Report of the HRD on the activities of the National Preventive Mechanism in Poland in 2011 connected with execution of the Budget Act6). In the draft budget for 2012, the amount of PLN 1,872,000 was earmarked for the implementation of tasks under measure Performing the function of the national preventive mechanism. When this report was drafted, the Polish Parliament was still working on the Budget Act. The financing of the National Preventive Mechanism has an impact, first of all, on the number of visits carried out. According to APT’s position, comprehensive visits should not be too frequent. In the opinion of APT representatives, it is more effective to focus on one aspect of detention at a time, increasing at the same time the number of visits to places of detention. In addition, according to the UN Special Rapporteur on torture, ad hoc preventive visits under the NPM should be carried out once in several months, and comprehensive visits once in five years. According to minimum standards defined by the APT, comprehensive visits to organisational units of the Police, pre-trial detention centres and to places of detention of people particularly vulnerable to threats or aggression, such as women and foreigners, should be carried out at least once a year. Focussing the NPM activity on more frequent and shorter ad hoc visits is more effective from the point of view of human rights protection as the visited entities will pay more attention to their observance. With the current number of National Preventive Mechanism Department staff (7 persons) and the number of places of detention (1,826), the Human Rights Defender is unable to guarantee that the above minimum standards of visit frequency would be adhered to. To be able to do that, the Department should employ 38 people.7 3. Cooperation with NGOs In 2011, two meetings were held between the Human Rights Defender and members of the National Preventive Mechanism Department and the representatives of the Coalition for the implementation of the OPCAT8 (hereinafter: “Coalition”). The meeting on 14 March 2011 was devoted to evaluating the Human Rights Defender’s activity in the capacity of the National Preventive Mechanism9 in Poland in 2009. Members of the Coalition presented to the Defender and to NPM members their evaluation of the organisation of the Mechanism and their opinion on the 2009 annual NPM report. The Human Rights Defender informed representatives of the Coalition about the difficulties relating to amending the Act on the Human Rights Defender, whose purpose is to regulate the functioning of the National Preventive Mechanism in Polish law, and about the NPM’s financial standing. Changes made in the organisation and functioning of the NPM were discussed. The problem of insufficient staffing of the NPM Department was raised, as well as the problem of  Dz. U. of 2011, No 291, item 1707.  The number results from a calculation done by NPM representatives on the basis of APT standards.  The Coalition is an initiative group composed of representatives of the academia and NGOs acting for human rights and their protection. 9  Hereinafter referred to as “NPM” or “Mechanism.” 6 7 8 14