Section two The third year – an overview Article 19(c) Developing coordination • the Scottish Human Rights Commission (SHRC) responded to a government consultation on the detention and questioning of suspects in police custody and their right to legal assistance • SHRC and HM Chief Inspector of Prisons for Scotland each gave evidence to a Commission on Women Offenders established by the Scottish government to explore ways to improve outcomes for women in the criminal justice system • the Children’s Commissioner for England and HMIP each submitted evidence to an inquiry by the Justice Select Committee into the youth justice system • HMIP responded to a European Union green paper on detention, and supported the responses of both the French and Spanish NPMs. To address some of these challenges, the members agreed to establish a steering group. The role of the steering group is to facilitate decision making, set the strategic direction for coordinated or joint work, monitor the outcome and value of such work, and support HMIP and the NPM coordinator in their roles. The steering group is made up of five members, including HMIP (as the coordinating body) and one member from each of the four nations. It began its work in January 2011 and meets three times a year. In addition to regular visits to places of detention, OPCAT requires NPMs to have the power ‘to submit proposals and observations concerning existing or draft legislation’. Article 19(c) is interpreted as envisaging a more strategic role for NPMs under which they may seek to improve the treatment of and conditions for detainees at a national level. The members of the UK NPM carry out this role on both an individual and collective basis. Individual members often comment on policy proposals or draft legislation. In 2011–12, this included: The NPM members have also commented on policy and legislation on a collective basis. For example, the NPM responded to Scottish government proposals to reform policing, successfully calling on the government to use this reform as an opportunity to strengthen custody visiting arrangements. Although HMIP was appointed as the coordinating body, it is not ‘in charge’ of the NPM: it does not take decisions on behalf of the members without first consulting with them and securing consensus. Coordinating such a large and disparate group of organisations can be challenging and securing agreement on particular issues can be difficult, particularly when decisions are needed quickly. These challenges are only likely to increase as the government considers expanding the NPM membership. The creation of a steering group has been a positive step in developing the coordination of the NPM, and has led to the NPM having, for the first time, a business plan for its coordinated activities for 2012–13.5 Its purpose is to maximise efforts to prevent ill-treatment in all places of detention by providing effective coordination of the NPM. The plan features three key objectives, against which progress will be monitored by the steering group: • to support the NPM members and promote collaboration between them and the sharing of information and good practice. 5 The business plan is available from the NPM coordinator. 13