41 register different levels of criminality (North East area registered a high rate of criminality), some persons were transferred to other places of detention, at relatively large distances from the support environment. Also, transfers were made to fulfill the obligation to ensure the minimum accommodation conditions. In order to mediate the relationship with the support environment, at the level of the penitentiary system the aim is to maximize the use of the right to online calls. The Ministry of Justice has stated that it is considering the creation of new accommodation places for the persons who execute the punishment in open regime, in the North-East region of the country, acting on two levels: 1. the reduction of the number of inmates accommodated by the penitentiary units of the North-East Region; 2. increasing the accommodation capacity (within the Norwegian Financial Mechanism 2014-2021, a series of infrastructure investment measures will be financed, between 2018-2023, including: Botosani Penitentiary - 400 places and Vaslui Penitentiary - 210 places; based on the Memorandum of Understanding, a Concept Note was developed, in which it was proposed to create new accommodation places, including in Iași Penitentiary - 600 places). However, given the repeated transfers of detainees, the NPM stresses that they can be assimilated to ill-treatment, according to the CPT Rules. ► Detention and preventive arrest centers: ● the location of the centers in the basement of the buildings, which generates deficiencies such as lack of natural light, insufficient ventilation, moisture and mold in the detention rooms; regarding this aspect, in the Report prepared following the visit to the Buzău Detention and Preventive Arrest Center, the NPM representatives emphasized and reiterated the proposal made by the People's Advocate since 2015, through the Special Report on the conditions of detention in prisons and detention and remand centers, determining factors in respecting the human dignity and the rights of persons deprived of liberty (p. 192), respectively: „identifying places that could be taken over by the administration of detention and preventive arrest centers, and, last but not least, the construction of new centers to replace the current "cellars", so that they correspond to the European standards in terms of surface, volume, ventilation, meeting the physiological needs under privacy conditions, by allocating adequate budgetary resources and accessing significant European funds "; ● the lack of at least one detention room adapted for persons with disabilities, as well as access routes for persons with disabilities in accordance with the provisions of Art. 12 paragraph (15) of the Order of the Minister of Internal Affairs no. 14/2018, which stipulates that in each center will be provided access routes for people with disabilities; ● not providing hot water at least twice a week, which would allow persons deprived of their freedom to shower with hot water; ● lack of female agents to ensure the guarding, supervision and, if necessary, the transfer of female persons deprived of liberty; ● lack of a space set up to ensure the right to online communications; ► centers for people with disabilities: ● the beneficiaries were not located in a center adapted to their needs (at the Center for Integration through Occupational Therapy Râmnicu Sărat, Buzău county, most of the beneficiaries were not able to perform lucrative activities in the community, not being autonomous); ● beneficiaries placed under interdiction did not have guardianship measures, so they were not represented at the time when decisions were made concerning them (at the Războieni Neuropsychiatric Recovery and Rehabilitation Center, in this case there were 32 beneficiaries); ● there were no appropriate conditions to provide psychological assistance (at the Războieni Neuropsychiatric Recovery and Rehabilitation Center there was only one space for the psychological activity, so the 4 employed psychologists were obliged to perform their activity by rotation, and the conditions regarding the confidentiality of the professional act and the emotional security of the beneficiaries were PEOPLE’S ADVOCATE ANNUAL REPORT 2019