A/HRC/37/54 different groups at risk of marginalization or vulnerability, such as women, children, the elderly, persons with disability, national, ethnic, linguistic and religious minorities or other groups that may be at risk in a given national context, such as indigenous peoples, refugees or internally displaced persons.52 53. Reliable and disaggregated data are needed to strengthen modelling or at least inform a more detailed analysis. The momentum to widen and strengthen the collection and analysis of relevant and timely data that can be disaggregated to ascertain progress in the reduction in inequality among societal groups has grown in the context of the 2030 Agenda and the 17 Sustainable Development Goals. While the indicators of the Goals may not necessarily be rights based and the resulting data may not provide a comprehensive overview of all aspects of human rights, such data-collection processes could serve as a useful information resource to those working in a human rights impact assessment context. 54. Once the analysis of potential impacts is done, a core part of a human rights impact assessment is designing prevention, mitigation and compensation measures to counteract adverse impacts. This is done by selecting alternative measures, modifying proposed measures through compensating for impacts (e.g., providing cash payments to the poorest to compensate for the removal of fuel subsidies). The experience of the application of regulatory impact analyses by the OECD indicated the risk for overall outcomes of relying on mitigation measures that must be adopted by another part of government that does not have a mandate to compel the adoption of such measures. Offsetting negative impacts through separate policy actions is likely to give rise to political difficulties in many cases, as there may be limited confidence that the promised “policy offsets” will actually be delivered by other parts of government. 53 That points to the need to carry out a human rights impact assessment on fiscal consolidation and/or economic reform packages at the national level that would involve a whole-of-government approach. 55. Deciding whether to integrate a human rights impact assessment into a broader government review, such as a regulatory impact assessment, or carry out a stand-alone assessment is an important question that should draw on experiences from other areas. A recent regulatory impact analysis review conducted for OECD considered the integration of a specific focus — such as environmental or social issues — into a broader regulatory impact analysis versus conducting a stand-alone impact assessment. The review of literature found that, in sum, the majority of authors remarked on the relatively poor performance of both impact assessment options — that is, the integrated regulatory impact analysis, on the one hand, and separate environmental, social or regulatory impact analyses, on the other — in ensuring that identified social and environmental impacts were taken into account in determining policy outcomes. The literature on impact assessment has generally advocated integration as a means of making policymaking more effective.54 56. Finally, it is important to acknowledge that any tool needs to be adaptable to potentially different levels of data availability and overall capacity to carry out a human rights impact assessment, so that the tool can be used in a wider range of circumstances. VII. Designing a human rights impact assessment to assess potentially impermissible retrogressive measures 57. This section sets out key points that need to be addressed and considered in designing a human rights impact assessment. The guiding principles for assessing the human rights impact of economic reform policies would be a set of substantive human rights principles and procedural guidance on how to conduct a human rights impact assessment of potentially impermissible retrogressive measures. 52 53 54 See, for example, A/HRC/28/59/Add.1. See Rex Deighton-Smith and others, “Promoting inclusive growth through better regulation: The role of regulatory impact assessment”, OECD Regulatory Policy Working Papers, No. 3 (2016), p. 45. Ibid. 15