uri=cellar:2bf140bf-a3f8-4ab2-b506-fd71826e6da6.0023.02/DOC_1&format=PDF