Another omission found is that medical exams and prescriptions are recorded in the medical exams register not by the doctors who performed the exams but by the police officers and the medical specialists do not sign off in the register. There are many RPD where the inspections register exists for a couple of years but no data on any inspection is recorded therein. The NPM believes this fact is an indication of lack of control over the keeping of the registers and the reporting procedures. The conclusions made indicate yet another problem of no less importance – the police staff engaged with this activity on a daily basis is not sufficiently trained for the proper keeping of the documentation. The NPM believes that new methodology should be adopted in order to simplify the established documentation reporting regime as a whole. The NPM team also inspected the registers for citizen's complaints against police officers, containing data regarding police violence or lack of action by the police officers at the RPDs. Differences in the procedure adopted with respect to the checks related to such complaints were found in this respect as well. For example, each complaint against an officer from DPD of MI Varna is sent to the Regional Prosecutor's Office Varna because of its competencies for investigation of such cases. In other locations complaints are reviewed by the superior administrative authority, which in the opinion of the NPM does not guarantee impartiality in the decision making process. 2. Detention facilities within the structure of the Central Directorate "Border Police“ In 2013 the NPM extended the scope of the inspected sites within the MI system. The NPM carried out inspections in the 24-hour detention facilities in 12 structural divisions (units) of the Central Directorate "Border Police“ – 2 Regional Directorate "Border Police“ (RDBP), 7 Border Police Departments (BPD) and 3 Border Control Check Points (BCCP). Living conditions The major negative assessment of the NPM is related to the unsatisfactory living conditions in the detention facilities. The inspected locations (partially with the exception of BPD Gyueshevo and BCCP Kapitan Andreevo) do not meet the regulatory requirements for sufficient number of premises and equipment available, as set out in Instruction No ІЗ1711 of 15 September 2009 regarding the equipment of the premises for accommodation of detained persons within the structures of the Ministry of Interior and the order therein. The situation at BPD Elhovo is particularly concerning. There, in addition to the 24-hour detention premises, individuals are detained in one big premise (hall), split by means of wire netting and chip board, without heating, where the conditions may be summarised as miserable. Some of the visited locations do not have premises to accommodate minor and under aged individuals (BPD Blagoevgrad, BPD Krumovgrad, BPD Kalotina). Another negative finding is related to the lack of or insufficient natural light in the detention premises in RDBP Kyustendil (administrative building), BPD Krumovgrad and 40

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