• Role only Some investigative bodies have opted to describe the role of the alleged perpetrator, but without revealing their name. For example, a CoI might report publicly that “the head of X militia” or “the president of Y political party” is deemed responsible for certain crimes or violations.151 In these cases, interested parties such as the media or civil society may be able to fill in the blanks. This approach carries with it many of the due process and security risks that attach to public revelation, and in many cases is tantamount thereto. • Institutional affiliation only A second, more suitable practice is where the investigative body sets out in the report its conclusions as to specific units/institutions responsible for violations and crimes, but without naming any individual. Elsewhere, the report includes factual findings concerning the individuals who held leadership positions in that unit/institution at the relevant point in time.152 This approach, while being less problematic in human rights terms, allows the identification of the State or party responsible, and of the particular structure within that State/party, while separately it identifies an individual or individuals who may or may not be responsible depending on their conduct within the institution.153 To be clear: there is no direct allegation of individual responsibility in the report,154 and hence there is also no responsibility to afford a right of reply to the individual(s) in question. Guidance for public revelation • If publicly releasing conclusions on the responsibility of individuals, - the “reasonable grounds” threshold must clearly be met,155 and - individuals must have been afforded the possibility to provide their version of the events; For example, see Libya Report (A/HRC/19/68), para. 188, with respect to Revolutionary Guard leadership, or para. 566, with respect to the leadership of the Popular Guard; in both instances the CoI replaced the name with a number. 152 See for example the OHCHR Sri Lanka (OISL) Full Report (A/HRC/30/CRP.2), paras. 104-170, detailing the organizational structures with the names of the leadership. Then see paras. 262, 274, 306 and 346 where the entity, in this case the military intelligence, is implicated in violations and crimes. 153 The size of a given unit within a military structure can vary widely, and CoIs can choose to be as specific as their information allows in making the identification, for example by going further into sub-units. 154 Further investigation would be required to “connect the dots” in terms of responsibility, as the individual might not have had “effective control” over the elements who committed the violations, or may have unsuccessfully tried everything in his or her power to suppress the violations. 155 As noted, this standard is a minimum: the investigative body might consider setting a higher threshold for public revelation. 151 HOW TO GET THE MOST FROM THE INFORMATION 89