encountered obstacles over the years in terms of access to a particular category of personal data. Noncompliance with the obligations set out in the Optional Protocol has been addressed several times by the UN Subcommittee on Prevention of Torture (SPT) in written communication with the Government of Georgia. The subcommittee emphasizes the need for the National Preventive Mechanism to have unimpeded access to all relevant data, including medical records, registers and other records. Despite the recommendation of the Public Defender the employees of penitentiary establishments were not trained on the mandate and authority of the National Preventive Mechanism. Establishing a constructive and trust-based, positive relationship between staff and prisoners is essential to maintaining order and security in the establishments32. In 2020, penitentiary establishments did not train security and legal regime staff on issues such as conflict prevention, mediation, and the ethics of penitentiary staff. The Ministry of Justice sent a reply to the Parliament stating that in 2020-2021 the process of retraining the staff of the Penitentiary Service on the principles of conflict prevention, mediation and ethics was delayed due to the epidemiological situation caused by the new coronavirus (COVID 19) in the country. The Ministry of Justice has not implemented the Public Defender’s recommendation requesting that the plan to tackle the problem of overcrowding in penitentiary establishments should increase the number of regime staff working in the wards of residential buildings so that at least one staff member responsible for maintaining order and security is assigned to 15 inmates. The Ministry of Justice sent a reply to the Parliament stating that as of March 1, 2020, the number of employees of the Legal Regime Department in penitentiary institutions had increased by 34, which is welcome, but not enough to substantially change the situation. The Public Defender hopes that the process of hiring new employees will continue actively. Despite the recommendation issued by the Public Defender, the accused and the convicts are still placed together in the N2 and N8 institutions, which is also a frequent cause of conflicts. Consequently, international standards33 and the requirements of the Imprisonment Code34 are being violated. During the reporting period, the implementation of the recommendation regarding taking into consideration the family's place of residence during the placement of the prisoner could not be assessed. The National Preventive Mechanism will pay particular attention to the implementation of this recommendation during subsequent monitoring visits. The Public Defender has been urging the Minister of Justice for years to ensure that the use of the de-escalation room as an extreme measure is done only with proper justification, for not more than 24 hours and in conditions of multidisciplinary work. Nevertheless, a long, unreasonable and punitive placement of prisoners in the de-escalation room still takes place, which in the Public Defender's assessment equates to cruel, inhuman and degrading treatment. Given the importance of the issue, our focus is directed to the criminal subculture and informal ruling in penitentiary establishments, which is often the cause of violence among inmates. The Public Defender's Nelson Mandela Rules, Rule 38 (2), Rule 76,1 (c). According to UN General Assembly Resolution 70/175 (Rules of Nelson Mandela) on the UN Standard Minimum Rules for the Treatment of Prisoners, accused persons and convicts should be placed separately. (Rule N11 (b)). 34 Imprisonment Code, Article 9(2). 32 33 26