A/HRC/44/32/Add.1 affected stakeholders in practice. To help overcome these problems, some mechanisms have the flexibility to commence investigations on their own initiative. 43. Ways that the “user-friendliness” of grievance handling processes (8.3(a)) can be enhanced include providing templates and model submissions, ensuring that these and other documents are available in the languages spoken by potentially affected stakeholders, and allowing rights holders to engage with the mechanism in their own languages. Procedures are unlikely to be user friendly, however, without meaningful consultation with rights holders about their needs and preferences. Mechanisms that are intended to benefit specific communities should be informed by an understanding of local methods of decision-making, and should be designed to work in a manner that is complementary to established practices, wherever possible. 44. In many cases, accessibility is best served by providing rights holders with a variety of communication options (8.3(a)), which could include the use of toll-free telephone lines, electronic or regular mail, and other online and in-person communication methods. Adopting a gender perspective will help mechanisms identify specific barriers that are faced by women (8.3(a) and 8.6), which may be cultural in nature, and/or related to physical security, job security, costs of arranging childcare and the times of day that they can participate. Grievance mechanisms should not overlook the economic barriers faced by people who may need to take time off to defend their rights and seek remedies for harm (e.g. in the form of lost wages). 45. Non-State-based grievance mechanisms must not be used to impede rights holders’ access to judicial mechanisms or relevant State-based non-judicial mechanisms. Thus, nonState-based grievance mechanisms should never demand that rights holders give up their rights to seek remedies elsewhere as a condition of accessing or participating in grievance processes (8.4). On the contrary, the mechanism should anticipate and respond appropriately to the possibility of parallel, overlapping or consecutive proceedings, especially in cases where the mechanism may provide only a partial remedy.37 46. Providing for collective action by rights holders can be an important way to enhance accessibility, for instance by allowing them to share costs and representation (8.5). 47. Mechanisms should take steps to reduce financial barriers that may be associated with their use (8.7). Examples include making available, free of charge, appropriate advisory and support services (e.g. through helplines or designated case workers), offline and online resources (e.g. pamphlets and videos), and assistance with translation of documents and other information. Furthermore, appropriate adjustments should be made to enhance access to different groups of rights holders (8.8), e.g., through the provision of resources in braille and audio formats. 48. Mechanisms should act responsibly to address rights holder concerns about the possibility of retaliation, and to reduce risks of harm (8.9). Where confidentiality has been requested by a rights holder, or the circumstances of a case would otherwise make it necessary or appropriate, policies and processes should be in place to guard against disclosures of personal information (and any information which may be used to identify a person) without the relevant person’s explicit consent (ensuring that such consent will not be deemed to have been given unless the relevant person has been fully informed of the risks to themself). In some cases, and especially where there are risks of retaliation, the need for accessibility may be best served by providing for the possibility of anonymous complaints, provided due process concerns are properly addressed.38 49. The strategies needed to address the risks of retaliation (8.9(b)) will be context dependent, though could comprise suitable organizational policies (e.g. “zero tolerance” policies), case-specific risk assessment and mitigation plans, and providing advice as to steps people may take for their own personal safety. 37 38 12 See section II.A.3. See para. 55 below.