II. Legal Framework Council of Europe The Council of Europe is made up of 47 Member States. Twenty-eight of these countries are also part of the European Union.8 The Council consists of two organ bodies: the Parliamentary Assembly and the Committee of Ministers. The Parliamentary Assembly represents the political forces in its member states, has ten committees, and can adopt three different types of texts: recommendations, resolutions, and opinions.9 The Committee of Ministers is the decision-making body and is both a governmental body, where national approaches to problems facing European society can be discussed on an equal footing, and a collective forum, where Europe-wide responses to such challenges are formulated. In collaboration with the Parliamentary Assembly, it is the guardian of the Council's fundamental values, and monitors member states' compliance with their undertakings.10 Some of the Committee of Ministers duties include: monitoring respect of commitments by member states, adopting recommendations to member states, and supervising the execution of judgments of the European Court of Human Rights.11 The CoE’s standards for non-nationals are based on the CoE’s Convention for the Protection of Human Rights and Fundamental Freedoms.12 The scope of the ECHR extends to 8 Strasbourg l’européenne Centre d’Information sur les Institutions Européennes, http://en.strasbourgeurope.eu/member-states,44987,en.html (last visited Dec. 5, 2016). 9 Who We Are, COUNCIL OF EUROPE, http://www.coe.int/en/web/about-us/who-we-are (last visited Dec. 5, 2016); See also, Sophia Lobey, History, Role, and Activities of the Council of Europe: Facts, Figures and Information Sources, http://www.nyulawglobal.org/globalex/Council_of_Europe.html (last visited Dec. 5, 2016). 10 Lobey, supra note 9. 11 Id. 12 Yannis Ktistakis, Protecting Migrants under the European Convention on Human Rights and the European Social Charter: A Handbook for Legal Practitioners, COUNCIL OF EUROPE (2013), accessible at http://www.coe.int/t/dgi/hr-natimplement/Source/documentation/hb_ProtectingMigrantsWeb_%20A5.pdf 4