Comprehensive Traceability Principles
Pathway to the Principles
The Pathway to the Principles details steps to apply the Principles when administering or improving a comprehensive electronic catch documentation and traceability (eCDT) program. A seafood traceability program that is comprehensive means it uses captured data to realize three potential benefits: ecological, social, and economic. Three phases (Initiate, Design, and Implement) guide users through a series of potential steps when administering a comprehensive eCDT program.
Featured at the left of each step is the icon matching one of the six relevant Principles. Clicking on any of the steps will reveal more information and examples of relevant guidance to support application.
Principles Key
Maximize ecological, social, and economic benefits
Be inclusive and collaborative with stakeholders
Use data to inform decision-making
Build a lasting and scalable program
Create a program that is electronic, interoperable, and data secure
Address data and verification needs across fisheries and supply chains
1- Define goals and scale of eCDT system
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
2- Learn from existing systems
- Review past eCDT programs and lessons learned to avoid common pitfalls. Consider reviewing recommendations from traceability programs outside of seafood to understand data needs
principle applied:
Use data to inform decision-making
Use data to inform decision-making
Relevant Guidance
3- Conduct research, assessment, or gap analyses on the existing systems and enabling environment to identify supporting regulatory frameworks, enforcement, and political will
- Identify and access what exists to support the comprehensive eCDT program (i.e., infrastructure, data and data systems architecture, regulatory enforcement measures, interested institutions, or relevant private sector initiatives)
- Assess stakeholder and institutional perceptions of the possibility of an entirely new program, including its socio-economic impacts (cost implications of developing, adopting, using, etc.) to mitigate unintended consequences such as negative environmental or human rights impacts
- Consider analyzing the different impacts to men/women and other key stakeholder demographics
- Leverage existing or encourage creation of supportive partnerships between governments and businesses in order for both groups to best fulfill their complementary roles as outlined in the UN Guiding Principles on Business and Human Rights
- Check for norms, policies, and government enforcement regarding health and safety, core human rights principles (i.e., the ILO core conventions, engagement with national or global trade unions), and the right to free speech without fear of retribution, to stay abreast of the law or identify any human rights gaps
principle applied:
Use data to inform decision-making
Use data to inform decision-making
Relevant Guidance
4- Characterize the supply chain
- Conduct a general overview of involved fisheries, including current catch documentation, reporting, and social responsibility data collection practices across government agencies
principle applied:
Use data to inform decision-making
Use data to inform decision-making
Relevant Guidance
5- Assess existing exposures and risks
- Assess existing exposures and risks of IUU fishing for relevant stocks and supply chains, including enabling mechanisms to mitigate the seafood value chain risks (if any)
- Specify risk data sources and needs
- Identify related governing agencies or departments
- Assess existing exposures and risks of human rights abuse for people working in or associated with relevant stocks and supply chains, including enabling mechanisms to strengthen policy for worker protections, such as the right to freely associate and collectively bargain, and/or general social safeguards, such as protections for free speech and human rights defenders
- Specify existing risk data sources and needs, including time spent at sea, captain’s logs, or instances of at-sea transshipment, recruitment dynamics, and risks to fishers’ families
- Identify related civil society organizations, worker associations including trade unions, governing agencies, or departments (such as Departments of Labor or Employment) that work on human rights risk, abuse, policy, and/or data collection
principle applied:
Use data to inform decision-making
Use data to inform decision-making
Relevant Guidance
6- Gather economic data to prepare for cost-benefit analysis
- Collect baseline data of costs involved with current fisheries management system, including food safety and regulatory compliance
- Set expectations around a feasible return on investment, as financial returns may take time to manifest
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
7- Be inclusive in identifying stakeholders
- Properly identify the stakeholders from governments, affected fisheries (including small-scale), technology/service providers, supply chain companies, trade unions and other worker/labor groups, whether aiming to develop an eCDT program on an international, national, or regional level that meets those stakeholders’ needs
- Identify if the program will impact marginalized and disenfranchised stakeholders (including migrant workers and women) and take steps to build trust and include them
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
8- Communicate incentives/benefits to foster stakeholder participation
- Identify and clarify the value proposition of eCDT to a variety of stakeholders (business, compliance, science, workers, etc.)
- Be transparent with stakeholders about the potential benefits of the program that have been demonstrated in other programs, the intended scope, and the degree to which there is flexibility
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
9- Consult stakeholders early, repeatedly, and with sensitivity to their needs
- Identify the preferred form of communication and makeup of stakeholder groups--ensuring equitable inclusion across marginalized and disenfranchised groups--which will depend on scope, objectives, and fishery characteristics
- Via stakeholders’ preferred outreach method, integrate knowledge and build accountability and trust
- Consider power dynamics and relationships among stakeholders in the consultation process (e.g., workers and businesses, men and women, government and private sector)
- Identify key stakeholders, such as trade unions and other fishers’ rights organizations, to support sensitive program needs, such as workers’ access to grievance and remedy
- Civil society organizations can support workers and program implementers in upholding key human rights needs (e.g., grievance and remedy) by helping uphold workers’ rights, which often requires specialized skills and experience
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
10- In consultation with stakeholders, clearly define objectives (ecological, social, and economic) of the comprehensive eCDT program
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
1- Map data needs and constraints along full supply chain
- Define the minimum data required to meet program objectives
- Identify where more information is needed to define data/tech needs
- Map key data elements (KDEs) to critical tracking events (CTEs) within affected supply chains and identify where CTEs start and end given the different jurisdictions among different players (regulators, stakeholders, regional bodies, etc.)
- Avoid requiring duplicative information
- Minimize exemptions from eCDT program data collection, but state clearly where they do exist (e.g., small-scale fishers, certain vessel types, instances in which data collection on workers may be used against them)
- Where appropriate, ensure that the program is vendor neutral and that transparency mechanisms (public requests for proposals, for example) are mandatory when competing for government contracts
principle applied:
Address data and verification needs across fisheries and supply chains
Address data and verification needs across fisheries and supply chains
Relevant Guidance
2- Design eCDT program with verification needs and challenges in mind
- Create a data quality assurance protocol that includes a plan for verification
- Identify how and where data will be verified
principle applied:
Address data and verification needs across fisheries and supply chains
Address data and verification needs across fisheries and supply chains
Relevant Guidance
3- Ensure data security and data access protocols
- Clearly define who has access to the data and for what purpose, with special considerations to worker privacy
- Prioritize informed consent and participant access to data
principle applied:
Address data and verification needs across fisheries and supply chains
Address data and verification needs across fisheries and supply chains
Relevant Guidance
4- Identify potential pilot sites
- Select supply chains that are well-understood and sites that have on the ground (industry and NGO) support
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
Relevant Guidance
5- Design eCDT program to fit within larger fisheries management program
- To inform alignment decisions, identify differences between the proposed eCDT program and the existing national strategy for fisheries management
- Consider those who may not have had any input in the design of the existing program, and how their perspectives and opinions might have changed the design
- Align data collection with stock assessment and/or integrate with existing fisheries management plans to ensure sustainable fishery management and promote biodiversity conservation
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
6- Identify how worker welfare will be monitored and supported
- Identify governing agencies that have jurisdiction over data related to worker welfare and data security issues (e.g., Departments of Labor and/or Employment and enforcement of minimum wage, immigration status, and healthcare requirements) to increase the relevance and interoperability of any social data collected by the eCDT program
- Identify existing protocols for how to share social data with agencies that oversee worker information, and revise or create new protocols as need to improve worker welfare outcomes
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
7- Implement safeguards to mitigate negative impacts of data collection to worker rights and privacy
- Consult existing data privacy laws, and identify processes, accountability mechanisms or new schemes for responding to privacy considerations and stakeholder/user concerns as needed
- Connect eCDT program implementers and stakeholders to other rights monitoring, advocacy, and social support organizations and systems (e.g. trade unions, migrant advocacy organizations, human rights advocates, and other civil society organizations)
- Confirm fishers and other workers have access to confidential grievance and remedy systems
- See definitions for ‘grievance mechanisms’ and ‘remedy’ in the Glossary for Comprehensive Principles
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
8- Seek to minimize costs
- Require only the minimum technology adoption and data collection needed to meet eCDT program objectives
- Identify technology that adds value to businesses’ bottom line; ensure there is a built-in cost-recovery scheme
principle applied:
Create a program that is electronic, interoperable, and data secure
Create a program that is electronic, interoperable, and data secure
Relevant Guidance
9- Avoid creating trade barriers
- Ensure that the program is compatible with the traceability requirements of major importers (e.g., SIMP, European Union)
principle applied:
Create a program that is electronic, interoperable, and data secure
Create a program that is electronic, interoperable, and data secure
Relevant Guidance
10- Clarify roles, responsibilities, and needs by stakeholder
- Identify expertise and capacity of stakeholders and leverage existing expertise
- Be aware that implementation roles and responsibilities for eCDT programs will vary across nations (e.g., flag, coastal, port, processing, end-market)
- Be aware that financial or capacity support may differ between developed and developing nations
- Define roles and capacity of both private sector and government bodies, especially within the various government agencies implementing the principles including labor, employment, and food safety (e.g., Who will cover the costs? Will the development process involve partnerships between government and industry?)
- Identify existing worker groups that can contribute to identifying worker roles, responsibilities, and needs (e.g., worker committees, trade unions, and other civil society organizations)
- Outline the role of individuals or companies collecting, verifying, and submitting data
- Identify opportunities for stakeholders–particularly civil society organizations–to provide oversight of the eCDT program and governance structures
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
11- As needed, formulate agreements between agencies for the sharing of information and responsibilities
- Explicitly identify the responsibilities and authorities of each agency as it pertains to the goals of the comprehensive eCDT program
- Determine how to best integrate processes of various involved agencies for efficacy of the program
- Determine whether agencies require technical assistance or capacity building to construct the data management system, and if so how they can obtain that assistance
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
12- Ensure stakeholders from relevant supply chains formally agree to support the eCDT program
- Obtain both commitment and action (implementation, monitoring, control, and enforcement) all the way along supply chains to derive counter-IUU fishing and worker protection benefits
- Recruit influencers to support program adoption (e.g., community leaders, association heads, industry champions, thought leaders, key local government officials) and to test the program
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
13- Identify eCDT technologies to fulfill data collection and analysis needs
- Let data collection, program objectives, and user needs drive eCDT tool selection
- Define the architecture of the system (e.g., central repository, distributed ledger)
principle applied:
Create a program that is electronic, interoperable, and data secure
Create a program that is electronic, interoperable, and data secure
Relevant Guidance
14- Develop eCDT programs and technologies with “human-centered design” approaches
- Use site-specific approaches or designs where possible, but customization should still support interoperability
- Consult with technology users before and during implementation (see: ‘Initiate’ section)
- Use co-creation to develop the program as it can foster buy-in and ownership among users
principle applied:
Create a program that is electronic, interoperable, and data secure
Create a program that is electronic, interoperable, and data secure
Relevant Guidance
15- Prioritize interoperability with existing traceability programs and data
- Build on existing and planned investments
- Use standardized data formats (i.e., KDEs)
- Consider alignment with industry data standards (e.g., GDST Version 1.0) and import data requirements of market states (e.g., U.S. SIMP)
- Where there are national electronic traceability platforms, allow them to interface with eCDT systems, including private sector systems
principle applied:
Create a program that is electronic, interoperable, and data secure
Create a program that is electronic, interoperable, and data secure
Relevant Guidance
16- Encourage the adoption of these Principles into policy
- Encourage policy adoption/development to strengthen eCDT support at the governmental level
- Generate community support for the eCDT program where possible
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
Relevant Guidance
17- Estimate funding needs and responsibilities to fund the program sustainably
- Develop plan for long-term funding to support all steps of program implementation
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
Relevant Guidance
18- Plan to adaptively manage the eCDT program
- Build in designated time periods for monitoring and adaptation, particularly from the entities providing oversight
- Design the program with a forward-thinking mindset by enabling possible use of modern and emerging technology in data analytics
- Avoid prescribing a specific technology so that the program can adapt to changes
principle applied:
Use data to inform decision-making
Use data to inform decision-making
Relevant Guidance
1- Pilot test the eCDT program
- Formalize partnership with the users and supporters who will be the first implementers
- Deploy technology
- Implement mechanism to receive and integrate feedback from the first implementers
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
Relevant Guidance
2- Provide user assistance, technical support, and capacity building as needed
- Provide training to stakeholders across the supply chain
- Training and support could be to encourage uptake of the program, promote maintenance, or build capacity for the analysis and interpretation of data collected
- Use culturally effective methods and ensure instructions are available in useful formats
- Conduct stakeholder consultation to gather feedback
principle applied:
Be inclusive and collaborative with stakeholders
Be inclusive and collaborative with stakeholders
Relevant Guidance
3- Monitor and evaluate the efficacy of the eCDT program by analyzing data to determine if objectives (ecological, social, and economic) are being met
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
4- Document costs of eCDT program implementation and project costs of long-term operation
- Conduct cost–benefit analysis and/or a return-on-investment (ROI) study using the collected baseline economic data
- Consider conducting an economic impact study for government initiatives to advocate for sustained funding from state budgets
- Identify other business drivers (e.g., facilitation, trade preference)
- Consider documenting and publicly reporting environmental, social, and ecological benefits
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
5- Assess the benefits, limitations, and challenges of the program in relation to equity and worker welfare
- Analyze worker participation in the creation and implementation of the eCDT program
- Track and resolve concerns raised from workers regarding the program’s efficacy and privacy
- Evaluate the alignment and complementarity (as well as any gaps) in the roles of eCDT implementers and governmental agencies that monitor labor
- Continue to strengthen the dialogue between fisheries operators and labor monitoring agencies to confirm that the data gathered is used for implementation and/or enforcement of human rights laws and other social benefits
- Monitor, evaluate, and adapt as needed
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
6- Evaluate whether data is accessed timely and analyzed usefully for fisheries management
- Ensure necessary agencies have clear data flows for assessing efficacy of the fisheries management strategy
principle applied:
Maximize ecological, social, and economic benefits
Maximize ecological, social, and economic benefits
Relevant Guidance
7- Utilize monitoring and evaluation tools to assess eCDT program performance and identify opportunities for adaptive management
- Adapt and scale technology based on user feedback
principle applied:
Use data to inform decision-making
Use data to inform decision-making
Relevant Guidance
8- Outline scope and objective for scaling
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
Relevant Guidance
9- Identify differences between the pilot and other areas for implementation
- Determine how objectives of the scaled program overlap and differ from that of the pilot
- Assess resources for scaling: are the funds, staff, infrastructure, political will, and resource commitments still present and appropriate for the scope?
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
Relevant Guidance
10- Return to the ‘Initiate’ section when necessary
principle applied:
Build a lasting and scalable program
Build a lasting and scalable program
see all of the Pathway steps