CAT/OP/ROU/1 23. The Subcommittee recommends that the national preventive mechanism focus not only on visiting places of deprivation of liberty but also on other preventive activities. It also recommends that the mechanism develop an annual plan of work that includes all preventive activities, such as commenting on draft legislation, awareness-raising and training activities. 24. The Subcommittee observed a lack of visibility of the national preventive mechanism among the authorities, persons deprived of their liberty and representatives of civil society organizations, which may have a detrimental effect on its efficiency and effectiveness. In the majority of places of deprivation of liberty neither the administration nor persons held were aware of the mechanism’s existence and visits. Moreover, the Subcommittee considers that some officials in places of detention are not familiar with the mechanism’s recommendations, while others do not receive feedback even after their institutions are visited by the mechanism. The Subcommittee is particularly concerned that the mechanism cannot guarantee protection from reprisals for those with whom it meets. 25. The Subcommittee recommends that the State party increase the visibility of the national preventive mechanism, including through activities that raise awareness of the Optional Protocol and of the mandate of the mechanism. The mechanism’s recommendations should be prominently discussed and addressed. To this end, the Subcommittee recommends that the national preventive mechanism enhance its advocacy with institutions where persons are deprived of their liberty, with relevant ministries and with legislators. The Subcommittee also recommends that the State party support such exchanges. Moreover, the national preventive mechanism should engage in legislative processes and advocacy, which such mechanisms are encouraged to undertake under article 19 of the Optional Protocol and which increase the overall visibility of the mechanism. 26. The Subcommittee also recommends preparing further materials on the national preventive mechanism’s mandate and activities and distributing them to personnel and detainees in the places of deprivation of liberty and to civil society at large. 27. The Subcommittee recommends that the State party build the capacity of newly appointed staff members of the national preventive mechanism and intensify training of all participants in the work of the mechanism. It also recommends that the mechanism continue to develop its capacity by increasing its cooperation with the Subcommittee and by engaging with other national preventive mechanisms and appropriate national preventive mechanism networks. V. Overarching issues A. Normative, institutional and policy framework 28. The Subcommittee welcomes the comprehensive legal framework in the area of torture prevention, which is, to a large extent, adequate, and congratulates Romania for the numerous legislative reforms undertaken. The definition of torture in domestic legislation, 7 the existing legal safeguards against torture and ill-treatment and the legal protection of the rights of persons deprived of their liberty generally correspond with international standards. However, the Subcommittee is seriously concerned about the gap that was often observed between the legal framework and its application in practice, as some legal protections did not appear to be implemented consistently. 29. The delegation noted that a considerable number of persons deprived of their liberty suffered from a lack of information on the charges brought against them or the status of their case, even though all detainees interviewed were represented by legal-aid lawyers. While information on the detainees’ rights was usually available in detention facilities, it was generally limited to a compilation of laws, which most people did not understand and 7 6 Penal Code, art. 282.