Summaries of selected statements | 71 Since 2014, the conditions for this category of persons had changed in a number of respects. A significant change was that they were now required to reside at Kærshovedgård, which is in overall terms considerably more isolated than Sandholm. On the other hand, in the case of a not insignificant proportion of persons with tolerated residence status, the requirement that they reside at Kærshovedgård had been terminated by a court or by the Danish Immigration Service. In the Ombudsman’s opinion it could thus be noted that the hopelessness characterising the lives of persons with tolerated residence status had to a certain extent undergone a positive change compared to 2014. The Ombudsman maintained his view from the 2014 report that the overall conditions for the category of persons on which the visit focused were to be regarded as very stressful and as severely restricting even basic aspects of living. However, the general conditions for these persons did not contravene, for instance, the prohibition of degrading treatment under the UN Convention Against Torture and the European Convention on Human Rights. 2018-19. Practice of processing several requests for access to documents or information together In connection with his investigations of specific com­plaint cases concerning requests for access to documents or information under the Access to Public Administration Files Act, the Ombudsman became aware that, for resource reasons, some authorities had a practice of processing several requests for access to documents or information about the same subject together. The practice consisted in grouping a number of more or less identical requests for access to documents or information about the same subject received by the authority within a certain period of time and releasing the same material, based on the most broadly worded request, at the same time to all those requesting access. In two specific cases, the Ombudsman had criticised the authorities’ procedure on the grounds that it was clear that it had resulted in longer processing times – in one of the cases because the request, which was for one document only, had been processed together with some very comprehensive requests. These cases, among others, caused the Ombudsman to ask the Ministry of Justice for its opinion of the practice of processing several requests for access together. The Ministry stated to the Ombudsman that in its opinion it is legal for authorities to process several requests together. However, in an effort to save resources, an authority is not permitted, for instance, to exceed the time limits set out by the Access to Public Administration Files Act. In addition, the Ministry made some general comments on the organisation of the processing of requests which are grouped and processed together. Among other things, the Ministry pointed out that the processing must, to the greatest extent possible, be organised in a manner to ensure that the least comprehensive requests can be processed to conclusion as quickly as possible. In addition, decisions on subsets of the total material should be made on an ongoing basis if possible. In essence, the Ombudsman concurred with the Ministry’s views, and he concluded the case with reference to the Ministry having stated that it intended to inform the other ministries of its views on the organisation of the processing of requests which are grouped and processed together and to publish this information on the Public Access Portal (www.offentlighedsportalen.dk), an Internet portal set up by the Ministry which contains information about access to public records.

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