an increase of around 60 FTE in comparison with 2015. In the opinion of the National Mechanism for the Prevention of Torture which appreciates the efforts taken by the Central Headquarters of the Prison Service, the indicated increase does not translate into a smaller number of prisoners per one psychologist. It merely constitutes a necessary addition to the composition of that professional group to the level at which that standard can be met. In another letter 23 the Director General of the Prison Service informed about notyfying the Ministry of Justice of the necessity to allocate at least additional 205 full-time equivalents for psychologists in case Article 164a of the Executive Penal Code is amended24. The NMPT believes that the increase in staffing level will only mitigate the growing workload of psychologists resulting from additional obligations but will not translate, in real terms, into a decreased number of prisoners per one psychologist. ASSESSMENT OF LEGISLATIVE ACTS Assessment of legislative acts, both those in force and those at the drafting stage, is a form of preventing torture and other cruel, inhuman or degrading treatment or punishment. The national preventive mechanisms’ power to submit proposals and observations concerning existing or draft legislation to relevant authorities is provided for in Article 19(c) of the OPCAT. On 15 April 2019 the Commissioner for Human Rights presented his reservations to the draft act on juveniles comprising proposed changes on the operation of detention establishments for minors, including youth care centres25. In the opinion of the Commissioner youth care centres should not perform personal searches due to invasive nature of that measure and the risk of humiliation, which has a negative impact on educational objectives26. The Commissioner also pointed out to the following: • the need to exercise judicial supervision over the restriction of contacts of a ward (the court should obligatorily be notified of the restriction or prohibition of contacts and censorship or interception of correspondence)27 and the inspection of parcels (minors should have the right to lodge a complaint in that regard)28, • the need for the act to specify places covered by monitoring (in the opinion of the Commissioner, in case of youth care centres bedrooms as well as sanitary facilities should not be monitored due to the specificity of that establishment and the purpose of its operation)29, 23 24 25 26 27 28 29 Letter of the Director General of the Prison Service of 14 May 2019, no. BP-P-1155-2019/22641. The amendment would impose an obligation on prison service personnel to conduct a risk assessment concerning the likelihood of committing a crime with a use of violence by perpetrators of „aggressive crimes” once they are released from the penitentiary establishment. Cf. Draft act on minors of 8 March 2019 entered to the register of legislative and program projects under no. UD 480; Letter of the Commissioner for Human Rights to the Minister of Justiceof 15 April 2019, ref. O22.1.2019. RK. Documents are available on the website https://www.rpo.gov.pl/content/opiniowanie-akt%C3%B3w-prawnych. Ibid, item 37. Ibid, item 32-33. Ibid, item 36. Ibid, item 42. Report of the Commissioner for Human Rights on the activities of the National Mechanism for the Prevention of Torture in Poland in 2019 23