Part I 3. Implementation of the right to lodge complaints by juveniles deprived of their liberty The problem of introducing an effective system of lodging complaints by juvenile residents of youth care centres, juvenile detention centres, juvenile shelters and police emergency centres for children remains unsolved. The issue was already mentioned in the NMPT’s activity report for 201578. The NMPT would like to emphasize that the possibility for juveniles to lodge complaints to independent institutions and entities is a fundamental guarantee of their protection against torture and other forms of inhuman or degrading treatment. This right may be a dissuasive factor towards persons inclined to use such treatment, and makes it possible to take effective action in cases when juveniles are mistreated. An effective complaint mechanism, as a  guarantee of protection against torture and other inhuman and degrading treatment, is a method which can be commonly applied in all places where persons are deprived of their liberty. Its importance has been frequently emphasized by the SPT79 and CPT80. As regards juveniles, the CPT has pointed out that effective complaints and inspection procedures are basic safeguards against ill-treatment in juvenile establishments. Juveniles should have avenues of complaint open to them, both within and outside the establishments’ administrative system, and be entitled to confidential access to an appropriate authority81. According to point 121 of the Recommendation CM/Rec(2008)11 of the Committee of Ministers to member states on the European Rules for juvenile offenders subject to sanctions or measures, Procedures for making requests or complaints shall be simple and effective. Decisions on such requests Cf. Report of the CHR on the activities of the National Preventive Mechanism in Poland in 2015, p. 37. The report is available on the CHR website under the tab Reports on the activities of the National Preventive Mechanism. 79 UN Subcommittee on Prevention of Torture; Cf. Articles 57, 80, 87, 91 and 100 of the 7th Annual report of the SPT of 20 March 2014, CAT/C/52/2; Article 50 of the Report of the SPT visit to Italy, 23 August 2016, CAT/OP/ITA/1; Articles 39, 53-55, 72-73 and 96 of the Report of the SPT visit to Ukraine, 16 March 2016, CAT/OP/UKR/1; Articles 32-33, 67, 86 and 141-142 of the Report of the SPT visit to Brasil, 5 July 2012, CAT/OP/BRA/1. 80 Cf. Articles 41 and 54, Excerpt of the 2nd General Report on the CPT’s activities [CPT/Inf (92) 3]; Article 45, Excerpt of the 12th General Report on the CPT’s activities [CPT/Inf (2002) 12]; Article 53, Excerpt of the 8th General Report on the CPT’s activities [CPT/Inf (98) 12]; Article 38, Excerpt of the 14th General Report on the CPT’s activities [CPT/Inf (2004) 28]. 81 Cf. Article 36, Excerpt of the 9th General Report on the CPT’s activities [CPT/Inf (99) 12]. 78 37