A/HRC/45/14 individual autonomy also means that older persons need to be allowed to deviate from what is expected of them. 45. The growing gap between the data that older persons actively offer and the massive amounts of passive data being generated and mediated by third parties magnifies challenges relating to data protection, individual data sovereignty and informational self-determination that need to be addressed. There is a need to assess existing frameworks comprehensively and to update them to address challenges emerging from data collection via new technologies.21 D. Overview of the legal and policy framework and recent initiatives 46. The existing international human rights framework does not currently include a specific obligation for data on older persons to be gathered in order to effectively monitor and measure the implementation of their rights. 47. The Committee on Economic, Social and Cultural Rights recognizes the role of data in giving effect to the International Covenant on Economic, Social and Cultural Rights. In its general comment No. 20 (2009) on non-discrimination in economic, social and cultural rights, the Committee calls for national strategies, policies and plans to use appropriate indicators and benchmarks, disaggregated on the basis of the prohibited grounds of discrimination. By noting that age is a prohibited ground, but, however, in several contexts only, the Committee failed to attribute to age discrimination equal standards of protection as to other grounds. The Committee only focused on discrimination in the fields of work and pensions. Read together, the general obligation for data collection, analysis and dissemination and the lack of a generalized prohibition of age discrimination do not create an adequate framework for monitoring older persons’ rights and collecting data as evidence of age discrimination. Neither did the Committee’s earlier general comment No. 6 (1995) on the economic, social and cultural rights of older persons include a reference to data collection and disaggregation. General recommendation No. 27 (2010) of the Committee on the Elimination of Discrimination against Women, though referring to the need for data disaggregated by age and sex, and highlighting vulnerable groups and situations,22 applies to older women only. 48. There is some guidance at the regional level deriving from the Inter-American Convention on Protecting the Human Rights of Older Persons and the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Older Persons in Africa. For example, article 30 of the Inter-American Convention calls on member States to ensure equal access to financial services. This obligation could inform the implementation of target 8.10 of the Sustainable Development Goals on expanding access to banking, insurance and financial services for all.23 Article 21 of the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Older Persons in Africa considers the coordination and collection of data, and stipulates that States parties are to ensure the systematic collection and analysis of national data on older persons. Article 21 also calls for the development of a national mechanism on ageing with the responsibility to assess, monitor, evaluate and coordinate the integration and implementation of older persons’ rights in national policies, strategies and legislation. 49. The Madrid International Plan of Action on Ageing, as the main international policy framework on older persons, makes very few references to the need for improved data collection and analysis. To facilitate the national reviews and appraisals of the Plan of 21 22 23 Data Strategy of the Secretary-General for Action by Everyone, Everywhere, with Insight, Impact and Integrity, 2020–2022, p. 27. General recommendation No. 27 (2010) on older women and the protection of their human rights, para. 19. Economic Commission for Latin America and the Caribbean, Sandra Huenchuan and Emiliana Rivera (eds.), Experiencias y Prioridades Para Incluir a las Personas Mayores en la Implementación y Seguimiento de la Agenda 2030 para el Desarrollo Sostenible (United Nations publication, LC/MEX/SEM.245/1). 11