Disclosing a RAP: what has to be published, where, and in what language

Disclosure is a dated act with an audience, not a file uploaded to a website. The distinction matters because disclosure is what converts a plan into something affected people can hold the project to, and because it is one of the few safeguard obligations whose discharge is either evidenced or not.

What has to be disclosed

The resettlement instrument itself, in full, before implementation begins. In practice a project needs three artefacts rather than one, because the full plan is not a document a rural household can use.

• The plan, complete, in the official language, publicly accessible and left accessible.
• A summary in the local language covering the parts that affect decisions: eligibility, the entitlement matrix, the cut-off date, rates, the grievance route and the timetable.
• Individual entitlement statements, each household's own recorded assets and calculated entitlement, disclosed to that household with time to respond before signature.[1]

The third is the one most often skipped, and it is the one that determines whether the first two mattered.

Where, and in what form

A website is necessary and insufficient. Disclosure has to reach the affected population where it is, which means physical copies at locations people already use — the local government office, the parish or ward office, a school, a place of worship — announced in a way people actually receive, and read aloud where literacy cannot be assumed.[2]

Language is not a formality. A summary translated into a national lingua franca that a third of the affected community does not read is a partial disclosure, and the third it misses will predictably be the older, poorer and more rural part of the population.

The test is not whether the document was made available. It is whether a person affected by it could obtain it, in a language they read, without travelling further than they usually travel.

Timing against project decisions

Disclosure has to precede the decisions it concerns, and the sequence is testable:

1. Cut-off date disclosed before or at enumeration, not after.
2. Entitlement framework disclosed before individual offers are made.
3. The plan disclosed before implementation, with a period to comment.
4. Individual statements disclosed with enough time before signature for a household to query them.
5. Any revision to rates or entitlements re-disclosed to everyone affected by it.

Where disclosure occurs after the fact, the project has published a record rather than consulted, and a reviewer comparing disclosure dates to payment dates will see it immediately.[3]

Evidencing it

For each disclosure event the file should carry: what was disclosed, in what version and language; the date; the locations and how they were chosen; how the event was announced; who attended or received a copy; what was asked; and what answer was given. Photographs of a notice board, dated, with the notice legible, are worth more than a paragraph asserting that disclosure took place.

Keep the versions. Where an entitlement matrix is revised, the disclosed version at each point in time is the thing a completion audit needs, and a single document overwritten in place cannot produce it.[4]

Comment periods that are real

A disclosure period with no mechanism to receive comment is publication. The minimum is a named person, a physical location, and a channel that does not require literacy — with every comment logged against the same register the grievance mechanism uses.

Comments should be answered individually where the commenter is identifiable, and the plan should record which comments changed it. That record is the single most persuasive piece of evidence that consultation was meaningful, and it takes an afternoon to compile if the log exists.

Confidentiality and personal data

One caution runs the other way. Individual entitlement details are personal data, and publishing a full register of names, holdings and amounts creates real risks — intra-family conflict, targeted theft, opportunistic claims against the recipients.

The workable position is to disclose the framework publicly and the individual determination privately to the person concerned, with a public list limited to what is needed to allow objection: names and parcels, without amounts. That balance satisfies both the objection process and the duty not to expose people by publishing what they are about to receive.