subjected to torture”.152 Cases fulfilling the “substantial grounds” requirement must contain a foreseeable, real and individualized risk of torture that goes “beyond mere theory of suspicion” or “a possibility of torture”, although the risk posed to the individual does not have to be “highly probable”.153 The danger has to be “personal and present”, and the authorities must also assess the particular situation of the victim and not only the general context of the risk of torture in the state where the victim is to be returned to.154 If the victim’s individual circumstances show that he or she may be at risk of being tortured, the UNCAT provision of protection from refoulement applies regardless of whether a consistent pattern of torture or other mass human rights violations have emerged.155 Under the ECHR, a trafficked person would need to demonstrate that there are substantial grounds to believe that, if expelled, the person would face a real risk of treatment contrary to Article 3 of the ECHR in the receiving country to which he or she is being sent. The principle of non-refoulement can, therefore, offer victims an additional protection option.156 Long-term residence options Many OSCE participating States provide long-term residence permits to persons who qualify for refugee status or subsidiary protection. In principle, such permits are available to trafficked persons who meet the criteria of being a refugee or a person “in need of international protection”. In some countries, “complementary protection” is also provided on the basis of international obligations concerning family unity, health, children and other human rights concerns.157 In many countries, general clauses also allow protection to be granted in the exercise of executive discretion on “humanitarian grounds” or “compassionate grounds”.158 Other obstacles to return, including legal, technical or practical reasons that make return impossible, may also serve as a basis for granting a temporary residence permit.159 The EU Group of Experts has recommended that victims of trafficking be made eligible for a residence permit in certain circumstances, regardless of their level of co-operation with the national authorities. The Group has set out criteria according to which residence permits should be granted on humanitarian grounds, as follows: 152  UNCAT, art. 3. 153  Trafficking in Human Beings Amounting to Torture and other Forms of Ill-treatment (Vienna: OSCE, 2013), p. 30. 154  Ibid. 155  Ibid. 156  Ibid., p. 39. 157  European Council on Refugees and Exiles, Complementary Protection in Europe, 29 July 2009, p. 5. 158  Ibid., p. 7. 159  See, for example, Mathilde Heegaard Bausager, Johanne Köpfli Møller and Solon Ardittis, “Study on the situation of third-country nationals pending return/removal in the EU Member States and the Schengen Associated Countries”, European Commission, March 2013, HOME/2010/RFXX/PR/1001. Part 2: Explanatory Report to the Principles 59