http://www.coe.int/documents/16695/995226/COE-Logo-Fil-BW.png/bb17a17e-5308-4fc0-929d-5c4baf3ab99d?t=1371222816000?t=1371222816000

 

 

 

 

 

19 March 2015

DECS-RPD(2015)15

 

 

 

 

Committee of Experts

on the Rights of People with Disabilities

(DECS-RPD)

 

 

Strasbourg, Council of Europe - Agora building

22-24 April 2015

 

 

Report by EASPD

Enjoyment of rights in practice: towards the new CoE Disability Action Plan

 

 

 

Item 6.2 of the agenda

Evaluation report on the implementation

of the Disability Action Plan 2006-2015

 

 

 

Document prepared by EASPD

 

 

The opinions expressed in this report are those of the author and
do not necessarily reflect the official policy of the Council of Europe

 

 

 

This document is restricted. It will not be distributed at the meeting. Please bring this copy.

 

 


 

Contents

 

Contents

Executive Summary

List of Abbreviations

1. Introduction

2. Added value of the Disability Action Plan 2006-2015 for the European region

3. Impact assessment on EASPD’s policies and actions

Action Line 1 - Participation in political and public life

Action Line 2 - Participation in cultural life

Action Line 3 - Information and communication

Action Line 4 – Education

Action Line 5 - Employment, vocation guidance and training

Action Line 8 - Community living

Action Line 9 - Health care / Action Line 10 Rehabilitation

Action Line 11 – Social Protection

Action Line 12 – Protection against violence and abuse

Action Line 13 - Awareness rising

Cross-cutting issues

Ageing of Persons with Disabilities

People with disabilities in need of high level of support

Women and girls with disabilities

Children and young people with disabilities

Evaluation and Monitoring of the Plan

4. The way forward: the new Disability Action Plan 2016-2020

The concept

Proposed domains of action

5. Conclusions


Executive Summary

 

The Council of Europe Disability Action Plan 2006-2015 has come to an end. The present report intends to underline its added value for the European region and to contribute to the new Plan for 2016-2020. The report starts by analysing the impact of the Disability Action Plan 2006-2015 on EASPD’s work at the European level. For each action line, it examines the state of play and explains what our organisation has done in terms of policies, projects and events. In doing so, it highlights two important facts: the first is that the added value of the Plan lies in its ability to reflect the UNCRPD’s articles. The second is that it has the merit of having reached out to other groups with support needs. With regard to the new Plan, the report gives suggestions and ideas on the domains of action (accessibility, legal capacity, disaster preparedness, etc.) and cross-cutting issues (young people with disabilities, migrants, etc.) on which to focus the future work. Moreover, it defines a new methodology based on the analysis of the current situation and of existing gaps. It also defines three types of actions to be carried out: collection of knowledge and know-how, gathering of models of promising practices and drafting of policy recommendation. The report concludes by reiterating that the ultimate objective of the Plan is to reach an inclusive society and that to do so, cooperation at all levels is fundamental.

 

 

 

 

List of Abbreviations

 

ANED – Academic Network of European Disability Expert

CoE – Council of Europe

DPOs – Disabled People’s Organisations

EASPD – European Association of Service Providers for Persons with Disabilities

EU – European Union

FRA – European Fundamental Rights Agency

UNCRPD – United Nations Convention on the Rights of Persons with Disability

Others such as CAHPAH, CAHPAH-PPL, etc


1. Introduction

 

The Council of Europe Action Plan “to promote the rights and full participation of people with disabilities in society: improving the quality of life of people with disabilities in Europe 2006-2015” has come to an end.

The Plan was built on the idea that the governments of the Council of Europe member states have the commitment to do everything possible, to ensure that persons with disabilities can access, participate and be actively included in the society. Moreover, it specifically recognises that a close cooperation between all actors of the civil society, from organisations of disability rights to individualised services ones working at the regional and national level, is needed to fight discrimination and ensure equal rights and opportunities. In fact, all other actors in society can be considered having an implicit obligation to work on the implementation of the Action Plan and the UN CRPD. It is for this reason that EASPD, as a civil society organisation of support providers, is specifically focusing on this.

EASPD is a European not-for-profit organisation, representing over 10,000 service providers working in the field of disability in 30 countries across Europe. Our members are national umbrella organisations or single national agencies providing support services to persons with disabilities ranging from education, to employment, to day-care services which work in rehabilitation, recreational activities and support. Our main objective is to promote equal opportunities for people with disabilities, through effective and high-quality services systems. We believe that services are human rights enablers, since they can empower persons with disabilities. In fact, they can participate in reinforcing social ties, paving the way towards their inclusion in society.

This report has the aim to analyse the added value of the CoE Disability Action Plan 2006-2015 for the European region. In the first instance, it will examine the contents of the Plan and the actions undertaken by the CoE in order to implement it. Specifically, it will focus on its impact on EASPD’s work, in terms of policies, projects[1] and events carried out at the European level. In doing so, it will also reflect the views of civil society organisations working in the sector of individualised service providers in Europe. The intent of this report is to give our contribution to the new CoE Disability Action Plan for 2016-2020. Starting with the major success factors, EASPD will provide the CoE with suggestions and ideas, together with tools and instruments to continue the work in the following years.

2. Added value of the Disability Action Plan 2006-2015 for the European region

 

EASPD develops its policies and actions according to the principles enshrined in the UNCRPD. At the European level, it refers to two main texts: the Council of Europe Disability Action Plan 2006-2015 and the European Disability Strategy 2010-2020. EASPD recognises the relevance of both texts, and understands their complementary and different nature.

Within the frame of the CoE Disability Action Plan 2006-2015, EASPD contributed to the international debate on disability rights at the level of 47 member states. This was done by bringing to the table the knowledge and know-how of services and their expertise in providing individualised support and responding to the changing needs of persons with disabilities on a day-to-day basis. Specifically, EASPD took part as an observer to the CoE disability related meetings as well as to the CAHPAH, CS-RPD and DECS-RPD committees[2]. In addition to this, representatives of our organisation were present, as participants or speakers, at many relevant international conferences organised by the CoE and the countries holding the CoE Presidency.

Assessing the real impact of the Action Plan on services and support systems is extremely difficult. Nevertheless the Plan undeniably had a substantial influence on the overall understanding of disability and the challenges related to the correct implementation of the UNCRPD. The Action Plan had an awareness raising effect on support providers and amplified the attention on key issues regarding the implementation of the UNCRPD. The CoE Action Plan helped EASPD to focus its work over the last years on the action lines of most relevance to support providers: educational services, employment facilitating services, DI and community living, the use of technology and last but not least staff re-training.  Moreover, thanks to the Action Plan the UNCRPD was discussed by the International NGOs (INGO) enjoying participatory status at the CoE, which explored the role and responsibility of civil society organisations in this respect. One should not underestimate also the impact of the CoE committee that monitored the progressive implementation of the Action Plan. This committee provided a platform for debate and exchange of models of promising practices amongst member states and civil society actors. This contributed to the development of a common jargon and mutual understanding.

Overall, the added value of the Plan lies in the ability to reflect the ideas underpinning the articles of the UNCRPD, both in its action lines and recommendations to member states. In this context, EASPD specifically underlines the relevance of Recommendation CM/Rec(2011)14 of the Committee of Ministers to member states on the participation of persons with disabilities in political and public life[3] drafted by the CAHPAH-PPL and of Recommendation CM/Rec(2013)3 on ensuring full, equal and effective participation of persons with disabilities in culture, sports, tourism and leisure activities as guidelines for the work of service providers. However, these recommendations have not been followed by an assessment of the real outcomes of the actions undertaken afterwards. In this context, being able to evaluate and measure the impact of these actions, through the use of appropriate tools, would be crucial to plan the work ahead. With regard to the methodology, the new Plan has to analyse the current situation and identify existing gaps. This has to be carried out through three types of actions: collection of knowledge and know-how, gathering of models of promising practices and drafting of policy recommendations. The aim of the new Plan is to provide tools and instruments such as support systems, services and legal frameworks enabling individualised and inclusive responses to the needs of persons with disabilities.

Finally, an important merit of the Plan is that of reaching out to other groups with support needs and to other domains in which disability should be mainstreamed as a cross-cutting issue itself. EASPD believes that cooperation is essential for ensuring that disability remains a political priority. With regard to the work developed under the Plan in the past years, the focus was particularly on the rights of children with disabilities, ageing of persons with disabilities, as well as on new technologies, education, employment and political participation. EASPD recognises the importance of all actions undertaken in these fields. For the future, the Association underlines that higher attention should be paid to the topics of legal protection, disaster and risk preparedness and to other groups with support needs such as migrants and people with intellectual, mental or psychological disabilities. Through our suggestions, we intend to stress that substantially disability is just another human condition.

3. Impact assessment on EASPD’s policies and actions

 

The impact of the CoE Disability Action Plan on EASPD’s policies and actions can be evaluated by analysing the work carried out with regard to each of the following action lines:

Action Line 1 - Participation in political and public life

 

With regard to participation of persons with disabilities in political and public life, inclusion at this level remains unachieved. This is due to the fact that in the majority of the member states, the decision to deprive a person of the legal capacity, still results in the denial of the right to vote and to stand as a candidate. This is particularly the case for persons with intellectual and mental disability under guardianship. In addition to this, information and campaign materials in alternative formats such as easy-to-read, large print or Braille are not always provided. Finally, public authority buildings and procedures remain largely inaccessible, preventing persons with disabilities from registering to vote and accessing polling stations.

 

On this topic, EASPD has contributed to the implementation of the Plan by:

 


Action Line 2 - Participation in cultural life

 

With regard to the participation of persons with disabilities in cultural life, it refers to a variety of activities, such as leisure, media, sport and tourism. These activities are linked to the issues of accessibility, universal design, independent living and individualised support services. Despite improvements in these fields and particularly in relation to the accessibility of cultural events and centres, this right still remains unachieved.

On this topic, EASPD has contributed to the implementation of the Plan by:

 

Action Line 3 - Information and communication

 

With regard to information and communication across Europe, e-communications generally remain unavailable in alternative formats, such as easy-to-read, large print, Braille. Moreover, digital technologies still do not comply with design-for-all standards.

 

On this topic, EASPD has contributed to the implementation of the Plan by:

 

Action Line 4 – Education

Inclusion of persons with disabilities in society through education remains far from being achieved. In fact, many CoE member states still rely on special education systems for persons with disabilities. Moreover, segregated institutions continue to be created, despite what stated by the UNCRPD (specifically, articles 19 and 24). Access to education and lifelong learning programmes in mainstream schools is still difficult. This is due to the lack of training for professionals and adequate support that could facilitate the inclusion of pupils and students with disabilities. Structures and tools have yet to be fully adapted to universal design principles. Access to higher education and vocational training opportunities have to be developed. Finally, prejudices on the skills and potential of persons with disabilities continue to represent barriers against future improvements.

 

On this topic, EASPD has contributed to the implementation of the Plan by:

 

Action Line 5 - Employment, vocation guidance and training

 

Across Europe, barriers posed by society continue to exclude persons with disability from the labour market. This structural disadvantage leaves them in a situation of persistent underemployment. A variety of work and employment models and methodologies, from occupational services and sheltered workshops, to supported employment, still mark the difference from country to country. Support measures, such as vocational and educational training (VET), reasonable accommodation, technical guidance, personal assistance measures and subsidies for employers, are yet to be implemented. These measures would particularly help to overcome structural and functional hindrances, unlocking the job potential and shifting the focus away from the disability, on to the skills and competences of a person.

On this topic, EASPD has contributed to the implementation of the plan by:

 


This event was attended by around 450 participants and represented an important moment to link with local actors and to build bridges between the different regions of Europe. It was concluded by an award ceremony on best practices in the field of employment, coming from various organisations based in Europe, Asia and USA[17];

Action Line 8 - Community living

 

Across Europe, the transition from institutional, to community-based services has started, and is now under way. Situations differ widely according to the country and region of residence. However, many persons with disabilities still live in large segregating institutions, with detrimental consequences for their individual’s life and personal development. They remain exposed to high risks of abuses and violations of their human rights and dignity. Person-centred and individualised services such as personal assistance, social housing etc. remain underdeveloped, due to the consequences of the economic and financial crisis. Signs of re-institutionalisation are also multiplying.


On this topic, EASPD has contributed to the implementation of the Plan by:

 

This event was organised as part of the activities of the PUSH Network[37] and in cooperation with the ELOSH project[38] and was attended by 200 participants. Hosting interventions from international organisations’ representatives of the CoE, OESCE and hosts of the USA, it represented an opportunity to network, during workshops and informal events, with colleagues from across Europe, representatives of local authorities and of the civil society. During the conference, relevant CoE materials were distributed. A final report was produced as a main outcome;


Action Line 9 - Health care / Action Line 10 Rehabilitation

 

Across Europe, access to quality and affordable health care as well as preventive healthcare and rehabilitation services to persons with disabilities has to still be ensured. Professionals have to be provided with better training on early intervention and long-term care. Actions to reduce the risks of acquiring a disability during the working life have to be encouraged. In addition to this, health rehabilitation services in the community have to be developed. Finally, sharing knowledge, expertise and cooperation between health and disability professionals, as well as parents remains fundamental.

On this topic, EASPD has contributed to the implementation of the Plan by:

 

Action Line 11 – Social Protection

 

Across Europe, social security systems, social assistance and support, and social services are confronted to the lack of appropriate resources, caused by the continuing withdrawing of public authorities, which is hindering the quality of our welfares. Also due to the consequences of the economic crisis, governments are focusing more on financial measures than on social and inclusive policies. In this situation, in which social inequalities are increasingly wider, persons with disabilities remain one of the categories mostly exposed to the risks of poverty and of social exclusion.

On this topic, EASPD has contributed to the implementation of the Plan by working to influence the European Semester process and the EU2020 Strategy, particularly in relation to the issues of poverty and social exclusion. In order to do so, we are working at the European level, taking part to the Semester Alliance, which is composed of civil society’s organisations, to reorient European policies towards a more social and inclusive growth. We are also working at the national level, organising capacity-building sessions for our members and other organisations of the civil society at the local level. Specifically, we are explaining to them how to effectively have an impact on the social policies implemented or planned by their governments, showing how these are relevant to their work.

Action Line 12 – Protection against violence and abuse

 

As stated by the CoE Action Plan, the cases of abuse and violence against persons with disabilities are higher than for the general population. This is particularly the case of women, who are affected by severe disabilities. Such cases are frequent within institutions, but can also occur in other types of support or familiar environments.

In order to prevent abuses on persons with disabilities, EASPD has contributed to the implementation of the Plan by:

 

Action Line 13 - Awareness rising

 

Rising awareness on the rights of persons with disabilities and working to advocate for the provision of services of high quality to respond to their individual needs is crucial to combat prejudices and stigma. In fact, particularly in fields such as education or employment, discrimination still represents a barrier preventing the full inclusion of persons with disabilities in the society.


On this topic, EASPD has contributed to the implementation of the Plan by:

 

Outcomes of the events were: policy papers and declarations, training materials and good practices. These materials were made available at Member State level, to authorities and civil societies’ actors and at the European level, to the CoE. Since 2006 EASPD and local partners organised annually around 7 Provider Fora as key tools for building local capacity. These events took place in CoE member states, with particular regard to Turkey, Serbia, Moldova, FYROM, Bosnia and Albania. Through national and local networking and putting the UNCPRD and the CoE Action Plan in practice, their objective is to improve the structure of social service providers throughout Europe:

The impact envisaged is to implement this “train-the-trainer” approach into the curriculum of educational institutions providing training and education for staff of service providers in the disability sector. This will have a positive effect on the quality of services people with disabilities receive and will improve their life according to the UNCRPD.

The analysis of the Disability Action Plan 2006-2015 does not directly cover action lines 6 on the built environment, 7 on transports and 14 on research and development. These are linked to the issues of accessibility, knowledge and innovation which are treated respectively in the sections on political participation and when referring to our participation to European projects.

Cross-cutting issues

 

During the past years, EASPD has specifically focused on the following issues, contributing to the implementation of the Plan by:

Ageing of Persons with Disabilities

 

People with disabilities in need of high level of support

 

Women and girls with disabilities

 

Children and young people with disabilities

 

Evaluation and Monitoring of the Plan

 

With the role of observer, EASPD took part to the CoE Committee of Experts on the monitoring of the implementation of the CoE Action Plan (CAHPAH-DCEC), through the Secretary General. Moreover, it contributed to the works of the following CoE Committee of Experts on the rights of people with disabilities (CS-RPD and DECS-RPD).

4. The way forward: the new Disability Action Plan 2016-2020

In EASPD’s view, the new Disability Action Plan should continue to develop and implement viable strategies to include people with disabilities in society and ultimately to mainstream disability throughout all the policy areas, both at the European and at the national level. Moreover, the new Plan should specifically strengthen the cooperation with mainstream sectors and provide guidance to member states, tackling issues that require a cross-cutting response.

The concept

 

The new Plan should bring tools and instruments to bridge the gap between where we are and where we want to go to fully respond to the needs of persons with disabilities. For each topic, it should give the state of play, and analyse strengths and weaknesses. Moreover, it should consider steps needed to improve the condition of persons with disabilities in that specific domain and desired outcomes of possible actions. The final objective of the Plan should be to fully realise the principles enshrined in the UNCRPD.

For each domain, three types of actions should be envisaged by the new Plan. These are: knowledge base, best practices collection and policy recommendation.

Firstly, it should be oriented to collect knowledge and know-how, with the objective to identify current gaps. This could be done by developing a variety of knowledge platforms such as knowledge exchange events (conferences, seminars, working groups, etc.) or web based platforms. Knowledge platforms should aim at producing tangible results, which can take two forms. The first, that of information on the know-how present in the NGO world, as well as within CoE Members States. The second, that of trainings made available by the CoE to key actors in member states, to national and regional authorities and to civil society players on specific issues.

Secondly, it should focus on gathering Models of Promising Practices coming from all across Europe, which could be published online by NGOs, as well as by all CoE Members States. The outcome of this exercise should be mutual learning and should include these Models of Promising Practices in the previous mentioned trainings.

Thirdly, the new Plan should aim at drafting policy recommendations in order to provide guidance to Members States in relation to the further development of legal frameworks and practices. These recommendations must be focused and oriented towards practical results.

The added value of the work that the CoE carries out daily is that of fostering the rights of persons with disabilities throughout Europe. With the launch of the Disability Action Plan 2006-2015, the CoE has focused its attention on the needs of the disability community. The approval and entering into force of the UNCRPD, has de facto recognised the CoE as one of the guardians of their rights in Europe. The Disability Action Plan 2006-2015 has led the way, becoming the instrument to continue focusing the attention on these needs and on the importance to implement the UNCRPD.

Further opportunities to realise the rights of persons with disabilities have been provided by the inclusion of the CoE Disability Committee within a wider framework dealing with social and integration issues. This new framework leads towards new avenues of reaching out to other groups of people with support needs (children and young people, migrants and ethnic minorities, elderly, etc.) while carrying out actions related to disability. Moreover, it represents the chance to strengthen the cooperation with partner organisations, persons with disabilities, their families and friends. Specifically, it is an important opportunity to work closely with external stakeholders and with the mainstream sector, in order to reach a more inclusive society, always maintaining a focus on the rights of persons with disabilities.

Finally, it is well known that numerous difficulties exist in collecting information on policies and actions undertaken by member states to implement what is recommended by the CoE. To measure outcomes/results, it would therefore be fundamental to include in the new action Plan some elements (success indicators, targets) to facilitate this assessment. At the same time, it would also be important to make them follow by an implementation strategy. This last point should specifically have the objective to evaluate the need and possibility of having training and/or to collect statistics and data on a specific topic.


Proposed domains of action

 

Based on the work done in the past, EASPD proposes to focus on a number of domains of action that could more effectively contribute to the implementation of the UNCRPD in the future.

Domains included within the articles of the UN CRPD:

 

Cooperation with mainstream and civil society actors should be envisaged in all domains tackled by the new Plan:

 

 

Cross-cutting issues, targeting groups with individual needs, should be given higher attention:

 

 

5. Conclusions

 

Thanks to the work carried out by EASPD in the frame of the CoE Disability Action Plan 2006-2015 throughout the years, two important conclusions can be drawn. The first is that the Plan has contributed to raise awareness on the importance to implement the UNCRPD and to fully realise the ideals enshrined in it. Meanwhile, it has also highlighted the complexity of this task, clearly indicating that stronger efforts have to be made. The second is that the work carried out in the frame of the CoE Disability Action Plan 2006-2015 has revealed that the situation of persons with disabilities is different from one region to another and that the implementation level of the UNCRPD is different from country to country, making it difficult to find a common denominator. Despite these considerations, EASPD believes that cooperation should be possible, and that it should take place in many different domains, such as societal participation, community-based and inclusive support systems and emergency situations. Through the Disability Action Plan 2006-2015, the CoE has already demonstrated this, paving the way towards the inclusion of persons with disability in the society. It is for this reasons that EASPD is committed to continue its work, together with the CoE, the member states and DPOs, and all other relevant stakeholders. Using the words of Mr Dimitris Nikolsky, Chair of the CoE Committee of Experts on the Rights of Persons with Disabilities, we want to stress that: “the Disability Action Plan of the CoE, the EU2020 Strategy and the UN Convention on the Rights of People with Disabilities is enough to make the necessary changes towards an inclusive society”. Using these tools EASPD believes that we can achieve the ultimate goal of realising an inclusive society where there is a place for everybody regardless of one’s abilities, disabilities, age, gender, and race. In order to do that, we should stop thinking of working in 'silos' and start working together.

 

 

 

 

 

This report was compiled by Giulia Quarta on behalf of EASPD.

For additional information, please contact:

Luk Zelderloo

Secretary General

T. +32 2 282 46 10

info@easpd.eu

www.easpd.eu 


[1] Information on all EASPD projects, mentioned in the report can be found through the provided web addresses

[2] CAHPAH, CS-RPD and DECS-RPD - full names will be included

[3] https://wcd.coe.int/ViewDoc.jsp?id=1871285&Site=CM

[4] www.ajupid.eu

[5] www.fra.europa.eu/en/publication/2014/right-political-participation-persons-disabilities-summary

[6] www.disability-europe.net/

[7] http://easpd.eu/en/content/person-centered-technology

[8] https://www.ldw.org.uk/projects/past-projects/impact-in-europe.aspx

[9] www.etna-project.eu/ 

[10] www.entelis.net/

[11] http://blog.klikin.eu/  

[12] www.easpd.eu/sites/default/files/sites/default/files/SCEDUC/dublin_manifesto_on_inclusive_education.pdf

[13]  www.investt.eu/pathways-inclusion

[14] www.easpd.eu/sites/default/files/sites/default/files/budapest-manifesto-on-inclusive-learning-eng.pdf

[15]  www.tideproject.eu

[16] www.aldoproject.eu

[17] www.easpd.eu/en/content/employment-all-award-2013

[18]http://www.easpd.eu/sites/default/files/sites/default/files/News/new_easpd_employment_declaration_-_final_english.pdf

[19] www.easpd.eu/sites/default/files/sites/default/files/final_easpd_thessaloniki_declaration.pdf

[20] www.happy-farm.si/en/

[21] www.employmentforall.eu/Home/PassItOn/

[22] www.easpd.all2all.org/en/content/race

[23] www.easpd.all2all.org/en/content/t-est

[24] www.employmentforall.eu/Home/Projects/Conversion/

[25] www.en.lebenshilfe-guv.at

[26] www.eccertificate.eu

[27] www.easpd.eu/sites/default/files/sites/default/files/brochure_qol.pdf

[28] www.nqfinclusive.org

[29] www.employmentforall.eu/Home/IGOSInterestGrouponOccupationalServices/

[30] www.easpd.eu/en/content/bitse

[31] www.investt.eu

[32] www.easpd.all2all.org/en/content/new-services-employment

[33] www.easpd.eu/en/content/eqf-meets-ecvet

[34] www.vet4d.eu

[35] www.easpd.eu/sites/default/files/sites/default/files/Policy/easpd_di_roadmap_final.pdf

[36] www.easpd.eu/en/content/annual-conference-2014-norway

[37] www.easpd.eu/en/content/push-europe

[38] www.easpd.eu/en/content/elosh

[39] www.kent.ac.uk/tizard/research/documents/EU%20Comparative%20Costs%20Information.pdf

[40] www.easpd.eu/en/content/adapting-services-persons-disabilities-new-users

[41] www.easpd.eu

[42] www.easpd.eu/en/content/reaching-out-easpd-strategic-choices-2014-2017-building-inclusive-society

[43] www.myrightsmyvoice.eu/

[44] www.dielebenshilfe.at/fileadmin/inhalte/pdfs/GRAZDECLARATION_final.pdf

[45] www.sensage.eu

[46] http://www.easpd.eu/sites/default/files/sites/default/files/SensAge/d5-raisinig_awareness_on_the_needs_of_ageing_people_with_sensory_impairments.pdf

[47] https://wcd.coe.int/ViewDoc.jsp?id=1871285&Site=CM 

[48] https://wcd.coe.int/ViewDoc.jsp?id=2115367&Site=CM