CEDAW/C/GC/32 28. The Committee is aware that, in cases in which persecution is perpetrated by non-State actors, receiving States have advanced the option of internal flight alternative, according to which a person is not at risk of persecution by non-State actors if he or she is relocated to a safe place within the State of origin. The Committee recalls that articles 2 (d) and (e) of the Convention require that States parties ensure that women are protected against discrimination generated by non-State actors and, in the context of a refugee woman, it observes that the essence of refugee status is to provide effective protection to the refugee woman. It also notes that, should the internal flight alternative be considered by receiving States, the option should be subject to strict requirements, such as the woman’s ability to travel to the area concerned and gain admittance and settle there. 25 States should also take into account gender-related aspects and risks in the assessment as to whether internal relocation is permissible. 26 Difficulties faced by women in relocating to other parts of their countries of origin can include legal, cultural and/or social restrictions or prohibitions on women travelling or living alone, practical realities such as problems of securing accommodation, childcare and economic survival without family or community support, and risk of harassment and exploitation, including sexual exploitation and violence. 29. The Committee acknowledges that, as a matter of international law, the authorities of the country of origin are primarily responsible for providing protection to the citizens, including ensuring that women enjoy their rights under the Convention, and that it is only when such protection is not available that international protection is invoked to protect the basic human rights that are seriously at risk. However, the Committee notes that the fact that a woman asylum seeker has not sought the protection of the State or made a complaint to the authorities before her departure from her country of origin should not prejudice her asylum claim, especially where violence against women is tolerated or there is a pattern of failure in responding to women’s complaints of abuse. It would not be realistic to require her to have sought protection in advance of her flight. She may also lack confidence in the justice system and access to justice or fear abuse, harassment or retaliation for making such complaints. 27 30. In line with the Convention, States parties are required to take proactive measures to ensure that the legally recognized grounds of persecution, including those enumerated in the 1951 Convention relating to the Status of Refugees (race, religion, nationality, membership of a particular social group and political opinion), are given a gender-sensitive interpretation. In addition, gender may be used as a factor in recognizing membership of a particular social group or indeed as an identifying characteristic of such a group for purposes of granting refugee status __________________ 25 26 27 10/21 Salah Sheekh v. the Netherlands, application No. 1948/04, judgement of 11 January 2007 of the European Court of Human Rights, cited in Case of Sufi and Elmi v. the United Kingdom, applications Nos. 8319/07 and 11449/07, judgement of 28 June 2011 of the European Court of Human Rights, para. 266. UNHCR, “Guidelines on international protection: ‘internal flight or relocation alternative’ within the context of article 1A(2) of the 1951 Convention and/or 1967 Protocol relating to the Status of Refugees”, guideline No. 4 (HCR/GIP/03/04); UNHCR, “Guidance note on refugee claims relating to female genital mutilation”, paras. 28-32 (see footnote 21 above). Communication No. 5/2005, Şahide Goekce (deceased) v. Austria, views adopted by the Committee on 6 August 2007; communication No. 6/2005, Fatma Yildirim (deceased) v. Austria, views adopted by the Committee on 6 August 2007. 14-64766