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http://dx.doi.org/10.14400/JDC.2021.19.12.469

International Comparison of Anti-Discrimination Laws on Disability  

Ju, Youngha (Joongbu University)
Publication Information
Journal of Digital Convergence / v.19, no.12, 2021 , pp. 469-475 More about this Journal
Abstract
The purpose of this study was to compare the elements of anti-discrimination laws on disability in major OECD countries. This study used the analysis framework for the elements of the anti-discrimination law on disability presented in the national report of Chopin et al.,(2018). In addition, It was analyzed including the Anti-Discrimination Act on Disability, the General Anti-Discrimination Act including Disability, the Equality Act in the UK, and the Human Rights Act in Canada. The research results were as follows. In Austria, Belgium, France and Sweden, it were found that the countrys satisfied all of the provisions of the Act on 'Direct discrimination', 'Indirect discrimination', 'Harassment', 'Legal standing to act on behalf of victims', 'Legal standing to act in support of victims' and 'Prohibition of victimisation'. In particular, in Korea, 'Legal standing to act on behalf of victims' and 'Legal standing to act in support of victims' were not included. However, it was a country that satisfied the provisions of the Act on 'Direct discrimination', 'Indirect discrimination', 'Harassment' and 'Prohibition of victimisation'. Finally, this study suggested legal and institutional supplementation.
Keywords
Anti-Discrimination Act on Disability; International Comparative Study; OECD Major Countries;
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