NORWEGIAN PARLIAMENTARY OMBUDSMAN National Preventive Mechanism ANNUAL REPORT 2020 34 cations.8 When children have their mobile phones taken from them and are not permitted to move freely, this can result in institutionalization with only minimal contact with peers. The isolation-like conditions that these children experience are in some cases explained by the institution as a strategy of “warming up” or “containing” the individual adolescent so that staff can be in a better position to provide help. In the Ombudsman’s experience, it is difficult to see that this has been a successful strategy in relation to the adolescents involved.9 On the contrary, we have been concerned that such circumstances can lead to the the adolescents feeling isolated and abandoned, resulting in feelings of powerlessness, disruptive behaviour and an escalation of behaviour characterised by a distrust of adults. In some cases, we have seen situations involving the extensive use of physical coercion as a response to this type of escalating behaviour. Such incidents only increase mistrust and insecurity for both the child and the staff. Despite the fact that the particular situation where physical coercion is used can be well founded in the administrative decision, it is therefore important to examine the child's situation in more detail, in a longer and more holistic perspective. Acute incidents can be caused by strain experienced by the young person over time.10 These circumstances give rise to concern as to whether children live in situations that involve a ­violation of the prohibition against isolation according to national regulations. The European Common area in a child welfare institution visited by the NPM, in which only one adolescent lived. Convention on Human Rights (ECHR) article 8 stipulates that restrictions on private life may only be imposed if in accordance with the law and must be necessary and proportional in each individual case. In cases where a person’s freedom is already restricted as they have been forcibly placed, the European Court of Human Rights has a strict view regarding measures that limit the person’s freedom even further.11 Organising schooling and activities can take too long Children and adolescents who reside at child welfare institutions have the same right to schooling as other children.12 UN guidelines for alternative care for children point out that those who are responsible for children under alternative care, must “take steps to promote and protect all rights that are particularly relevant the children without parental care, including among other things access to education [...]”.13 8 Ref. Rights regulations Sections 22 and 24. 9 See The Parliamentary Ombudsman's report after visit to Stendi AS, Nymogården child welfare institution, 12–14 November 2019, page 31. 10 This is a correlation that is also highlighted in the County Governors of Hordaland, Rogaland and Troms (2016). “Dei forsto meg ikkje” [“They did not understand me”]. Supervisory report, 19 September 2016. 11 Munjaz v. United Kingdom, application no. 2913/06, 17 July 2012, section 80: “... when a person’s personal autonomy is already restricted, greater scrutiny [will] be given to measures which remove the little personal autonomy that is left.» 12 UN Convention on the Rights of the Child article 28, UN rules for protection of minors deprived of their liberty (Havana Rules) section 38, Education Act Sections 2–1 and 3–1, rights regulations Section 1. 13 United Nations, General Assembly (2010). A/RES/64/142. Guidelines for alternative care of children, article 16.