Open Supply Hub operates as an open platform, but with recognition that openness is not experienced uniformly, and that open data systems can generate uneven consequences depending on power, capacity, and context.  For trade unions and civil society organizations (TU/CSOs), particularly those operating in environments marked by weak labour protections, political repression, or employer retaliation, participation in open platforms can involve risks that are not easily captured by technical or data-centric frameworks.

In January 2026, Open Supply Hub introduced two mechanisms to strengthen how trade union and civil society data is submitted, reviewed, and published on the platform:

• The TU/CSO Data Safety Policy: This policy sets out how data contributed by trade unions and civil society organizations is assessed prior to publication, with explicit attention to safety, consent, and rightsholder context. 
• The TU/CSO Data Submission Form: This form provides a dedicated entry point for trade union and CSO data, improving accessibility and ensuring that submissions are reviewed through processes appropriate to the specific risks and contexts of trade union and civil society work. 

Together, these tools are designed to differentiate openness rather than apply it uniformly. They recognize that not all data can or should be treated in the same way, and that publication decisions must take account of how data may circulate, be interpreted, or used in practice. This approach responds directly to concerns raised by trade unions and civil society organizations through the Beyond Transparency report, particularly the need to ground data governance in the lived realities of workers and their organizations.

This blog outlines the considerations informing these steps, the challenges they are intended to address, and the role of the ‘OS Hub Advisory Committee on Trade Union & CSO Engagement’, in supporting their development. It also reflects on how this work can be extended, as Open Supply Hub continues to adapt its data-governance practices in response to the diverse contexts, capacities, and risks faced by those who engage with and contribute data to the platform.

Why Trade Union and Civil Society Data Requires Different Safeguards

Data shared by trade unions and civil society organizations is shaped by the conditions under which it is produced. Much of this data emerges in contexts where power is actively contested, including efforts to document labour violations, support collective worker organizing, or challenge abusive employment and environmental practices. As a result, TU/CSO data is often politically situated and closely linked to ongoing struggles over rights, representation, and accountability.

These conditions introduce sensitivities that extend beyond the individual organization submitting data. In many cases, the potential consequences of data visibility are borne collectively, by workers, organizers, or entire communities, rather than solely by the entity contributing the information. Collective exposure is further complicated by data environments in which information can be scraped, aggregated, or repurposed, often without contextual understanding, by a wide range of actors, including through automated or AI-enabled tools. In such settings, the risks associated with data circulation may be amplified in ways that are difficult to anticipate at the point of submission.

Despite these challenges, TU/CSO data is essential to understanding how supply chains function in practice — where risks materialize, which harms remain hidden, and what forms of remediation are effective. Without this data, even open platforms risk presenting incomplete or distorted accounts of supply chain realities. 

Taken together, the combination of heightened sensitivity and critical importance of this data, underscores the need for specific, differentiated measures to govern how trade union and civil society data is shared, reviewed, and used. Approaches designed for other forms of supply chain data are insufficient to accommodate these realities, making tailored safeguards a necessary component of meaningful and responsible transparency.

What This Intervention Is Trying to Enable

The differentiated safeguards described above raise a practical question: what does it mean, in practice, to support trade unions and civil society organizations to share data safely on an open platform? The TU/CSO Data Safety Policy is one of the first steps taken by Open Supply Hub in response to this question.

At its core, the policy is intended to address ‘lack of safety’ as a barrier to participation. For many trade unions and civil society organizations, the primary constraint on data sharing is not unwillingness, but the challenge of assessing risk and managing the potential consequences of making their data visible. By clarifying how TU/CSO data is reviewed, and by embedding safety considerations directly into publication decisions on Open Supply Hub, the policy seeks to redistribute responsibility for risk assessment, rather than placing it solely on submitting organizations.

A central aim of this approach is to improve safety through clear and supportive processes within digital platforms themselves, while helping trade unions and civil society organizations navigate the wider digital ecosystem. In practice, many trade unions and CSOs engage with these systems from very different starting points than corporate actors. Access to legal expertise for assessing downstream risk, familiarity with data-governance frameworks, fluency in dominant working languages, and stable digital infrastructure cannot be assumed to be evenly distributed. For many grassroots organizations and groups working with marginalized communities, long-standing barriers to technology access and digital participation persist, including the limited availability of tools and processes in local languages and increased exposure to surveillance. These dynamics reflect the structural conditions under which trade unions and CSOs document and share information on supply-chain operations, rather than deficits in organizational knowledge or agency.

The intention, therefore, is not to require organizations—many of which operate with limited resources or under significant pressure—to possess full legal, technical, or data-governance expertise at the point of data submission. Instead, the policy recognizes that such capacities can be developed and exercised through engagement with a clearer and more supportive system, and that digital platforms such as Open Supply Hub have a role to play in enabling this. In this sense, the data-review process is designed to function as a form of practical support, helping organizations consider how their data may circulate, what risks may arise, and what options exist for sharing, limiting, or withholding information.

Ensuring the accessibility of the platform, the Data Safety Policy, and its implementation is a core priority of this approach. For this reason, the Data Safety Policy is currently available in Bahasa Indonesia, Bangla, and Turkish, with scope to provide additional languages where needed. Data submissions are also accepted in any language and format, reflecting an understanding that rigid technical or linguistic requirements can exclude organizations working closest to workers and communities, particularly those with the least access to digital tools.

As part of this commitment, Open Supply Hub is also looking at providing memoranda of understanding (MoUs) related to data sharing not only in English, but also with limited technical legal jargon (or, where legal jargon is necessary, with clear, plain-language explanations for those without a legal background) in the languages of participating trade unions. This is intended to support genuinely informed consent as a practice, rather than treating consent as a purely formal or procedural step. Taken together, these measures aim to reduce procedural barriers without diluting safety considerations, and to ensure that participation in data sharing is both accessible and grounded in lived realities.

The OS Hub Advisory Committee on Trade Union & CSO Engagement also plays a complementary role within this architecture. Where organizations are uncertain about whether data can be shared safely, the Committee, composed of individuals with deep embedded experience within trade unions and civil society organizations, is intended to provide judgment and support. It works with submitters to assess risk and identify appropriate pathways for handling data, functioning as a facilitating mechanism rather than a gatekeeping one.

Finally, these measures are explicitly iterative. The policy does not claim to anticipate all scenarios or risks, and Open Supply Hub remains open to feedback  and revision. Additional steps, including the involvement of external expertise where relevant, are being explored as part of an ongoing effort to strengthen how trade union and civil society data can be shared responsibly within an open platform.

Looking Ahead 

We recognize that these measures do not resolve all the structural constraints faced by trade unions and civil society organizations, nor do they eliminate all the risks associated with data sharing in contested and unequal contexts. Rather, they are intended to offer a starting point: a framework that takes safety seriously, recognizes differentiated risk and capacity, and allows for case-by-case assessment of how data should be shared, limited, or withheld, rather than assuming uniform participation or visibility. 

Learning from practice, through real cases, challenges, and critique, will be essential to understanding what works, where gaps remain, and how safeguards can be strengthened over time. This learning will depend not only on the experience of those directly engaging with the policy, but also on feedback from the broader trade union and civil society community, whose perspectives are critical to ensuring that data governance approaches remain grounded in lived realities. We look forward to continuing the conversation initiated through Beyond Transparency, and to further strengthening Open Supply Hub’s systems so that they respond to diverse realities and contexts.