Updates on the inclusion of Roma from Belgium, Estonia, Finland, Greece, Italy and Lithuania

Belgium must do more to support Roma and Travellers’ access to fundamental rights

March 12, 2020

The second Roma Civil Monitor (RCM) report on Belgium examined the four central themes of employment, housing, health and education. The primary takeaway is that Roma and Travellers still do not enjoy their fundamental rights in this EU Member State to the extent that others do, especially in the field of housing. “Belgium must take measures to ensure Travellers access to sites during winter and to reduce the massive homelessness amongst Roma families,” says Ahmed Ahkim, director of the Centre de Médiation des Gens du Voyage et des Roms en Wallonie, which organized the work on the Roma Civil Monitor report.

The RCM reports are part of a project that began in 2017 and is funded by the European Commission for the purpose of strengthening the involvement of Roma civil society in the monitoring of National Roma Integration Strategies (NRIS) across the EU. The added value of civil society monitoring is that the coalitions of NGOs participating are in close contact with Roma communities and represent independent voices.

Photo from the "Romalettre project" of the Centre de Médiation des Gens du Voyage et des Roms en Wallonie, taken on 21 May 2019 in Charleroi; the project supports Roma children in making progress at school. (PHOTO: Centre de Médiation des Gens du Voyage et des Roms en Wallonie)

This article is a summary of the main findings of the second Roma civil society monitoring report in Belgium:

Employment: The report has found that the NRIS relies mostly on existing projects within existing structures and organizations, focusing more specifically on Roma migrants. In Flanders, a 2016 ESF funding call financed seven year-long projects focusing on the inclusion of Roma people in the labour market. The Flemish Action Plan for MOE-migrants (2012) called for the employment of mediators to work with Roma communities; however, in the three cities involved in such mediation projects, it is not required that the mediator/street stewards be of Roma background. A Forum of Minorities survey concluded that employing more mediators of Roma origin would improve implementation of the Action Plan. A few grassroots organizations employ Roma mediators and have launched projects focused on Roma socio-professional insertion. Additionally, the NRIS and the Roma Civil Monitor support the approach of the VormingCentrum GroepINTRO organization in Brussels, which since 2008 has been helping youth (including a significant percentage of Roma) to access the labour market through alternated instruction (combination of learning and working).

Housing: The report has found that the housing situation of Roma and Travellers, though characterized by distinct issues for each group, remains significantly problematic and unsolved. An increasing number of EU Roma are homeless in Belgium, leading to increased rates of squatting and the recent development of slums. A 2016 report from the Coopération et Initiatives pour les Réfugiés et Etrangers (CIRE) estimated that there are about 300 homeless Roma people in Brussels. Though the Belgian strategy was planning on providing "support for the temporary occupation of dilapidated buildings" in Brussels, Belgian authorities adopted a new law against squats in 2017 which exacerbated the problem. The “Housing First” homeless remediation programme has been running in the country since 2013 and has proven efficient for the homeless population, but reportedly nobody from the Roma community has benefited from it yet, in part because it is designed for individuals (not families). The basic conditions for accessing social housing exclude most EU Roma by virtue of their legal status.

As far as Travellers are concerned, the main problem they face is a critical shortage of sites, both for permanent and temporary stays. In 2012 Belgium was found to have violated the European Social Charter because of a significant lack of sites and because of its handling of evictions in general. As for Travellers who wish to remain on a residential site, a 2016 report estimated that between 500 to 1 000 Traveller families are waiting to be allocated a site by local authorities in Belgium. For both populations, these conditions of housing instability have a direct impact on their access to fundamental rights, including their access to health care and education.

Health: In 2014, the European Commission’s Roma Health Report found that Roma generally suffer from worse health than the rest of the European population, including lower life expectancy, higher child mortality, and more frequent rates of chronic and infectious diseases. According to that report, “the Brussels municipal social services estimate that Roma have a life expectancy of 55 years and that Roma health is poor, even when compared to refugees and undocumented migrants; and suggests this [is] to be linked to housing conditions.”  The RCM report has confirmed that this population in Belgium still suffers from globally poor medical conditions and very deficient access to healthcare. Still today, extreme poverty and social exclusion are likely the main visible factors. These issues are amplified significantly for those in situations of homelessness and for those without legal status in Belgium. Emergency Medical Assistance (EMA) is the only form of free social aid legally available to foreigners on an “illegal stay” or to EU citizens without health insurance or a legal residence. Yet in 2018, the Belgian government reformed the EMA to feature stricter regulations that further restricted access to healthcare for these vulnerable groups.

Education: The schooling of Roma children in Belgium still involves pitfalls. Amongst the main obstacles to their improved school attendance is the deep poverty in which many Roma families live, which is sometimes paired with situations of homelessness. When it comes to Travellers, it appears that the main reason for their low participation in education is that there is currently no school system adapted to a mobile lifestyle.

The Roma civil society monitoring recommends, among other things, that Belgium make the creation of sites for Travellers compulsory; promote the employment of Roma and Traveller mediators, especially in the fields of education and health; enforce anti-discrimination law with respect to the field of employment; develop accommodation alternatives that are suitable for homeless families; institute a moratorium on evictions of Travellers during winter ; and inform and support the Roma community in to their access to education and health care.

From: https://cps.ceu.edu/article/2020-03-12/roma-civil-society-belgium-must-do-more-support-roma-and-travellers-access?ct=t(EMAIL_CAMPAIGN_11_22_2019_12_36_COPY_01)&mc_cid=1619553d62&mc_eid=9b2


Substandard conditions in Estonia means no running water for some Roma

March 23, 2020

The second Roma Civil Monitor (RCM) report for Estonia has found that Roma community representatives say some members of the community are living in substandard conditions. In terms of demographics, 40 per cent of Roma in Estonia are Estonian citizens, 38 per cent are Latvian citizens, 14 per cent are Russian citizens and 7 per cent are stateless. The country’s Roma Integration Council was established in 2015 by the Culture Ministry and has 11 members, nine representing local governments and ministries and two members representing the Roma community. While Roma can access public services like all other residents, no specific measures have been developed to target their communities with information.

The RCM reports are part of a research project that began in 2017 and is funded by the European Commission for the purpose of strengthening the involvement of Roma civil society in the monitoring of Roma integration strategies across the EU. The added value of civil society monitoring is that it builds on the direct experience of Roma women and men and represents their independent voices. The report was drafted through a consultation process including Roma associations, civil society members, and community members.

“It’s good to see that after the report was published, the Government opened a public call to find a mentor for the Roma community,” says Egert Rünne, Director of Estonian Human Rights Centre. “The purpose of the mentor's work is to support Roma integration, including raising the Roma community's awareness of their rights and responsibilities. Also, the work includes improving the capacity of the public sector to safeguard Roma rights and overcome cultural differences. Its a step forward toward realizing the long-awaited dream of opening a Roma support centre.”

Estonia’s Unemployment Insurance Fund has justified not targeting Roma by explaining that all labour market services are already provided based on individual needs. Those Roma community representatives interviewed for the RCM report said Roma are reluctant to approach the fund for assistance because they fear interacting with the bureaucracy and experiencing discriminatory attitudes. For that reason, the Roma community would benefit from support targeting their community and delivered by Roma representatives. A study from 2014 found that 100 % of Roma youth respondents reported having perceived employers as being afraid of them because of their ethnicity.

Romani community member Zalina Dabla (left) and reporter Mari Roonema (right) at Radio Kuku for an interview on 9 October 2019 about the situation of Roma in Estonia; journalists reached out to the community after the Roma Civil Monitor report was published.(PHOTO: Estonian Human Rights Centre)

The Chancellor of Justice in Estonia is charged with verifying allegations of discrimination and settling disputes, including through conciliation procedures that require both parties’ consent. There is no information available whether any cases of work-related discrimination against the Roma have been brought to the attention of the Chancellor of Justice or the Office of the Gender Equality and Equal Treatment Commissioner.

The Roma community in Valga, near the Latvian border, is the largest in the country, and most of the Roma there emigrated to Estonia from Latvia. Representatives of the Roma community interviewed there for the RCM report said there have been issues with the availability of social housing in Valga and that often the social housing that is available is not suitable for families. A previous small-scale study in 2013 found that some Roma have no access to either electricity or running water.

Registration with the Unemployment Insurance Fund described above would also entitle Roma who are unemployed to health insurance and access to free general medical care. According to a report from 2018, about 6 per cent of Estonian residents do not have health insurance. There are no statistics available about how many Roma are insured, but Roma community representatives interviewed said lack of health insurance is indeed a problem in the Roma community.

Civil society recommends opening a Roma-staffed support centre to help Roma unemployed persons access labour market services; that research be conducted on why Roma face challenges in accessing housing; that data be collected on the Roma community’s access to health care; and that teachers be specifically trained for working with Roma students.

From: https://cps.ceu.edu/article/2020-03-23/roma-civil-society-substandard-conditions-estonia-means-no-running-water-some?ct=t(EMAIL_CAMPAIGN_11_22_2019_12_36_COPY_01)&mc_cid=1619553d62&mc_eid=9b29de635f

Finland marks 60 years of Roma advocacy

March 26, 2020

The second Roma Civil Monitor (RCM) report for Finland has found that mainstream employment services are having only a limited impact on Roma jobseekers. Despite general improvement in access to housing, some districts remain “challenging” and require public authorities or Roma NGOs to constantly negotiate with them to ensure Roma have equal access to housing there. Both NGOs and public authorities have been researching Roma health and access to healthcare services in order to increase health care providers’ and social services workers’ sensitivity to Roma needs. Recent studies have found that Roma education has not improved as expected and there is still a gap between mainstream Finnish students and Roma in terms of the level of education attained.

The RCM reports are part of a research project that began in 2017 and is funded by the European Commission for the purpose of strengthening the involvement of Roma civil society in the monitoring of Roma integration strategies across the EU. The added value of civil society monitoring is that it builds on the direct experience of Roma women and men and represents their independent voices. The report was drafted through a consultation process including Roma associations, civil society members, and community members.

Dimitri Lindgren (left), an event worker and Carmen Valerius (right), field worker, both members of the Finnish Roma youth network, plan the next week’s work in the office of the Finnish Roma Association, January 2020. (PHOTO: Samer Qaraman, media worker, Finnish Roma Association)

“Among the Finnish Roma NGOs there has been very little European-level cooperation in policy making,” says Paivi Majaniemi of the Finnish Roma Association. “The RCM reports may work as an initiative to encourage our NGOs to more systematically gather more relevant information for Roma policy development. This will benefit us, as well as give us some tools to compare the process with other countries. The RCM reports can create possibilities to better understand European Roma policies and also give us new ways to network with Roma in Europe."

The report finds that the concept of “nothing about us without us” is embraced by the Finnish authorities, who do highly involve Finnish Roma associations in Roma-related policy development. Different campaigns have been rolled out in Finland to promote hiring Roma, including tackling prejudices against them on the labour market by publishing various materials. An ESF-funded project has investigated discrimination against Roma when applying for jobs, and its preliminary findings emphasize both the effects of the structural discrimination against Roma and Roma’s own responsibility for their educational achievement. Because of the traditional clothing they wear, Roma women face more challenges in employment.

There is a long history of effective Roma civil activism in Finland. At the close of the 1960s, the Finnish Roma Association demanded that measures from the Government’s Advisory Board on Roma Affairs pay more attention to Roma housing conditions. Today the Board is an effective tool for democracy and equality at the Government level, and its development has been described in a recent publication celebrating its 60th anniversary. The history of the Roma movement in Finland has also been explored by the international RomArchive project.

Rents in municipally owned housing are regulated in Finland and there is a system of supporting housing by granting general housing allowances to low-income households. As most Roma’s socio-economic status is low, the majority of Roma are eligible for and receive such allowances in Finland. Roma families tend to have more members than non-Roma families in Finland, and combined with the higher Roma unemployment rate, this means Roma are disadvantaged when it comes to accessing housing of the appropriate size.

Civil society recommends authorities be more forceful in addressing the employment situation of the Roma population; investigate increased demand for housing among Roma youth and develop adequate measures to meet their needs; include diversity training in the curriculum for personnel in education and healthcare; and that school administrators should collaborate more with Roma parents and local Roma associations to improve Roma student achievement.


Greece can leverage Roma community strengths to promote inclusion

April 6, 2020

The second round of  Roma Civil Monitor (RCM) reports on Greece reports that a Special Secretariat for Roma Inclusion has been recently established there to act as the focal point for collecting information, planning, and receiving complaints about the social inclusion of Greek Roma people. For the first time, the Greek state is holistically approaching the issue of Greek Roma exclusion and connecting employment promotion measures with the social areas prerequisite to being employable (education, health, housing and training). The state is planning to relocate Greek Roma people living in encampments in miserable conditions into better conditions and to improve Roma-inhabited neighbourhoods that are worth investing in. Data have been reported by researchers demonstrating that some environmental and socioeconomic determinants of health are negatively impacting Greek Roma, who suffer from comparatively poor health. Many difficulties also impede Greek Roma in accessing education.

The RCM reports are part of a project that began in 2017 and is funded by the European Commission for the purpose of strengthening the involvement of Roma civil society in the monitoring of integration strategies across the EU. The added value of civil society monitoring is that the coalitions of NGOs participating are in touch with Roma communities and represent independent voices.

Civil society discussion of employment opportunities with a Roma community in Western Greece (2018). (PHOTO: HEROMACT)

"Greek Roma are Greek citizens who are struggling to find the position they deserve to hold in modern Greek society," says Manolis Rantis of Hellenic Roma Action (HEROMACT), which coordinated the report.

The National Roma Integration Strategy 2011-2020 (NRIS) in Greece includes measures promoting the integration of Greek Roma into the labour market, and various policy sectors (development, economy, education, training) were reportedly involved in the design of those measures. The high rate of labour market exclusion of Greek Roma women due to their lack of education and professional skills is one area where specific measures either have been implemented or are planned to be implemented. The report also touches on the 2018 establishment of a Social Solidarity Income measure providing a monthly benefit to those who are economically the most vulnerable; many beneficiaries of this benefit are Greek Roma, as their standard of living is disproportionately low. The state has also been addressing the issues of informal work and open-air trading activities performed without authorization, in which many Greek Roma are involved; in 2017 the Government decided to abolish the very high fines and criminal penalties that were previously imposed against such persons and adjusted how the debts incurred by such fines can be repaid.

The report details well-documented cases of non-Roma workers committing fraud in order to access community mediation jobs requiring knowledge of the Romanes language. The Government had established that requirement to increase recruitment opportunities for Greek Roma to be hired by community centres and their Roma Departments. Some non-Roma candidates whose formal education achievements were superior to those of Roma candidates falsely declared they could speak the “Romani dialect” and were then recruited instead of the Roma candidates. The Government then introduced, by law, the “Process of Proof of Knowledge of the Greek Romani Language or Local Dialect” whereby a three-member special committee must test candidates’ Romanes language skills by means of a Skype interview and candidates who actually speak the language must be prioritized in the recruitment process.

As part of providing emergency housing assistance to Greek Roma living in inappropriate housing conditions, organized relocations have been planned that are reportedly being developed as complex types of social housing. The Special Secretariat has mapped Greek Roma settlements and categorized them as one of three types: Isolated encampments lacking basic facilities, mixed-type camps with informal structures on the outskirts of towns and villages, or neighborhoods with formal construction located in deteriorated urban areas. Municipal social housing is being developed that is intended to be used during a transition period between relocating from the settlements to eventually occupying regular housing.

Roma civil society recommends the Greek Government take advantage of the social economy and the skills of Greek Roma in the agricultural, artistic and commercial sectors to develop partnership initiatives between Greek Roma and non-Roma, not just so Greek Roma enter the formal labour market, but also so their integration can be accelerated by identifying non-Roma business partners to work with them to their mutual benefit. Other recommendations include researching municipally owned housing stock to assess how it can be used for social housing, researching the causes of school dropout nationwide, and cooperation between the Labour Force Employment Agency, municipalities and Greek Roma communities on empowerment programmes for Greek Roma youth who have dropped out, either so they resume their education or so they choose the most suitable training programme to complete.

From: https://cps.ceu.edu/article/2020-04-06/roma-civil-society-greece-can-leverage-roma-community-strengths-promote-inclusion?ct=t(EMAIL_CAMPAIGN_11_22_2019_12_36_COPY_01)&mc_cid=1619553d62&mc_eid=9b29de635f

Italy lacks knowledge about the Roma, Sinti and Caminanti people

March 16, 2020

The Roma Civil Monitor (RCM) report for Italy has found that there is no accurate data available at the national level about the number of Roma, Sinit and Caminanti (RSC) in the country. The Government approved its National Roma Integration Strategy (NRIS) after it was drafted by the National Office against Racial Discrimination (UNAR) in collaboration with civil society and RSC representatives. According to the RCM report, many problems persist with implementing the national strategy, problems that apparently require a radical change of direction if they are to be resolved. Many stereotypes about RSC people persist and continue to influence policy and its implementation locally and nationally.

The RCM reports are part of a project that began in 2017 and is funded by the European Commission for the purpose of strengthening the involvement of Roma civil society in the monitoring of integration strategies across the EU. The added value of civil society monitoring is that the coalitions of NGOs participating are in touch with Roma communities and represent independent voices.

From left to right onstage: Nazzareno Guarnieri (Fondazione Romani), Antonio Ciniero (Consorzio Nova) and Roberto Bortone (UNAR) discuss the analysis of the implementation of the National Roma Integration Strategy promoted by the first Roma Civil Monitor report at the Casa della Carità in Milan from 10-11 October 2019.

The report reviews the criminalizing approach that was taken toward RSC people when theItalian Government declared its “Nomad Emergency” in 2008, a state of affairs that persisted until 2011 when that policy was finally declared illegitimate. Criminalization of the RSC population is nothing new in Italy. While people speaking the Romanes language have been living on what is today Italian territory since the year 1400, despite that longevity and the fact that they are estimated to represent the country’s third-largest minority, RSC representatives have been deliberately excluded from legislative debates about them, including the one that eventually led to the adoption of a law recognizing “historical linguistic minorities” back in 1999. They are not officially recognized as a minority in Italy at all.

One member of the current coalition Government of Italy, the  “Lega” (League) party, is a re-named version of what was once the “Lega Nord” (Northern League), a party whose members have been convicted of inciting racial hatred who were instrumental in advocating for the “Nomad Emergency” policy to criminalize the RSC community. One Lega Nord candidate was convicted of incitement after saying in 2013 that he wanted to “eliminate all Gypsy children”, a case that was much-discussed nationally.

As far as the development of the NRIS is concerned, the civil society report finds that the formalistic involvement of RSC representatives during consultations on the strategy revealed that empowerment and participation remain problematic for the RSC in Italy. Two national level Working Groups are active, one that is working to bridge the information gap about the living conditions of RSC communities, and the other working on the legal situation of RSC community members who have been rendered stateless.

Few regions have undertaken initiatives aligned with the NRIS objectives on access to housing by RSC community members. Emilia Romagna Region has adopted a special law to finance the transition of RSC citizens living in camps to living in homes integrated into urban areas or what are called “micro-residential” areas. Tuscany’s approval in 2018 of a protocol for interventions aimed at resolving the existence of Roma camps and the inclusion of vulnerable persons living on that regional territory also appears to be aligned with the NRIS. The empowerment of the RSC community has been touched on by a project called “Housing First and Community Development: Community Welfare Project” for RSC families living in the city of Faenza(Emilia-Romagna Reiong) that was launched in 2015 by local social services in collaboration with the Fondazione Romanì NGO.

“Despite isolated progress in some regions, such as Emilia Romagna, many problems still persist with the NRIS implementation, and it appears they will be difficult to resolve without a radical change of direction,” says Donatella DeVito of Casa della Carità. “The limited powers the UNAR has to ensure the implementation of the NRIS at local level, together with poor capacity to coordinate actions among the different institutional levels, has negatively impacted thedevelopment of Local Action Plans for RSC inclusion. According to current legislation, at local level everything is left to the discretion of local institutions that have the powers to decide whether and how to adopt measures implementing the strategy. As a result of that, just 11 Regions out of 20 have set up the consultative meetings aimed at agreeing on how to implement the NRIS at local level, and only the Emilia Romagna Region has promoted and approved a regional law aimed at closing the Roma municipal camps and taking actions aimed at supporting RSC inclusion. Moreover, there are several regional and local authorities that not only are not implementing the NRIS but are even denying it exists and persisting in mono-ethnic residential areas and camps or even opening new ones. The delay in the implementation of the NRIS in the two regions where the RSC presence (and also their exclusion) is higher, such as Lazio and Lombardy, is particularly significant. In Lazio, the regional consultations did not start until 2015, while in Lombardy they have not even been organized yet.”

The civil society report recommends that Italy develop a monitoring and evaluation system for the NRIS and identify clear, measurable indicators for assessing the achievement of NRIS targets as well as any unanticipated effects, whether negative or positive, of the implementation of the strategy. It also recommends the Government build a local network of Working Groups including RSC community members through the UNAR to work on issues of discrimination. Last but not least, the report recommends investing in the promotion of RSC culture and focusing on long-term counter-narrative campaigns to combat antigypsyism, as has also been suggested by the Council of Europe.

From: https://cps.ceu.edu/article/2020-03-16/roma-civil-society-italy-lacks-knowledge-about-roma-sinti-and-caminanti-people?ct=t(EMAIL_CAMPAIGN_11_22_2019_12_36_COPY_01)&mc_cid=1619553d62&mc_eid=9b29de635f

Lithuania should keep progressing on Roma inclusion

The second Roma Civil Monitor (RCM) report on Lithuania has found that employment initiatives targeting Roma community integration into the labour market seem to have yielded positive change. Access to housing is a general problem in Lithuania, specifically with respect to the country’s biggest Roma settlement in the capital, Vilnius, where residents including young children are frequently subject to forced evictions during winter. While health indicators find that Roma access health care slightly less than others, including dental care, the difference in access is not significant. Better-designed measures are necessary to ensure Roma children access quality education in Lithuania.

The RCM reports are part of a research project that began in 2017 and is funded by the European Commission for the purpose of strengthening the involvement of Roma civil society in the monitoring of Roma integration strategies across the EU. The added value of civil society monitoring is that it builds on the direct experience of Roma women and men and represents their independent voices. The report was drafted through a consultation process including Roma associations, civil society members, and community members.

Photos from the “Exhibition on the Roma Genocide in Panevėžys, Lithuania” held in 2016, organized by the Panevėžys Children's Day Care Centre. (PHOTO: copyrights Daiva Tumasonytė and Vida Bernotienė)

"In 2019, after a long campaign by activists and civil society, the Government of Lithuania has added the 2nd of August - Roma Genocide Remembrance Day - to the national list of commemorative days,” says the director of the PI Roma Community Centre, Svetlana Novopolskaja. “This decision is a significant event for the entire Roma community in Lithuania. We hope that it will encourage the public to pay attention to the painful facts of our national history and will contribute to reconciliation between communities, to intercultural dialogue, and to the reduction of stereotypes."

The Roma Civil Monitor report has found that during 2004-2015, four EU-funded labour market access projects were implemented in Lithuania targeting Roma, one of which was administered by the Lithuanian office of the United Nations Development Programme. Local Roma NGOs involved in implementing the projects say that Roma women and youth were well-represented in them. A total of 351 Roma accessed the projects, of whom 73 became employed and some continued their education. Another project is currently ongoing. All of the projects have been aligned with the National Roma Integration Strategy (NRIS) guidelines and were implemented in close collaboration with authorities.

According to a 2015 study by the Centre of Ethnic Studies, more than half of the housing units inhabited by Roma in Lithuania are not equipped with indoor bathing facilities or toilets, compared to less than 20 per cent of majority-society households lacking such equipment. The study revealed that 29 per cent of Roma describe their health as “poor and very poor” compared to 23 per cent of the majority, with 50 per cent of Roma respondents reporting a chronic disease or long-term health problem compared to 37 per cent for the majority. Lastly, the study found that while 75 per cent of majority children attend preschool, just 25 per cent of Roma children attend preschool.

In 2011, the education of Roma children aged 10-19 differed from that of their non-Roma peers when it came to accessing secondary education, while illiteracy and failure to complete primary education differed between the two groups by anywhere between 1-5 per cent, an improvement over data for 2001, when the difference ranged from 11-36 per cent. Further improvement was recorded in 2015, when just 8 per cent of Roma schoolchildren were either illiterate or had failed to complete their primary education.

Civil society is recommending that there should be more synergy between education and employment initiatives with respect to Roma. The forced evictions to which some Roma communities have been subjected should be immediately stopped. Health-related education, especially for women and youth, should continue and expand. Lastly, the gap between non-Roma and Roma attending pre-school should be closed by increasing Roma attendance in preschool.

Related Project(s)

Roma Civil Monitor

From: https://cps.ceu.edu/article/2020-03-19/roma-civil-society-lithuania-should-keep-progressing-roma-inclusion?ct=t(EMAIL_CAMPAIGN_11_22_2019_12_36_COPY_01)&mc_cid=1619553d62&mc_eid=9b29de635f