PART I.  SETTING THE BOUNDARIES FOR THE USE OF FORCE IN LAW ENFORCEMENT opponents” by politicians, State authorities and State-owned media.96 Women defenders and human rights defenders working on LGBTI-related issues often find themselves particularly at risk, due to their work on issues that challenge established customs and norms, which are culturally and politically sensitive.97 Even when human rights defenders voice criticism of State laws, policies and practices, the enjoyment of their human rights must be guaranteed. Law enforcement officials should strive for a good relationship with human rights defenders, as this may provide them with useful information and channels of communication with the communities they serve. It will also provide them with suggestions on how to improve their efforts towards human rights compliant law enforcement, particularly regarding the use of force.98 Journalists and other media workers The right to freedom of expression and the right to seek, receive and impart information are contained in both the Universal Declaration of Human Rights and the ICCPR.99 Journalists and other media workers, including citizen journalists, bloggers and community media workers play an important role in holding law enforcement agencies to account, and the Special Rapporteur on the situation of human rights defenders has argued that many journalists and other media workers are in fact human rights defenders.100 In his report on “the safety of journalists and the issue of impunity”,101 the Secretary-General of the United Nations emphasized the important role of journalists and media workers as follows: “Independent and critical journalism is vital in any democratic society. It drives the right to hold and express opinions and the right to seek, impart and receive information and ideas, as defined in article 19 of the Universal Declaration of Human Rights and of the International Covenant on Civil and Political Rights. It contributes to ensuring transparency and accountability in the conduct of public affairs and other matters of public interest, and it enables individuals to participate fully, actively and meaningfully in all aspects of society.” Journalism has been defined as “a function shared by a wide range of actors, including professional full-time reporters and analysts, as well as bloggers and others who engage in forms of self-publication in print, on the Internet or elsewhere.”102 A broad understanding of who constitutes a journalist or media worker is important to ensure adequate protection of those who are investigating and reporting on human rights issues and therefore should include those formally recognized as journalists, as well as, for example, community media workers, bloggers, citizen journalists, and those monitoring assemblies and protests.103 In this regard, the United Nations High Commissioner for Human Rights pointed out that all individuals are entitled to the full 96  See Report of the Special Rapporteur on the situation of human rights defenders. A/HRC/13/22, 30 December 2009, para. 27. 97  Ibid., paras. 47-49. 98  For a list of good practices for engagement and protection of human rights defenders, see OHCHR, Human Rights and Law Enforcement, A Manual on Human Rights Training for Law Enforcement Officials, 2017, p. 210. 99  See UDHR, article 19 ; ICCPR, article 19. 100   See Report of the Special Rapporteur on the situation of human rights defenders. A/HRC/19/55, 21 December 2011. 101  See A/69/268, para. 3. 102  Human Rights Committee, General Comment No 34, United Nations doc. CCPR/C/GC/34, para. 44. See also A/HRC/20/17, paras. 4-5, and A/HRC/20/22, para. 26. 103  See Report of the Special Rapporteur on the situation of human rights defenders. A/HRC/19/55, 21 December 2011, paras. 33-34; Report of the Special Rapporteur on extrajudicial, summary or arbitrary executions, A/HRC/20/22, 10 April 2012, paras. 36 and 122; Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression, A/HRC/20/17, para. 54. 37