CCPR/C/118/D/2608/2015 indicated that the risk must be personal and that there is a high threshold for providing substantial grounds to establish that a real risk of irreparable harm exists. 19 4.3 The State party observes that in their communication, the authors did not provide any essential new information regarding their circumstances beyond the information already relied upon in connection with their asylum proceedings and that the Refugee Appeals Board considered those circumstances in its decision of 9 July 2015. The Board considered it a fact that the authors had been granted refugee status in Bulgaria and found that they fell within section 29b of the Aliens Act. The State party further submits that the Board requires as an absolute minimum that the asylum seeker or refugee is protected against refoulement. It also must be possible for him/her to enter lawfully and to take up lawful residence in the country of first asylum, and his/her personal integrity and safety must be protected. That concept of protection also includes a certain social and economic element, since asylum seekers must be treated in accordance with basic human standards. However, it cannot be required that the relevant asylum seekers will have exactly the same social living standards as the country’s own nationals. The core of the protection concept is that the persons must enjoy personal safety, both when they enter and when they stay in the country of first asylum. Moreover, the State party notes that Bulgaria is bound by the European Convention on Human Rights. 4.4 Furthermore, the State party submits that the Refugee Appeals Board took into account the authors’ written statements about their stay and living conditions in Bulgaria, as well as the background material available in that regard. The State party maintains that the Committee cannot be an appellate body, which reassesses the factual circumstances advocated by the authors in their asylum application before the Danish authorities and it must give considerable weight to the findings of fact made by the Board, which is better placed to assess the factual circumstances of the authors’ case. The State party further makes reference to the Committee’s jurisprudence, according to which it is generally for the organs of States parties to examine the facts and evidence of a case, unless it can be established that such an assessment was arbitrary or amounted to a manifest error or denial of justice.20 4.5 The State party notes that on 25 June 2014, the Bulgarian authorities published a new integration programme, scheduled to be implemented as of 2015, which would cover a larger number of persons, including language training for a greater number of beneficiaries than the preceding programme.21 It submits that the circumstance that the authors may not have access to such a programme cannot independently lead to a different assessment of Bulgaria as their first country of asylum. The State party further states that, according to background material submitted by the authors, refugees acquire the same rights as Bulgarian nationals, except the right to participate in elections and to hold certain positions which require Bulgarian nationality and that although the reception system in Bulgaria has proved incapable of processing the large number of asylum applications submitted since 2013, it appears that conditions in reception centres have improved.22 The State party cites a Human Rights Watch report of 2013, in which it is stated that all centres have heat, the 19 20 21 22 The State party refers to communication No. 2007/2010, X v. Denmark, Views adopted on 26 March 2014, para. 9.2. The State party refers to communications No. 2426/2014, N. v. Denmark, decision of inadmissibility adopted on 23 July 2015, para. 6.6; No. 2272/2013, P.T v. Denmark, Views adopted on 1 April 2015, para. 7.3; No. 2393/2014, K v. Denmark, Views adopted on 16 July 2015, paras. 7.4 and 7.5; No. 2186/2012, X and X v. Denmark, Views adopted on 22 October 2014, para. 7.5; and No. 2329/2014, Z v. Denmark, Views adopted on 15 July 2015, para. 7.4. The State party refers to “Trapped in Europe’s quagmire”, pp. 24 and 25. The State party refers to “Containment plan: Bulgaria’s pushbacks and detention of Syrian and other asylum seekers and migrants”, pp. 2 and 72. 7