What Does ‘Closing Well’ Entail for Humanitarian Project Data? Seven Questions as Humanitarian Health Projects Are (Being) Closed or Handed Over

Humanitarian health projects generate extensive amounts of data as part of their activities. In many situations, this data will endure long after the projects have ended. Careful attention is needed within project closure planning and implementation to decisions of when and how to share, store, return to the individuals from whom it was collected, or destroy data. Drawing on a review of the literature and guidelines related to data responsibility and project closure, we propose seven questions that can help orient reflection and deliberation around data management from the perspective of an ethics of project closure. The questions foreground considerations related to purpose limitation and data minimisation, respect for data rights, upholding duties of care, clarifying expectations, commitments and agreements, minimisation and mitigation of risk, and alignment of policy and regulatory frameworks for data responsibility. We illustrate the application of the questions to a case study of the handover of a healthcare project in a refugee camp where project activities were transferred from an international humanitarian organisation to local authorities. This analysis reinforces the importance of understanding data responsibility as an essential component of ‘closing well’.