A/HRC/21/42 protection to the honour and reputation of, for example, homeless people, sex workers or prisoners as to that of any other member of society. 56. For many stigmatized individuals, stigma results in a negative impact on their right to privacy when attempting to meet their water and sanitation needs. For instance, homeless people may be forced to urinate and defecate in public, given the inexistence or lack of maintenance of public facilities. During her mission to Slovenia, the Special Rapporteur met with Roma communities who were forced to defecate in the open and bathe in a stream due to the lack of adequate facilities. When doing so they were reportedly chased by the police (A/HRC/18/33/Add.2, para. 35). In these cases, the State directly interferes with people‘s privacy, not only by chasing them, but also by not allowing their dwellings to be connected to water supply and sewerage systems due to their alleged ―illegal‖ status. Similar situations can be found in slums all over the world where the alleged ―illegal‖ status of settlements results in people being denied access to facilities that would guarantee their privacy. In South Africa, a case was brought to the court concerning unenclosed toilets built by the municipality, that is, toilets that were erected without the enclosing superstructure that would hide people from view when using them. The Western Cape High Court found, inter alia, a violation of the right to privacy enshrined in article 14 of the South African Constitution.39 57. Article 17 of the International Covenant on Civil and Political Rights goes on to guarantee that ―everyone has the right to the protection of the law against such interference or attacks‖, thus including an explicit guarantee of protection against interference by private parties. This results in a positive obligation of States parties to protect privacy against interference and attacks by others, 40 which has been found to be of particular relevance, for instance, in relation to persons deprived of personal liberty, older persons, persons with disabilities or transgendered persons. 41 This provision is of enormous significance in the context of combatting stigma. It clearly demonstrates that States‘ obligations reach into the private sphere. They cannot dismiss stigma as a social phenomenon over which States have no influence. Instead, they have positive obligations that extend into this realm, requiring States, for instance, to take measures that enable women and girls to manage their menstrual hygiene needs in a manner that protects their privacy and dignity. VI. Identifying appropriate strategies for prevention and response 58. States cannot meet their human rights obligations without addressing stigma. They not only have obligations not to act as stigmatizers, but are also obliged to protect individuals from actions or omissions of third parties. States must protect individuals from human rights abuses committed by private actors, including the media, service providers, community members and family members. To determine what States are required to do to combat stigma, one can build on the due diligence standard developed to define the obligations of States as regards the actions of private parties. It has been widely used in other areas of law, such as violence against women,42 providing a framework of assessment 39 40 41 42 Western Cape High Court, Beja and Others v. Premier of the Western Cape and Others, case No. 21332/10, judgement of 3 April 2011, para. 150. Nowak, CCPR Commentary (note 32 above), p. 380 Ibid. See report of the Special Rapporteur on violence against women, its causes and consequences (E/CN.4/2006/61); Declaration on the Elimination of Violence against Women, art. 4 (c); Committee 15