The lack of data collection and the collected data not being shared with the public, makes it impossible for CSOs and DPOs to conduct monitoring activities in line with the Convention. Recommendations for Article 31 - In order to provide the necessary public services and academic studies for persons with disabilities, the entire population of persons with disabilities need to be identified and this identification should be supported by disaggregated data, such as the region, gender, age, type of disability, and the rate of disability. - The General Directorate of Services for Persons with Disabilities and Elderly (EYHGM) should prepare a policy document in line with the Convention on how to establish statistical data in the field of disability; this should include persons with disabilities and CSOs to participate effectively in the preparatory process. Effective participation is only possible if the right to speak is explicit, the feedback mechanism functions and the channels are clear. - The policy document to be prepared should be binding for all public institutions collecting statistics on the disability area. - The sample groups selected for the collection of data on persons with disabilities should include persons with disabilities who belong to different ethnic, religious or belief groups and gender identities (LGBTI+) etc. who are at risk of multiple discrimination, and the results collected should be analyzed in terms of these groups. - Persons with disabilities, CSOs and DPOs should be actively included in the process of data collection. An action plan with a time frame and set budget should be developed to collect data on the level of access to rights for persons with disabilities, including different ethnic, religious or belief groups, LGBTI+ persons with disabilities, persons with disabilities in rural areas and persons with disabilities at closed institutions, starting from the groups with the least access to rights. 30