employer association was established, as well as for the Office of the Council of Ministers, the Ministry of Justice and the Ministry of Interior. The filing of the statutes and the name list of leaders, managers and those responsible for the administration shall be re-submitted if any changes are made to the statutes or in the leaders, managers and those responsible for the administration. Comment: Authorization at the discretion of the Government The phrase “shall be approved” in draft article 12 allows for the possibility of the registration procedure becoming an authorization procedure, which would be contrary to the ICESCR.18 The CESCR has voiced concern for authorization regimes, calling upon State parties to consider repealing legal provisions requiring authorization before a trade union can legally exist.19 The SRFAA “is of the opinion that a ‘notification procedure’, rather than a ‘prior authorization procedure’ that requests the approval of the authorities to establish an association as a legal entity, complies better with international human rights law and should be implemented by States”.20 Moreover, in contrast to the considerable detail with which the requirements on unions for registration are set out, precise information on the process or criteria for the granting of approval has been omitted. This task is left to the Ministry of Labor to set out subsequently in a Prakas – an omission that confers a high degree of discretion to the Government and could constitute an infringement of international law, particularly when considered together with draft article 15. Regular publication of personal details The lack of clarification in the phrase “may work together to publish [registration records] on a regular basis” in draft article 11 could give rise to concerns expressed by the CFA/ILO that “[t]he establishment of a register containing data on trade union members does not respect rights of the person (including privacy rights) and such a register may be used to compile blacklists of workers.”21 Recommendations OHCHR recommends revising the phrase “shall be approved” to ensure that the registration process, in practice, will not require approval. OHCHR recommends revising the phrase “may work together to publish them on a regular basis” from draft article 11, to specify the information that would be published. Article 13: The statutes of any union or employer association seeking registration shall include:  The name, logo, address, and a sample stamp of the union or the employer association;  A description of the occupational or sectoral scope of the union or the employer association;  The determination of safekeeping of ordinary financial records and regular publication of annual financial reports of the union or the employer association;                                                              18 See OHCHR comments on draft article 9 on the permissible limitations to freedom of association under article 8 of the ICESCR. 19 For example, see E/C.12/1/Add.62, para. 44. 20 21  A/HRC/20/27, para. 58.  Digest decision of Freedom of Association of ILO, para. 177. 12