A/HRC/45/44/Add.2 political support; in its report, the Office of the Ombudsperson also noted the weakness of the National Anti-Discrimination Commission. Once again, the very concerns raised by the Ombudsperson were echoed by civil society and public officials in their meetings with the Working Group. 29. The lack of implementation of the National Development Plan for the Afro-Peruvian Population has also led to institutional failures to use the information gathered by the National Institute of Statistics incorporating the ethnicity variable with respect to Afro-Peruvians, although reported delays in generating race and ethnicity statistics also played a role. The Ombudsperson recommended that ministries expedite analysis and incorporation of data from the 2017 national census. 30. The Ombudsperson also noted the impact of the lack of regulations specifying clear authority to implement the National Development Plan for the Afro-Peruvian Population: of the 10 regional governments, half claimed ignorance of the National Development Plan, lack of competence to implement it, or suggested that the Plan was the exclusive responsibility of the Ministry of Culture. The regional government of Lima, where nearly one third of all people of African descent in Peru live, did not respond to the Ombudsperson’s request for information. Only the regional governments of Ica and Piura issued specific ordinances to draft plans to implement the Plan. Therefore, rather than serving as an initiative to address the needs of Afro-Peruvians, the Plan has become a complex means of facilitating avoidance of that responsibility, resulting in a profound failure of public administration to serve AfroPeruvians. 31. With no intent to follow up the National Development Plan for the Afro-Peruvian Population with a dedicated plan for Afro-Peruvians, the National Centre for Strategic Planning (CEPLAN) has indicated that it will be integrated into an imminent national policy on mainstreaming an intercultural approach. No government official was, however, able to clarify what funding, resources, structure and authority the policy would have in promoting and protecting the rights of Afro-Peruvians. As the National Development Plan is already coming to an end, the matter is of particular concern. 32. Part of the issues of the visibility and development of Afro-Peruvians is the acknowledgment of their collective rights. Their status as a people (as against a population) under ILO Convention No. 169, and the resulting rights framework under international law, offers them the protection they need. Civil society representatives have reported revisions to this policy, without field studies or consultations with Afro-Peruvian communities being conducted; any decision to downgrade the status of Afro-Peruvians from “people” to “population” would therefore not be the result of an adequate or legitimate process, and may indeed constitute the institutional denial of collective rights and the suppression of AfroPeruvian identity. Such a concern appears to be well-founded. According to one submission received from civil society in response to a call for submissions regarding the coronavirus (COVID-19) pandemic, the law adopted on 30 May 202011 supporting the collection of data in the COVID-19 health emergency excluded the term “Afro-Peruvian” from its final version. The official reason for the refusal to collect disaggregated data on the impact of COVID-19 among Afro-Peruvians (despite the stark racial disparities for people of African descent globally) was because no technical or legal instrument conferred status as a “people” to AfroPeruvians. 33. For Afro-Peruvians with intersectional identities, a severe lack of access to public administration persists in policy and practice, as reported by women, LGBTI persons, migrants, young people and persons with disabilities. Public policy does not routinely include intersectional analysis. Workplace training and guidance often fail to raise awareness of or support for public policy, rendering public services (such as public restrooms) traumatizing for some Afro-Peruvians, including some LGBTI persons. In addition, public interventions to address the lack of networks, mentoring and informal assistance for LGBTI persons and other Afro-Peruvians appear non-existent, leaving intersectional populations in a particularly precarious situation with respect to, inter alia, education, employment and health care. 11 www.gob.pe/institucion/cultura/normas-legales/633316-005-2020-mc. 7