Day 3: Long-term ethical, legal and policy changes needed to move from the current scenario to the desired scenarios

Hello Everyone

Welcome to Day 3 of this E-Consultation on the ethical, legal and policy aspects of data sharing affecting farmers. I am about 10 hours ahead of many of you so I thought I would being our discussion a little earlier with a few thoughts.

My name is Leanne Wiseman  I am also excited to accept the challenge of moderating  Day 3 of our discussion. This discussion will begin on Wednesday the 6th June.

Today we would like to focus on the  Long-term ethical, legal and policy changes needed to move from the current scenario to the desired scenarios.

We have been provided with some guidance of some points for our discussion so I look forward to hearing your thoughts and suggestions as to how we address some long terms goals.

• Ethical: what are the ethical questions we should make to contribute to increase food and nutrition security and better livelihoods of the poorest and most vulnerable farmers around the world by harnessing their access to and use of agricultural data? How should our mindset change in the long term about data rights? Should data rights be recognized as human rights? Should we still consider receiving a service in exchange for surrendering data an ethically acceptable business model?

The issue of whether data rights should be recognized as human rights is an interesting notion. Certainly the introduction and impact of the GDPR in the EU and also the soon to be introduced Consumer Data Right (CDR) (see http://dataavailability.pmc.gov.au/consumer-data-right) that will be introduced into Australia, sector by sector, in the near future  reinforces the notion that individuals should have the right to data that is generated about them or by them. 

There is a useful discussion here of data as a human right http://www.ohchr.org/Documents/Issues/HRIndicators/GuidanceNoteonApproachtoData.pdf

• Legal: what do you think are the best legal approaches to achieve the desired scenarios? How to recognize and implement farmers’ intellectual property rights over their data and traditional knowledge? How should the licensing scenario change?

When thinking about the best legal approaches to solve problems,  the law can be a very blunt and inflexible tool when trying to encourage behaviour change. It is often 'soft' law or policy driven changes that are more influential in influencing and shaping behaviour. How can the current data licensing practices be changed to ensure a more equitable outcome for famers? How best can traditional knowledge, particularly in relation to farmining practices be safeguarded from exploitation?  Empowering our farmers and their communities with the tools to realise the value of their information is one positive step. How can this be done?  Should not the onus of changing the current licensing practices come from regulators who can shape the conduct of multi-nationals by requiring more transparency and openess about their data management practices?

While we have seen the adoption of data principles and codes of conduct around data management, which have resulted in the raising of awareness of the issues of data sharing and the potential for misuse, there has been little  uptake by multinationals. How does 'best practice' of data management and use be embedded into businesses' social conscience?

• Policy: what strategies and priority areas of intervention would you recommend at the policy level? Do you think there should be more governance and by whom? Do you think international agreements could help?

 We have seen the positive impact of international agreements such as the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization to the Convention on Biological Diversity (CBD) so there is clear evidence that international treaties can make a positive change to behaviour.

An interesting question is whether agricultural data/ farm data is sufficiently meritorious of a new independant treaty or whether the international shift, such as the GDPR etc around the need for better data managemetn practices around consumer data are sufficient to provide coverage for  the issues arising from the increasing collection, aggregation and dissemination of agricultural data? Some would argue that agronomic and agricultural data has a significantly different value proposition to that of consumer data ? others disagree ?

Looking forward to your contributions to what long-term ethical, legal and policy changes that need to happen

A strategic insertion of digitized agriculture data can best be explained, perhaps, by way of example specific to nutrient management.  Nutrient management is extremely complicated to implement in the best of conditions given the rate and timing of nutrient application, its placement as well as the measurement and assessment.  These data points also need to be algorythmically evaluated together with other variables like soil condition and weather.  It seems undeniable to many that leveraging digitized and artificially-intelligence enabled supply chain data flows from sensors and satellites and more, on behalf of the very best nutrient management practices, will have the largest most immediate impact on lives of farmers due to higher quantity and quality of production.  A key challenge is that in order to reach the fullest potential for nutrient management the agriculture sector must become more aware of the technology, business model and economic dynamics of blockchain, sensors, UAV's,  wires, satellites, controllers, monitors, computer programs and more.  How do we respond to this key challenge?  I just read a wonderful report by FAO on unmanned aerial vehicles (UAV's) with multiple case studies on their use in rice and other crops.   

Meanwhile, there is rapidly emerging the formation of cross sectoral partnerships to deliver agriculture digital solutions.  It includes agribusinesses, mobile network operators, financial institutions, civil society, etc.  From Ghana to Kenya and points in between agribusinesses, MNOs, donors and others have partnered and are continuing to partner on multiple initiatives.  A key challenge here is how can we begin to codify a strategic approach to the formation of agriculture digital solution alliances?  This codification can be best served by first having this discussion about ethics, legality and policy.  

To the ethics question for today:  There is signficant investment by global, regional and local agribusiness and other private sector players to deliver digital products and services to farmers.  What is missing from their investment decisions is any real farmer perspective or voice.  This discussion we are having is vitally important so that we can consider the ethics, legality and policies in order to help the farmers share their voice with the supply chain from their cell phone.   Key ethical considerations include data ownership and data privacy.  I recently wrote about the General Data Protection Regulation (GDPR) and its contrast to blockchain technology here:

https://medium.com/@leebabcock/digital-version-2-0-for-poor-farmers-1d97b8384a27 

To the legal and policy questions for today:  What kind of policies do we need?  An analogy is the European 'principles-based' International Accounting Standards (IAS) compared to the U.S. 'rules-based' Generally Accepted Accounting Standards (GAAP).  This is like comparing 15 pages of IAS 'policy' guidance to 5000 pages of GAAP 'policy' guidance.  When we think about policies and standards for agriculture data are we thinking about 'principles' or 'rules' or both?   When we kinda have an eye on what type of policies and standards this will best inform our thinking about legal issues.  

Since we're supposed to think of long-term changes to move towards the desired scenarios, for those who didn't follow the discussion yesterday here is a recap of some common points in scenarios envisioned by participants (you can also look at the more detailed summaries by Manuel Ruiz yesterday, from which I borrowed something, thanks Manuel!).

Many of Leanne's suggestions can be usefully discussed in relation to these scenarios.

1. There will be cooperation /collaboration not competition, trust, free flows and exchange of data: several participants envisioned an ecosystem where different actors share data for mutual benefit

2. Common data platforms, data shared in the cloud, "organized data communities": all farmers' data shared with other farmers but also platforms where all necessary data from outside the farm is shared (weather, financial, market...); farmers organized and registered in a platform that brings in also big service providers; some participants envisage centralized platforms.

3. Organizational aspects: associations / cooperatives / "virtual aggregations" allowing for larger scale planning of farmland and cropping cycles, more efficient access and use of farm inputs, more precise forecast, better marketing. 

4. Specificity: data, products and processes for data driven agriculture must be context specific, designed to suit the conditions of farmers; weather data will be broadcast in a language understood by farmers, market data will be available via messaging updates and through tradition media; technologies co-developed with farmers; traditional knowledge recognized

5. "Success": improving not only production but contributing to overall welfare and and improved livelihoods; success interpreted in a social way (environment, food security, health, equality, transparency) or from the point of view of the farm as a business?

6. Related to point 2, data protection and transparency: data shared with appropriate licenses; through blockchain technology for maximum transparency.

7. Envisioned roles of actors: government ("our government will have repositories for farmers data and data related services available all the time"), private sector (providing technologies and services, using farmers' shared data with no unfair advantage, but still with the comparative advantage that comes with better processing and application of the data), intermediaries (enabling smallholder farmers to structure, organise and make use of any data that might be available), farmers organizations (aggregating farmers' data, negotiating data access on their behalf). Everything to the benefit of the farmer.

Dear all,

Sorry I was not able to participate in the first two days of the consultation due to an overbuderden agenda. I have read the contributions of day 1 and 2 and may in the course of this discussion  come back to some of the issues discussed previously. Let me start by stating my interests in this topic:

1. I am big data focal point at CIMMYT

2. I chair our Internal Research Ethics Committee

3. I coordinate the community of practice on socio-economic data, which is part of the CGIAR Platform for Big data in Agriculture

4. I lead the foresight ex-ante impact assessment and targeting research at CIMMYT, hence a keen interest in all things future.

Prior to the 20th century, scientists guarded their findings meticulously and only expanded on them after they were many steps further and considered their previous scientific discoveries less valuable. Today scientists rush to publish their findings to be the first. While till recently research data was guarded by scientists, it is becoming common practice in many settings to share data sooner than later. I don't think anybody has any qualms about bringing their old newspapers to a paper recycler, knowing that the recycler is making some money. So let's not get too hung up on data sharing.

Having said that, data that contains personally identifiable information is a different matter. Its use may pose risk to the subject of that data. It is therefore useful to distinguish between data with and without identifiers. Note that high resolution satellite images fall under the heading of personally identifiable information.   

The main question at stake here is farmer level data and how that can benefit those farmers, especially the poor farmers in resource scarce environments who have not been benefiting from global economic development. The promise of data-driven agronomy (not necessarilly precision-ag) holds in store for accelerating productivity for ppor farmers requires some level of data-sharing.  GDPR offers some useful pointers in a direction that it may evolve. 

1. Consent: The data subject should provide unambiguous positive consent regarding the processing of his/her personal data for specific purpose(s).
2. Performance of contract: The data in question should be processed in order to allow/facilitate the performance of a contract that the data subject is part of. Data processing can also be a way for the data subject to initiate a contract agreement.

A service contract between a farmer and a service provider, whereby the service provider must guarantee the privacy and data confidentiality. Unless explicit consent is given the service provider cannot (legally) share that data with third parties.

Hyper ledger technology (HLT, better known as blockchain) is one way of dealing with personal data sharing since the authorization granting rights can stay with the original data provider (farmer)  if a system is set up that way. Think a few generation further than the current best HLT solutions and don't worry about the current drawbacks of, for example, bitcoin blockchain or Ethereum. 

Since technology is still developing and evolving rapidly, any policy such be principle based and not rule based, because rules are likely to be obsolete before they are published.

I'll chip in more later.

We have reached almost the mid-point of this consultation. Valeria has summed up the discussion very competently.

I accept that data driven agriculture and Agri-food systems is not possible without cooperation and collaboration of all actors in and stakeholders of these systems. However, we should not club cooperation with “no competition”. We should be very careful and be specific about “no competition”.  Let me explain, all data and data sets collected and collated are notional based on a framework developed by individuals or a group, either with a mandate or without. If we state that there should not be any competition, does this mean that we should not have any change in this framework of data collection? The consequence of “no competition” would mean freezing the framework and with it the data and dataset. This is akin to saying that “Standards” should not change and are set in stone. This, in turn, will block innovation and possible efficiencies emerging from innovations.  Farming, agriculture and Agri-food systems are constantly evolving and need continuous change and innovation in data and applications as new needs arise. How then will we cope with this change?

In my opinion, the most efficient way would be to develop platforms that “point” to A. The applications and B. The data needed by these applications for use by the various actors and stakeholders to an Agri-food system.  This allows innovation of all three, the data, the applications and the platform itself.

The Platform would be a “Trust Center” for the meta data to individual data providers as also for applications using the data. It will assure trustworthiness, security and, where needed, privacy for both the data and application. The Platform will also function as an “App Store”, something like Apple’s App store, where users can buy both the data and the applications they need. The platform will also prescribe the standards for interoperability, sharing and exchange of data between the applications.  These functions of the platform will thus provide an open market for both data and applications and therefore force competitiveness for the benefit of the users who will also get the flexibility through mix and match of interoperable data and applications so necessary in farming and the larger Agri-food system. The platform would be mandated in its functions by the Government. For small holder farmers, who may not be able to afford the use of data and applications or the information services, the Government and other agencies may offer support or subsidies.

Let me explain this further by the “CIARD.RING” led by GFAR. CIARD.RING has been envisaged as a “Trust Center” for agricultural research for development (ARD) related data and information which includes documents as also data sets. It collects and organizes meta-data about data and information repositories not the primary data which is maintained by the repositories themselves. It provides many of the services mentioned above. CIARD.RING encourages development of applications to use ARD information and data.

The “GeoAgri Gujarat” Project, now in development in Gujarat and where I am involved, is based on this concept of a platform as described above. It aims to provide a single window access to all services farmers (overwhelmingly smallholders) in Gujarat need related to their farming. Now, the Government is funding the creation of this platform. The initial data set is being defined by a Project Steering Committee and the applications needed initially are being developed and implemented by the private sector as the GeoAgri Gujarat is expected to be financially self sustaining and is a public-private-community partnership. Initially the data used by GeoAgri is expected to be “owned” by the Government and managed by the Project Steering Committee using private sector services.

Thinking of legal/policy changes that are needed to move towards the scenarios we designed yesterday, and considering what we said on the first day about not rushing into regulations, it could be useful to check if some existing framework that sets guidelines can be a good basis.

Both on the first day and today the GDPR has been mentioned on the one hand as a useful framework and on the other hand as something that concerns only personal data and therefore not sufficient. Another EU document could be more useful for us: the “EU Code of conduct on agricultural data sharing by contractual agreement”, drafted by “a coalition of associations from the EU agri-food sector” led by COPA COGECA. The aim of this code of conduct is to “ensure that data-sharing leads to a prosperous agri-food chain bringing benefits for all”.

Link: http://www.copa-cogeca.be/img/user/files/EU%20CODE/EU_Code_2018_web_version.pdf

This document is not conceived as a legal document and compliance is voluntary.

I think it’s interesting to check a few points against some features of the scenarios envisaged yesterday:

1. “This Code recognises the data originator’s right, whether they are a farmer or another party, to benefit from and / or be compensated for the use of data created as part of their activity. It also recognises the need to grant the data originator a leading role in controlling the access to and use of data from their business and to benefit from sharing the data with any partner that wishes to use their data.”

Yesterday we didn’t delve much into what rights we expect the farmer to have on their data, but Juanita spoke about recognizing the importance of the farmer as provider of data and Uchenna highlighted that ownership and rights related to digital agriculture must be balanced to protect the interests of smallholder farmers. Besides the Code is not very prescriptive regarding ownership, which, as someone observed in the e-discussion, might limit the possibility of working with data. And the idea that the farmer should benefit from data sharing underlies all the scenarios described yesterday.

2. “Access to data, be it in read-only or fully editable modes, should be strictly audited and any transfer or change to the data should be fully traceable, e.g. accompanied by metadata about the author and modification”. “Data originators should be granted appropriate and easy access and be able to retrieve their attributed (‘own) data further down the line”.

These points could be useful for those aspects of the scenarios that concern transparency (and e.g. the blockchain) and the idea that all farmers data is stored somewhere and always accessible to them.

3. “In order to facilitate data sharing, this Code encourages partners in the agro-food chain to set up tools to support decision-making systems for data originators as well as for data users that would allow them to integrate a vast array of data. This should involve different partners of the food chain, in particular data originators, in order to effectively contribute to their development and better respond to their needs.”

This is an interesting paragraph because it shows that the Code wants to facilitate and encourage data sharing, not limit it. And it seems to propose an approach to collaboration on common platforms to “integrate a vast array of data” which seems in line with what was proposed yesterday regarding common platforms, "organized data communities" and building trust.

I hate being the one who starts asking about business models but it came to my mind when we started discussing common data platforms. How will these platforms pay for salaries and servers? Should the investments be made by governments or intergoverdmental organisation who want to create a common good, or can we see ways to create revenuw streams on which these platforms can depend?

Current trade and intellectual property laws are unclear as to where the rights to digital technologies start for smallholder farmers, and where they stop. This problem is highlighted in relation to intellectual property law, under which certain data can be seen as exclusive property.

To solve this ethical challenge, legal rights that guarantee open processes and some form of proprietary ownership should be given to small holder farmers, so that they no longer view digital technology as something outside coming to rip them off, but as something that they own, have a stake in, participate and continuously gain from.

It is important to emphasize that as users of digital data, farmers have some form of Users’ rights, which are made up of personal property rights in the copy of a copyrighted work; contractual rights to access works through a service; and exceptions to copyright infringement. All three facets of this right should be protected either by the formulation of exceptions and limitations to current IP regulations and digital rights management laws, specifically designed to meet the requirements of smallholder farmers, or the creation of new forms of IP protection. Flexibilities exist under current international IP treaties which may allow for such.

In order to guarantee wider utilization of digital technology, governments should adopt policies that obligate companies to ensure that smallholder farmers actively participate in the negotiation, development and design of digital agricultural products and processes. Such participation will also help digital agriculture meets the local content requirements adopted in some developed countries.

Clear legal rules regarding the interaction of digital rights with other rights, especially human rights, and obligations under relevant multilateral, regional, and bilateral agreements, need to be drawn up.

Interesting discussion is emerging and some useful insights.In line with my comments yesterday of the involvement of farmers and local community, l concur that the approach by the coalition of association of EU agri-food chain that signed on the 23 of April a joint EU Code of Conduct on sharing of agricultural data is a good precedent.

In many developing countries farmers are also grouped into farmers' organisations, any model or scenario should not avoid this key constituency. If discussions and platforms are co-owned by the farmers through their associations, there is sustainability and also local ownership of the emerging models and platforms.

On ethical issues, l believe an emerging scenario should atleast be compliant with GDPR requirements.In that way a lot of ethical issues are avoided. Data rights like any property should be protected and the owner should rightfully hand them.

Legal approaches vary from place to place, l think platforms should be hosted under jurisductions that are not restrictive, however - legal requirements are now transnational i.e DGPR.

Traditional and Indegineous knowledge is a burning theme , the challenge being some of this knowledge isnt documented and an attempt to do so usually infers an ethical breach. Farmers and farming community should reserve the right not to share data they classify either as sensitive or indigenous. There is also a 'caveat' that needs to be placed for those that will access this data, so that its ensured they do know abuse the IP and property rights of the communities that created this information.

Change in food habits,and using some of such which avoid fat,fatigue,or generate blood sugar are the Ethical issues.

Legal,the society is to have a pro farmer systems either made under rules,including consumption,generation and insurence.

The policies shall address to meet the demands of huge human power growth existing and likely to grow.The governments have to meet the challenges by implementing pro farmer-pro consumer policies.

What a complex and large topic we have today! I feel rather speechless and don't envy Leanne Wiseman who started today's e-consultation.  I like a lot in what I read in Wiseman's start and other people's replies, but find it very difficult to react too. I find it difficult, because I don't know what the current scenario is (which scenario? whose? And where?) and what the future scenario should be (Valeria resumed a whole bunch of them very well). So, what is the present starting point and what is the goal? If we don't know that, it's going to be hard to answer today's question....

So, I'm simply going to share how we do it, and I'd love to hear what you think about it or how you do it. Since March I am leader of a workpackage on ethics in a large-scale IoT pilot in Europe (IoF2020) and we chose not to start from the big picture, but to start with smaller ones. Our project includes 19 use cases, divided over different 'branches' of farming: arable, meat, vegetable, fruit and dairy. The ethics part starts with questions that partners in the use cases ask, for example about whether they should share their data with the other partners in the network. Starting from these questions we want to talk about what impacts they want to realize, for their own organizations as well as for society. And then we start thinking about how we get from the present situation to the future one. If the partners in the use case favor certain impacts, this imposes requirements on their cooperation, and on the technology itself.

So that's how we do it. We start in use cases and from there we try to acquire insight in the values at stake and the impacts participants want to realize. And then we think about what values the technology should serve (value-sensitive design is the approach) and how the collaboration between the partners around it should be organized.

From these individual use cases we can generalize. Hopefully at the end of our project we can offer a catalogue of designs for IOT that serves different collaborations, so that stakeholders have something to choose. And guidelines and codes of conduct should be assessed to see whether they support the desired collaborations.

This approach has downsides, of course, but what I like is that it allows for different solutions in different contexts. And it starts with needs and values of people in the network around smart farms, as well as farmers themselves. From there we generalize towards designs of IOT that can be implemented in different locations, and guidleines and codes of conduct that help future innovators to think about what they want in their contexts. 

Let us try to delve into one of the questions for today in more detail:

• Legal: what do you think are the best legal approaches to achieve the desired scenarios? How to recognize and implement farmers’ intellectual property rights over their data and traditional knowledge? How should the licensing scenario change?

The notion of farmer's rights is one that is already recognised in Article 9 of the International Treaty on Plant genetic resources recognizes the enormous contribution that the local and indigenous communities and farmers of all regions of the world, particularly those in the centers of origin and crop diversity, have made and will continue to make for the conservation and development of plant genetic resources which constitute the basis of food and agriculture production throughout the world. It gives governments the responsibility for implementing Farmers' Rights, and lists measures that could be taken to protect, promote and realize these rights:

• The protection of traditional knowledge relevant to plant genetic resources for food and agriculture;
• The right to equitably participate in sharing benefits arising from the utilization of plant genetic resources for food and agriculture;
• The right to participate in making decisions, at the national level, on matters related to the conservation and sustainable use of plant genetic resources for food and agriculture; and
• The right that farmers have to save, use, exchange and sell farm-saved seed/propagating material, subject to national law and as appropriate.

Could it be possible that these rights be extended to protect the data generated on farms?  some have even argued that the data itself would fall under this treaty 

Could rights in their farm data be potentially be an extension to an already exisiting international framework?

This could avoid the potential difficulty of considering new sui generis farmer data rights scheme whether that be an extension of copyright in intellectual property (which would be unlikely) or a new property right ? could this be seen as being at odds with the approach taken to personal data protection more generally  as we have seen with GDPR and CDR

Another 11th hour comment.  There’s been a prevailing discussion on government and questions around their role in the provision/enabling the data environment.  In the absence of any reference to it I would like to table the concept of a Spatial Data Infrastructure as a governance model for government data or public sector data (PSI). 

I have found that most countries in the world (even in less developed countries) there is some traces of SDI and the structure of data governance exists and is aligned (once again in varying degrees) to international initiatives. 

For example the UN-GGIM aims to address global challenges regarding the use of geospatial information, including in the development agendas, and to serve as a body for global policymaking in the field of geospatial information management.  With regional entities (and member states)  for Asian-Pacific (Afghanistan, American Samoa, Armenia, Australia, Azerbaijan, Bangladesh, Bhutan, Brunei Darussalam, Cambodia, China, Cook Islands, Democratic People's Republic of Korea, Fiji, French Polynesia, Guam, Hong Kong, China, India, Indonesia, Islamic Republic of Iran, Japan, Kazakhstan, Kiribati, Kyrgyzstan, Lao People's Democratic Republic, Macao, China, Malaysia, Maldives, Marshall Islands, Micronesia, Mongolia, Myanmar, Nauru, Nepal, New Caledonia, New Zealand, Niue, Northern Marianas, Pakistan, Palau, Papua New Guinea, Philippines, Republic of Korea, Russian Federation, Samoa, Singapore, Solomon Islands, Sri Lanka, Tajikistan, Thailand, Timor-Leste, Tonga, Turkmenistan, Tuvalu, Uzbekistan, Vanuatu and Viet Nam.) , Arab states (Algeria, Bahrain, Comores, Djibouti, Egypt, Iraq, Jordan, Kuwait, Lebanon, Libya, Mauritania, Morocco, Oman, Qatar, Saudi Arabia, Somalia, State of Palestine, Sudan, Syrian Arab Republic, Tunisia, United Arab Emirates and Yemen. ), Europe (Albania, Andorra, Armenia, Austria, Azerbaijan, Belarus, Belgium, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Georgia, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, the Former Yugoslav Republic of Macedonia, Malta, Republic of Moldova, Monaco, Montenegro, Netherlands, Norway, Poland, Portugal, Romania, The Russian Federation, San Marino, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, Ukraine and the United Kingdom of Great Britain and Northern Ireland ), Americas (Antigua and Barbuda, Argentina, Bahamas, Barbados, Belize, Bolivia, Brazil, Canada, Chile, Colombia, Costa Rica, Cuba, Dominica, Dominican Republic, Ecuador, El Salvador, Grenada, Guadeloupe, Guatemala, Guyana, Haiti, Honduras, Jamaica, Martinique, Mexico, Nicaragua, Panama, Paraguay, Peru, St. Maarten, St Lucia, St. Vincent and the Grenadines, St. Kitts and Nevis, Suriname, Trinidad and Tobago, United States of America, Uruguay, Venezuela. ) and Africa (Algeria, Angola, Benin, Botswana, Burkina Faso, Burundi, Cameroon, Cape Verde, Central African Republic, Chad, Comoros, Congo, Democratic Republic of the Congo, Côte d'Ivoire, Djibouti, Egypt, Gabon, Gambia, Ghana, Guinea, Guinea- Bissau, Kenya, Kingdom of Eswatini, Lesotho, Liberia, Libya, Madagascar, Malawi, Mali, Mauritania, Mauritius, Morocco, Mozambique, Namibia, Niger, Nigeria, Rwanda, Sao Tome & Principe, Senegal, Seychelles, Sierra Leone, Somalia, South Africa, South Sudan, Sudan, United Republic of Tanzania, Togo, Tunisia, Uganda, Zambia, Zimbabwe ).SDI references beyond UNGGIM (http://ggim.un.org/ )