The detention facility needs reconstruction of the windows and overhaul to ensure normal daylight. Due to the existing overcrowdedness in the two detention facilities such an overhaul cannot be conducted without using the territory of Sofia Prison, which will result in further overcrowdedness of Sofia Prison. As regards the correspondence of detainees, GDEP issued Order No. Л-2037 of 28 November 2018, setting out the procedure for filing applications and complaints. It expressly states that answers to the letters submitted to the administration will be given against signature. Despite the existing rules for document turnover, record keeping and archiving activities, the Ministry of Justice requires control over the incoming and outgoing correspondence “in the interest of security, in order to prevent commitment of crimes”. The content of item 3 of the order precludes the submission of an application or complaint in a sealed envelope. If the detainees want to know the incoming number, they must file a separate request. Sealed letters in the form of correspondence are allowed under item 6. While the outgoing correspondence is sealed before an official, there is no requirement in item 7 for the received correspondence to be opened before an official. The secrecy of correspondence is violated in view of the effective regulatory framework and the above-mentioned order. GDEP Order No. Л-2036 of 28 November 2018 issued pursuant to item 59 of GDEP Order No. Л-4102/06.10.2016 regulates telephone conversations of detainees. In accordance with this order, telephone conversations are made during their stay in the outdoor area. At the same time, the outdoor area is not equipped with telephone sets and a detainee has to choose whether to use the outdoor area or a telephone. During a telephone conversation an official compares the dialled number against the number stated by the detainee and must stay at a distance of 5-6 m from the detainee during the conversation. Item 8, however, states that “the nature and content of telephone conversations of detainees may not put at risk or violate the security and order in the detention facility”. Item 9 provides for interruption of a telephone conversation if the procedure for making it is violated. GDEP Order No. Л-1969 of 15 November 2018 regulates visitations with lawyers, attorneys and non-marital partners. In the view of NPM, this order infringes the rights of the lawyers as it does not stipulate the right to visitation at any time. The procedure for delivery of written materials in case of barred visitations is not regulated. Two doctors, a dental practitioner and two nurses take care of the detainees at the detention facilities on G.M. Dimitrov Blvd. and on Major Vekilski Str. At least once a month medical specialists make on-site visits: a neurologist, a cardiologist and a dermatologist. For consultation/treatment by other medical specialists, detainees are brought out from the detention facility based on a referral by a detention facility doctor after authorisation from the prosecutor’s office, which does not always respond on a timely basis. Consultations/treatment in external medical institutions at the request of lawyers to the prosecutor’s office are increasing in frequency. Such detainees usually do not report having health problems or do not submit medical documents at the initial medical examination in the detention facilities. Their lawyers refer directly to the prosecutor’s office, stating concrete medical institutions, which is defined by the NPM as poor practice. The inspection of access to medical care in the detention facilities showed that there is a schedule of making examinations of detainees. In 2019, no cases of difficult access to external medical institutions during consultations/treatment of detainees were reported to the NPM. There are single cases of difficulties with the provision of specialised medical assistance due to delayed authorisation of the prosecutor’s office or inability to provide escort. The inspection of documents on the health status of a detainee from reception till leaving the detention facility shows that all the information had been duly recorded in the required medical records. The NPM considers that a uniform information system of electronic health 24