Division 8.2 Bias mitigation

CAR recognises that the level of detail provided by national governments in response to trace requests, ranging from no response, to full disclosure and the provision of transfer documents, may result in Member States experiencing differing degrees of public exposure. CAR undertakes to mitigate any implicit bias, which such a disparity in trace responses might introduce into iTrace reporting, by:

1. (a)

   explicitly prefacing, in text, all cases reported by the iTrace Action whereby Member States have responded transparently to trace requests in a manner that, where applicable, affirms unambiguously the legality of the transfers subject to those trace requests;

2. (b)

   explicitly prefacing, in text, all cases reported by the iTrace Action whereby states have not responded to trace requests, stating that 'given the absence of a trace response, CAR cannot pronounce on the legality of the transfer in question' (this will not apply to cases in which Member States have provided, in response to specific trace requests, reasons that prevent them from responding immediately or in full); and

3. (c)

   providing a scheduled report to the European External Action Service on all cases whereby CAR has not received from states an acknowledgment of their having received a trace request within 28 days of receipt. CAR will register all acknowledgements of receipt that it receives in the form of letters, facsimiles, emails, or telephone calls.