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The purpose of the Optional Protocol is to address violations of socio-economic rights which have been loosely applied when compared to the civil and political rights.

\n

The Protocol achieves this by giving an individual locus standi before the Committee and hence asking directly whether a state violated the ICESCR

\n

Reasons to  support  ratification of the Optional Protocol by the Kenyan government.

\n
    \n
  1.   help clarify Kenya’s obligations under the ICESCR. 
    2. \n
  2. give “context” and meaning to rights such as education, housing, and work, in a developing economy like Kenya’s
    3. \n
  3. strengthen accountability in Kenya.
    4. \n
  4. Offers an opportunity for governments to be thoroughly investigated on their obligations under ICESCR.
    5. \n
  5. the existence of a complaint based mechanism always acts as a warning device towards government.
    6. \n
  6. The Optional Protocol would allow Kenyans to raise concerns with government policies and practices that would otherwise not receive attention from parliament or the media
    7. \n
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The Functions Kenya National Human Rights Commission

\n\n

 

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These provisions are read with
Art. 20(5) and 21(2) of the Constitution which provides that the rights are subject to progressive realisation.

\n

The Constitution does not prescribe the formula and the approach to be adopted in the interpretation of the concept of progressive realisation. It leaves it to the court to interpret what progressive realisation entails and to set the standards that should be met in progressive realisation of socio-economic rights. The courts are supposed to develop the concept of progressive realisation and adopt an interpretation that most favours progressive realisation of socio-economic rights.2

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Monitoring

\n

Most United Nations bodies concerned with human rights provide for continuing supervision of the realization of international human rights standards under a system of periodic review of information including reports from Member States, intergovernmental and non-governmental organizations, and communications alleging violations of human rights and thus the right to education.

\n

As regards monitoring the implementation of the United Nations conventions on human rights, the United Nations Committee on Economic, Social and Cultural Rights (CESCR) as a treaty body, monitors the implementation of the right to education as provided for in Articles 13 and 14 of the International Covenant on Economic, Social and Cultural Rights.

Every five years, each state party to the International Covenant on Economic, Social and Cultural Rights is obliged to submit a report to the Committee. These reports cover all the rights in the Covenant and explain what the state is doing to implement the right to education (articles 13 and 14 of the International Covenant).

Other United Nations treaty bodies whose work relates to monitoring the right to education are: the Committee on the Rights of the Child (CRC) which monitors this right as provided for in Articles 28 to 30 of the Convention on the Rights of the Child (1989); and the Committee on the Elimination of All Forms of Discrimination against Women, which monitors this right as provided for in Article 10 of the Convention on the Elimination of All Forms of Discrimination against Women (1979)

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Kenya is a Dualist State

\n

The Constitution turned the Country from a Monist State to a Dualist State under Article 2 (5)

\n

 

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Article 13: Right to Education

\n

1. The States Parties to the present Covenant recognize the right of everyone to education. They agree that education shall be directed to the full development of the human personality and the sense of its dignity, and shall strengthen the respect for human rights and fundamental freedoms. They further agree that education shall enable all persons to participate effectively in a free society, promote understanding, tolerance and friendship among all nations and all racial, ethnic or religious groups, and further the activities of the United Nations for the maintenance of peace.

\n

2. The States Parties to the present Covenant recognize that, with a view to achieving the full realization of this right:

\n

(a) Primary education shall be compulsory and available free to all;

\n

(b) Secondary education in its different forms, including technical and vocational secondary education, shall be made generally available and accessible to all by every appropriate means, and in particular by the progressive introduction of free education;

\n

(c) Higher education shall be made equally accessible to all, on the basis of capacity, by every appropriate means, and in particular by the progressive introduction of free education;

\n

(d) Fundamental education shall be encouraged or intensified as far as possible for those persons who have not received or completed the whole period of their primary education;

\n

(e) The development of a system of schools at all levels shall be actively pursued, an adequate fellowship system shall be established, and the material conditions of teaching staff shall be continuously improved.

\n

3. The States Parties to the present Covenant undertake to have respect for the liberty of parents and, when applicable, legal guardians to choose for their children schools, other than those established by the public authorities, which conform to such minimum educational standards as may be laid down or approved by the State and to ensure the religious and moral education of their children in conformity with their own convictions.

\n

4. No part of this article shall be construed so as to interfere with the liberty of individuals and bodies to establish and direct educational institutions, subject always to the observance of the principles set forth in paragraph I of this article and to the requirement that the education given in such institutions shall conform to such minimum standards as may be laid down by the State.

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\n

Human Rights Monitoring Mechanisms in the UN System

\n

Human Rights Bodies

\n

The Office of the High Commissioner for Human Rights (OHCHR) works to offer the best expertise and support to the different human rights monitoring mechanisms in the United Nations system : UN Charter-based bodies, including the Human Rights Council, and bodies created under the international human rights treaties and made up of independent experts mandated to monitor State parties' compliance with their treaty obligations. Most of these bodies receive secretariat support from the Human Rights Council and Treaties Division of the Office of the High Commissioner for Human Rights (OHCHR).

\n\n\n\n\n\n\n
\n

Charter-based bodies

\n\n
\n
\n\n\n\n\n\n\n
\n

Treaty-based bodies

\n

There are ten human rights treaty bodies that monitor implementation of the core international human rights treaties:

\n\n
\n
\n

Charter-based bodies

\n

\"UN

\n

Charter bodies include the former Commission on Human Rights, the Human Rights Council , and Special Procedures. The Human Rights Council, which replaced the Commission on Human Rights, held its first meeting on 19 June 2006. This intergovernmental body, which meets in Geneva 10 weeks a year, is composed of 47 elected United Nations Member States who serve for an initial period of 3 years, and cannot be elected for more than two consecutive terms. The Human Rights Council is a forum empowered to prevent abuses, inequity and discrimination, protect the most vulnerable, and expose perpetrators.

\n

The Human Rights Council is a separate entity from OHCHR. This distinction originates from the separate mandates they were given by the General Assembly. Nevertheless, OHCHR provides substantive support for the meetings of the Human Rights Council, and follow-up to the Council's deliberations.

\n

Special Procedures is the general name given to the mechanisms established by the Commission on Human Rights and assumed by the Human Rights Council to address either specific country situations or thematic issues in all parts of the world. Special Procedures are either an individual –a special rapporteur or independent expert—or a working group. They are prominent, independent experts working on a voluntary basis, appointed by the Human Rights Council.

\n

Special Procedures' mandates usually call on mandate-holders to examine, monitor, advise and publicly report on human rights situations in specific countries or territories, known as country mandates, or on human rights issues of particular concern worldwide, known as thematic mandates. All report to the Human Rights Council on their findings and recommendations, and many also report to the General Assembly. They are sometimes the only mechanism that will alert the international community to certain human rights issues, as they can address situations in all parts of the world without the requirement for countries to have had ratified a human rights instrument.

\n

As of 1 November 2014, there are 39 thematic mandates and 14 country mandates.

\n

OHCHR supports the work of rapporteurs, independent experts and working groups through its Special Procedures Branch (SPB) which services all but one of the thematic mandates and provides centralised support to the Special Procedures as a system. The Field Operations and Technical Cooperation Division (FOTCD) supports the work of country-mandates.

\n

Treaty-based bodies

\n

There are nine core international human rights treaties, the most recent one -- on enforced disappearance -- entered into force on 23 December 2010. Since the adoption of the Universal Declaration of Human Rights in 1948, all UN Member States have ratified at least one core international human rights treaty, and 80 percent have ratified four or more.

\n

There are currently ten human rights treaty bodies, which are committees of independent experts. Nine of these treaty bodies monitor implementation of the core international human rights treaties while the tenth treaty body, the Subcommittee on Prevention of Torture, established under the Optional Protocol to the Convention against Torture, monitors places of detention in States parties to the Optional Protocol.

\n

The treaty bodies are created in accordance with the provisions of the treaty that they monitor. OHCHR supports the work of treaty bodies and assists them in harmonizing their working methods and reporting requirements through their secretariats. 

\n

There are other United Nations bodies and entities involved in the promotion and protection of human rights

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Qualitative Aspect assesment of access to Education

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Thirdly, economic, social and cultural rights together with the principle of
non-discrimination bring in a qualitative aspect by asking not only how
many but also who is being lifted out of poverty. For instance, goal 1
seeks to reduce by half the proportion of people who suffer from hunger
by 2015.

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MDGs are political commitments. mThey are not adequate for the achievement of access to education.

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The Millennium Development Goals are political commitmetns. They are a set of benchmarks developed to reflect objectives agreed in the Millennium Declaration, which is a non-legally binding commitment. However, it should be noted that the Millennium Declaration is explicitly built on the recognition of human rights norms and standards.

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Thus the Millennium Development Goals should be pursued in a manner that is compatible with the legal obligations each State may have under human rights norms and standards.

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The scope of issues that economic, social and cultural rights cover is wider than those covered by the Millennium Development Goals.
For example, the Millennium Development Goals do not directly address higher education, security of tenure or participation in cultural life. Thus, while goal 2 requires States to achieve universal primary education, the right to education requires States to address not only primary (which must be free) but also secondary and tertiary education.

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How To monitor the progressive realization of ESC Rights

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    \n
  1. Monitoring budgets is particularly important when analysing the realization of ESCR. National budgets are key political documents reflecting States’ policy priorities as well as the level of public resources. Analysing them is therefore relevant for monitoring efforts towards the progressive realization of rights, including the extent to which the most efficient use is made of the available resources.
    2. \n
  2. Underfunding of programmes, manifest disparities in the use of public funds for specific groups and regions, or significant decreases in funding to particular sectors may indicate a State’s failure to realize economic, social and cultural rights progressively.
    3. \n
  3. monitoring should identify the effort the Government makes in relation to implementation. Measuring the proportion of the budget spent on realizing economic, social and cultural rights can help measure Government effort.
    4. \n
  4. While the analysis of budget processes can be useful to monitor efforts to realize economic, social and cultural rights, there are limitations and challenges. For example, the national budget does not necessarily give the full picture of the financial resources available to a State.
    5. \n
  5. Equally, the size of budget allocations to different sectors does not necessarily lead to improved access to services and the realization of rights. Often the key issue is not the amounts spent, but rather how they are spent
    6. \n
  6. A country’s ability to progressively realize economic, social and cultural rights hinges upon, in no small measure, its capacity to formulate an appropriate budget based on sound policy and participation, and to ensure its effective and efficient utilization. (Bernards Mudho, independent expert on the effects of structural adjustment policies and foreign debt on the full enjoyme
    7. \n
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All the nine core United Nations human rights treaties have their own monitoring mechanisms—committees of independent experts known as treaty bodies.The main treaty body overseeing the implementation of economic, social and cultural rights is the Committee on Economic, Social and Cultural Rights

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Treaty bodies perform four main functions:
(a) They periodically review reports on States' implementation of treaties;
(b) They articulate the contents of rights and obligations under the treaties through their general comments or general recommendations;
(c) Most treaty bodies examine complaints known as communications or petitions from individuals and groups of individuals.
(d) Some treaty bodies also conduct inquiries, under certain conditions, when they receive reliable information of grave or systematic violations of human rights..

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The other main United Nations human rights mechanisms which monitor States’ compliance with their human rights obligations are the special
procedures of the Human Rights Council.

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The Human Rights Council appoints independent experts to address specific country situations or thematic issues.Such experts are called special rapporteurs, independent experts, special representative, or they are appointed as working groups.
Currently, there are several thematic mandates which focus on specific economic, social and cultural rights. e.g.  • The Special Rapporteur on the right to education (since 1998)
Regional mechanisms
There are regional mechanisms to monitor economic, social and cultural rights in Africa, the Americas and Europe. They also regularly review
State party reports, interpret treaties and receive individual
complaints.
Box 19: Regional human rights monitoring mechanisms with clear
mandates covering the protection of economic, social and
cultural rights
African system
The African Commission on Human and Peoples’ Rights
The African Court on Human and Peoples’ Rights

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ESC rights are justiciable

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Filling in the gaps in legislation is a clear function of the judiciary, not only in human rights law but in any area of law.

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some have questioned whether it is possible for a court to assess the progressive realization of economic, social and cultural rights. Monitoring progressive realization can rely on several mechanisms, including the courts. In South Africa, courts have assessed whether the State is meeting its obligations towards progressive realization by considering whether the steps taken by the Government are reasonable.

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A failure to take into account the needs of the most vulnerable in, for instance, a housing policy would suggest that the policy would not meet the test of reasonableness.

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1. Essential features of the right to education pg. 10

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The Committee on Economic, Social and Cultural Rights, through its series
of general comments, has articulated the contents of each economic, social
and cultural right. For example, reflecting the work of the Special Rapporteur
on the right to education, it set out the essential features of the right to
education in its general comment No. 13 (1999):
Education in all its forms and at all levels shall exhibit the following interrelated
and essential features:
(a) Availability: functioning educational institutions and programmes have
to be available in sufficient quantity;
(b) Accessibility: educational institutions and programmes have to be
accessible to everyone.
Accessibility has three overlapping dimensions:
• Non-discrimination: education must be accessible to all, especially
the most vulnerable groups, in law and fact, without discrimination;
• Physical accessibility: education has to be within safe physical reach,
either by attendance at some reasonably convenient geographic
location (e.g., a neighbourhood school) or via modern technology
(e.g., access to a “distance learning” programme);
• Economic accessibility: education has to be affordable to all: whereas
primary education shall be available “free to all”, States parties
are required to progressively introduce free secondary and higher
education;
(c) Acceptability: the form and substance of education, including curricula
and teaching methods, have to be acceptable (e.g., relevant, culturally
appropriate and of good quality) to students and, in appropriate cases,
parents;
(d) Adaptability: education has to be flexible so it can adapt to the needs
of changing societies and communities and respond to the needs of students
within their diverse social and cultural settings.
When considering the appropriate application of these “interrelated and essential
features” the best interests of the student shall be a primary consideration.

\n

2. What are the obligations of States on economic, social
and cultural rights? pg. 11
The obligations of States in relation to economic, social and cultural
rights are expressed differently from treaty to treaty. For example, the
International Covenant on Economic, Social and Cultural Rights requires
States “to take steps” to the maximum of their available resources to
achieve progressively the full realization of economic, social and cultural
rights.

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The Covenant also requires States to guarantee the enjoyment of
economic, social and cultural rights without discrimination and to ensure
the equal right of men and women to the enjoyment of these rights.

\n

Other treaties or constitutions word obligations differently and even include
specific actions that States must take, such as the adoption of legislation
or the promotion of these rights in public policies.

\n

In order to clarify the meaning of States’ obligations, they are sometimes
put under three headings: to respect, to protect and to fulfil economic,
social and cultural rights.

\n

3. What is progressive realization of social economic and Cultural rights?

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The concept of “progressive realization” describes a central aspect of States’ obligations in connection with economic, social and cultural rights
under international human rights treaties. At its core is the obligation to take appropriate measures towards the full realization of economic, social and cultural rights to the maximum of their available resources (see box 5). The reference to “resource availability” reflects a recognition that the realization of these rights can be hampered by a lack of resources and can be achieved only over a period of time. Equally, it means that a State’s compliance with its obligation to take appropriate measures is assessed in the light of the resources—financial and others—available to it. Many national constitutions also allow for the progressive realization of some economic, social and cultural rights.

\n

The concept of progressive realization is sometimes misinterpreted as if States did not have to protect economic, social and cultural rights until
they have sufficient resources. On the contrary, the treaties impose an immediate obligation to take appropriate steps towards the full realization
of economic, social and cultural rights. A lack of resources cannot justify inaction or indefinite postponement of measures to implement these rights.
States must demonstrate that they are making every effort to improve the enjoyment of economic, social and cultural rights, even when resources
are scarce.

\n

For example, irrespective of the resources available to it, a State should, as a matter of priority, seek to ensure that everyone has access
to, at the very least, minimum levels of rights, and target programmes to protect the poor, the marginalized and the disadvantaged.

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4. Obligation to Take Steps

\n

Even under the obligation of progressive realization, States have to make constant efforts to improve the enjoyment of economic, social and cultural rights. This means that, while their full realization may be achieved progressively, steps towards that goal must be taken within a reasonably short time.

\n

Such steps should be deliberate, concrete and targeted as clearly as possible, using all appropriate means, including particularly but not only the adoption of legislative measures.
Examples of steps that States should take towards progressive realization:

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• Assess the state of enjoyment of esc rights, including ensuring adequate mechanisms to collect and assess relevant and suitably disaggregated data;
• Formulating strategies and plans, incorporating indicators and time bound targets, realistic, achievable and designed to assess progress in the realization of these rights;
• Adopting the necessary laws and policies, and making adequate funds available to put the plans and strategies into practice;
• Regularly monitoring and assessing the progress made in the implementation of the plans and strategies;
• Establishing grievance mechanisms so that individuals can complain if the State is not meeting its responsibilities.

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5. Minimum Core Obligations

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The Committee on Economic , Social and Cultural Rights in its general comments highlighted the Minimum core obligations, require States to: Ensure free and compulsory primary education to al

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6. Do economic, social and cultural rights oblige Governments to supply goods and services free of charge?

\n

Some services necessary for realizing certain ecs  rights must be provided free of charge. For example, under international law, primary education must be free and compulsory for all, and secondary education should be available and accessible to all, in particular by the progressive introduction of free
education. Services relevant to pregnancy should be free to women where necessary. Some national legislation might also require other
services relevant to other economic, social and cultural rights to be provided free of charge.

\n

7. Scope of issues that esc rights cover is wider than those covered by the Millennium Development Goals.
For example, the Millennium Development Goals do not directly address higher education, security of tenure or participation in cultural life. Thus,
while goal 2 requires States to achieve universal primary education, the right to education requires States to address not only primary (which must
be free) but also secondary and tertiary education.

\n

 

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Key Actors in Promoting and Protecting the right to Education

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The Key Actors in promoting and protecting the right to education

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8. Here are examples of actions that State organs can take:

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(a) The legislature has a role to play in

\n\n

(b) The executive complements the work of the legislature and has an important role in

\n\n

(c) The judiciary 

\n\n

(d) National human rights institutions (NHRIs), such as ombudsmen, national human rights commissions and defensores del pueblo(peoples defender)

\n\n

(e) Various actors in civil society, such as NGOs, social movements, community-based organizations, human rights defenders,
professional associations (e.g., associations of lawyers, health professionals, teachers), trade unions, academics and religious
institutions, have crucial roles in working with individuals and groups to promote their economic, social and cultural rights, and in holding the
Government accountable for realizing these rights.

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Goal Four Targets

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Some of the critical shortcomings and challenges facing the education system include
the following:
(a) Many children still remain out of school. It is estimated that 1.5 million
children are still out of school. These include children with special needs,
the handicapped, the exceptionally gifted children, refugees and children
in exceptional difficult circumstances.
(b) Declining enrolment and participation rates at higher levels of education.
(c) Gender parity has almost been achieved nationally especially in primary
schooling. However, there are disparities in regions especially in arid and
semi arid lands, areas of informal settlements and hard to reach areas.
Gender disparities are evident as one goes up the education ladder.
(d) Many pupils do not proceed to secondary school. For example, in 1999 the
transition rate from primary to secondary was only 44.8% (43.1% for girls
and 46.1% for boys). However, this has improved to over 70%.
(e) Under-enrolment of children with disabilities in formal schools. The
education system does not effectively cater for children with special needs
including the exceptionally gifted children.
(f) Inefficiency, poor governance and management of structures and
educational institutions are still a poor mark of the present education
management.

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", "tags": [], "collections": [], "relations": {}, "dateAdded": "2015-11-06T19:17:42Z", "dateModified": "2015-11-06T19:17:42Z" } }, { "key": "MM63VBG8", "version": 3, "library": { "type": "group", "id": 426489, "name": "Realization of the Right to Education", "links": { "alternate": { "href": "https://www.zotero.org/groups/realization_of_the_right_to_education", "type": "text/html" } } }, "links": { "self": { "href": "https://api.zotero.org/groups/426489/items/MM63VBG8", "type": "application/json" }, "alternate": { "href": "https://www.zotero.org/groups/realization_of_the_right_to_education/items/MM63VBG8", "type": "text/html" } }, "meta": { "createdByUser": { "id": 2710061, "username": "Purity Kibugi", "name": "", "links": { "alternate": { "href": "https://www.zotero.org/purity_kibugi", "type": "text/html" } } }, "creatorSummary": "Orodho et al.", "parsedDate": "2013", "numChildren": 1 }, "data": { "key": "MM63VBG8", "version": 3, "itemType": "journalArticle", "title": "Progress towards attainment of Education for All (EFA) among Nomadic Pastoralist: Do Home-based Variables make a Difference in Kenya", "creators": [ { "creatorType": "author", "firstName": "John Aluko", "lastName": "Orodho" }, { "creatorType": "author", "firstName": "Peter Ndirangu", "lastName": "Waweru" }, { "creatorType": "author", "firstName": "Kennedy Nyambeche", "lastName": "Getange" }, { "creatorType": "author", "firstName": "Justus Mbae", "lastName": "Miriti" } ], "abstractNote": "The purpose of this study was to analyze home-based factors inhibiting access and participation in basic education among vulnerable groups in Garissa County, Kenya. The study was framed by a household production function approach that typically assumes that postulates that household schooling decisions are explained by the interaction of social, cultural, and economic factors working through power relations within the household.  The study used a sample of 45 students selected by convenience sampling from undergraduate and postgraduate students undertaking their school-based studies at Kenyatta and Mount Kenya universities residing or teaching in Carissa County, Kenya during the 2012/203 academic year. The   study used mixed methods to collect and analyze the data.  It was found that despite the gains in access and equity since the launch of FPE and FDSE in Kenya at the national level, there still remain pockets within Kenyan communities, especially Carissa County which has remained unreached for a host of reason including home-based factors. The major reasons were the low educational level of the heads of households, household poverty, retrogressive cultural practices, and low premium attached to education. It is concluded that home-based factors make a significant difference in efforts to achieve EFA among nomadic pastoralists .It is recommended  that :all other user charges that have been sneaked into the current FPE and FDSE should be removed; enhance the school security by  advocating for  peaceful conflict resolution; create  a conducive learning environment through peace education and education in emergency; reverse most of the retrogressive socio-cultural practices through civic education as well as mass advocacy and appropriate legal measures as stipulated in the Basic Education Act 2013;  amongst others. Key words :  Home-based factors, Access, Participation, equity, and quality of Basic Education, Nomadic pastoralists, multiple approaches; Education for All.", "publicationTitle": "Research on Humanities and Social Sciences", "publisher": "", "place": "", "date": "2013", "volume": "3", "issue": "21", "section": "", "partNumber": "", "partTitle": "", "pages": "54-67", "series": "", "seriesTitle": "", "seriesText": "", "journalAbbreviation": "", "DOI": "", "citationKey": "", "url": "http://www.iiste.org/Journals/index.php/RHSS/article/view/9535", "accessDate": "2015-10-28T08:33:29Z", "PMID": "", "PMCID": "", "ISSN": "2225-0484", "archive": "", "archiveLocation": "", "shortTitle": "Progress towards attainment of Education for All (EFA) among Nomadic Pastoralist", "language": "en", "libraryCatalog": "www.iiste.org", "callNumber": "", "rights": "", "extra": "", "tags": [], "collections": [], "relations": {}, "dateAdded": "2015-11-06T19:17:38Z", "dateModified": "2015-11-06T19:17:38Z" } }, { "key": "IZU6JB4T", "version": 3, "library": { "type": "group", "id": 426489, "name": "Realization of the Right to Education", "links": { "alternate": { "href": "https://www.zotero.org/groups/realization_of_the_right_to_education", "type": "text/html" } } }, "links": { "self": { "href": "https://api.zotero.org/groups/426489/items/IZU6JB4T", "type": "application/json" }, "alternate": { "href": "https://www.zotero.org/groups/realization_of_the_right_to_education/items/IZU6JB4T", "type": "text/html" }, "up": { "href": "https://api.zotero.org/groups/426489/items/MM63VBG8", "type": "application/json" } }, "meta": { "createdByUser": { "id": 2710061, "username": "Purity Kibugi", "name": "", "links": { "alternate": { "href": "https://www.zotero.org/purity_kibugi", "type": "text/html" } } }, "numChildren": 0 }, "data": { "key": "IZU6JB4T", "version": 3, "parentItem": "MM63VBG8", "itemType": "note", "note": "

1. Over a decade has passed since the international community adopted the six Educations for All (EFA) goals at
the World Forum held in Dakar, Senegal in April 2000, as well as the Millennium Development Goals in 2000
that call for increased access to quality basic education and training which have been domesticated in Kenya
(World Education Forum, 2000; Republic of Kenya/UNESCO, 2012). This broad Vision of education and the
holistic approach to sector development was fully embraced by Kenya as a critical vehicle for realizing Vision
2030, the road map for development (Odhiambo, 2010; Gikondi et.al, 2010; Republic of Keya/UNESCO, 2012).

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2.

", "tags": [], "relations": {}, "dateAdded": "2015-11-06T19:17:38Z", "dateModified": "2015-11-06T19:17:38Z" } } ]