facsimile or digital signature should be made on the basis of a legal framework which explicitly
regulates this fact, at law88.
And the "Center for the Rights of Persons with Disabilities" PA addressed another issue faced
by visually impaired people. This problem is related to the impossibility of using the card
independently at the bank's ATMs, including the possibility to know the information on the card
account, to withdraw cash or to perform other operations offered by ATMs.
Existing good practices in several countries (such as Germany, Belgium, Belarus, the Russian
Federation) show that ATMs have easy-to-find openings for touching, both for card insertion and
for issuing banknotes, as well as larger screens for the visually impaired and have headphones
attached through which the blind can listen to voice commands and implicitly follow them.
Therefore, the People's Advocate recommended to the Governor of the National Bank of
Moldova and the Ministry of Health, Labour and Social Protection the creation of a working group
to examine the opportunity to amend and supplement the legislation in force to regulate the
procedure for applying the special signature (facsimile) by persons with severe visual impairments,
including on documents and bank documents provided by financial institutions. He also proposed
the initiation of the procedure for regulating the obligation to adapt or gradually adapt ATMs to the
needs of visually impaired people.
At the same time, the People's Advocate recommended that in the process of initiating the
procedure for improving the normative framework, the persons with disabilities and / or nongovernmental organizations that ensure the protection and promotion of the rights of persons with
disabilities, must be consulted.
In response, the National Bank of Moldova reported that "the Council for Preventing and
Eliminating Discrimination and Ensuring Equality is responsible for detecting and sanctioning acts
that are classified as discriminatory"89. The Ministry of Health, Labour and Social Protection
mentioned that the National Bank of Moldova is the authority responsible for regulating and
controlling the activity of financial institutions and respectively will solve the invoked problem.90
The People's Advocate was informed by a group of beneficiaries of the psycho-neurological
boarding school from Branzeni village, Edinet district, about the violation of the right to medical
assistance, due to the lack of identity documents.
88
Letter of the NBM of 04.12.2018, no.09-03113154 / H25H;
NBM letter no. 26-01109 / 576/2039 of 27.06.2019;
90
MHLSP letter no. 13/2846 of 14.05.2019;
89
52
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