viewed as such. The Norwegian Bureau for the Investigation of Police Affairs (NBIPA) has powers to establish cases on its own initiative and is both an investigative and prosecuting unit. The Garda Síochána Ombudsman Commission in Ireland has all the powers, immunities and privileges conferred on, and all the duties imposed on, any member of the police. The Commission investigates independently and makes recommendations as regards punishments and sanctions. In criminal cases it makes recommendations to the Director of Public Prosecutions but does not bring criminal cases in its own right. The Police Ombudsman of Northern Ireland (PONI) supported by the Policing Board and Policing and Community Safety Partnerships, is regarded as the ‘gold standard’ of police oversight which, ‘exemplifies a model of regulatory independence’ 26. It has responsibility for the investigation of all complaints against the police, minor or serious, although it has recently piloted a scheme whereby minor matters are referred back to the police for investigation under PONI supervision. 3.2 Good practice The comprehensive review of existing approaches to oversight across the forty-seven states has revealed the challenges that exist in developing a generic and consistent approach to the topic. However, it has become clear that where good practice exists (PONI, GSOC, NBIPA), it is underpinned by an adherence to the promotion of an effective and accountable police complaints investigation. Smith (2010) maintains that these investigations that are conducted in public forums are characterised by the following principles (also referred to as the five ECHR principles)27: Independence, where the subject of a complaint is not investigated by a colleague or the respective organisation; Adequacy, which relates to the importance of conducting a thorough and comprehensive investigation of a complaint; Promptness, in the commencement of an investigation; Public scrutiny, through, where appropriate, transparent and open investigations, and Victim involvement, which equates to the idea that the complainant should be involved in the 26 Porter, L.E., and Prenzler, T. (2012) Police oversight in the United Kingdom: The balance of independence and collaboration. International Journal of Law, Crime and Justice 40(3)152-171 27 Smith, Graham (2010) Every Complaint matters: Human Rights Commissioner’s opinion concerning independence and effective determination of complaints against the police, International Journal of Law, Crime and Justice 38 (2010) 59-74. Smith also references the five ECHR principles from the Commissioner’s Expert Workshop in Strasbourg in May 2008. 70