Connectivity Research Consultant (Legal and Regulatory)

from UN High Commissioner for Refugees
Closing date: 29 Apr 2018


Project Title: Legal aspects of SIM card access in refugee hosting countries

Organisation: UNHCR

Job Title: Connectivity Research Consultant (Legal and Regulatory)

Duty Station: Home Based Consultant

Duration: 21st May to 21st August, 2018 (3 months)

Contract Type: International Individual Contractor Agreement (IICA)

Contract Level: IICA-2

Background Information:

Connectivity for Refugees is a UNHCR initiative that aims to ensure that refugees regardless of their background, age, or gender, have access to internet connectivity. It started in November 2016 with the launch of research conducted by Accenture Development Partnerships. This showed that a significant impact can be made on the lives of refugees through internet connectivity, in areas of education, livelihoods, communication and as a tool that supports their overall protection.

While UNHCR has been undertaking various projects to enhance the infrastructure available across its operations, in many places significant legal barriers exist which prevent refugees from legally accessing the internet. Alongside this, the UNHCR Identity Management and Registration Service has developed a Digital Identity and Inclusion Strategy. The Strategy and the Connectivity for Refugees initiative recognise the need to find solutions to regulatory barriers that can block refugees legally registering SIM cards or accessing mobile money (KYC requirements), which are often caused by inability of refugees to prove their identity through accepted documentation.

Based a number of stakeholder interviews with UNHCR and other humanitarian actors, the GSMA formulated a policy note on “Enabling Forcibly Displaced Persons to access mobile services by addressing identification barriers” that unpacks issues around KYC requirements, legal access to SIM cards for the forcibly displaced and UNHCR’s registration modalities. UNHCR and the GSMA now wish to expand on this and are seeking a consultant to support country-by-country research to determine specific systematic and policy issues that need to be addressed in each context with a view to developing an advocacy platform to support national authorities successfully adapt their identity and telecommunications frameworks to incorporate refugees.

Research questions are currently being developed that are to be answered through the consultancy. Some examples of such questions might be, for each country:

  • Are refugees legally able to register a SIM card? What registration / identification modality is required to facilitate this?

  • Are there discrepancies in the different national regimes around identity, SIM card access and KYC requirements vis-a-vis refugees? If so, what are the nature of these discrepancies?

Organizational context:

UNHCR Innovation Service - leading the Connectivity for Refugees initiative - and Identity Management and Registration Service are working closely together with the GSMA to develop a better understanding of the barriers that exist at the national level regarding how refugees can legally access SIM cards and meet KYC requirements for mobile money in a number of priority countries. For the basis of this project the following countries are: Tanzania, Uganda, Ethiopia, Angola, DRC, Turkey, Jordan, Lebanon, Iraq, Kenya, Iran, Bangladesh.

Duties and Responsibilities:

  • Develop the framework for the research based on the priority areas defined by UNHCR and the GSMA, including a research questionnaire

  • Liaison with UNHCR field offices to determine UNHCR current and planned registration / identity modalities

  • Working with regulators and other government agencies to develop a thorough understanding of the legal and regulatory frameworks governing SIM card access for refugees on a country by country basis, and applicability of the respective UNHCR registration approaches as a viable mechanism to meet KYC requirements

  • Research and analysis on the information gathered and obstacles / challenges ascertained on a country-by-country basis

  • Specific obstacles determined to build and prioritise UNHCR and the GSMA’s advocacy agenda regarding SIM card access to refugees on a country-by-country basis

Core Deliverables (TBC):

  • Public report with top level findings country by country

  • Internal comprehensive analysis matrix that UNHCR country operations can take forward to update on progress as the situation evolves country-by-country

  • Foundational Advocacy roadmap for further enhancement by the UNHCR Innovation communications team

Essential Minimum Qualifications and Professional Experience Required:


  • Possess University level qualifications Bachelor's (essential) or Master’s degree (desired) in a relevant area

Job Experience

  • Minimum of 7 years work experience relevant to the function.

  • Demonstrated experience in undertaking research projects similar in nature and level of complexity.

  • Experience working for a UN agency or international humanitarian organization


  • Fluency in English (required)

  • Knowledge of another language (desirable)

Required Competencies:


  • Demonstrates minimum 7 years experience in understanding legal and regulatory systems. Specific experience with either refugee and/or telecommunications issues desirable.

  • Previous experience with developing advocacy platforms with high-level national actors and relevant global institutions General

  • Highly organized and autonomous, able to multitask and prioritize workload when necessary.

  • Excellent writing and documentation skills, demonstrating high levels of attention to detail.

  • Works well in a multicultural team and has a strong work ethic: strives to deliver high-quality, error-free deliverables potentially targeting different types of users e.g. senior management, fundraising specialists and database managers.

Location: The consultant will be home based; during the consultancy, a mission to GSMA offices (London) for two-weeks will be conducted. The costs of this mission will be covered by UNHCR. The consultant is responsible for UK visa arrangements if necessary.

How to apply:

Interested applicants should submit their letter of motivation and Personal History Form (P11), including testimonials/degrees/certificates to indicating SIM Card Access Research in the subject of the email.

P11 forms are available on

The deadline for applications is 29th April, 2018.