CAT/OP/HUN/R.2 33. While noting the professionalism of some of the NPM members when conducting interviews with the detainees, the Subcommittee recommends that all NPM participants undergo regular trainings, including on interview techniques, visiting procedures and skills to detect signs and risks of torture and ill treatment, to develop working methods and a comprehensive visiting methodology that will highlight institutional and systematic challenges, including those affecting vulnerable populations in places where persons are deprived of liberty. Experienced NPM members could train the new members and the external experts on interviewing techniques. B. Recommendations on methodological issues relating to visits Work plan, reporting and follow-up 34. The NPM plans its visiting activates on a yearly basis, taking into account the different type and geographical location of places of deprivation of liberty and the categories of persons deprived of liberty as well as thematic target(s) of the year. However, the SPT observed that the NPM is mainly focusing on detention monitoring activities. 35. The Subcommittee recommends that the NPM should focus not only on visiting places of deprivation of liberty but also on other preventive activities. The Subcommittee further recommends the NPM to develop an annual plan of work which should include all preventive activities, such as commenting on draft legislation, awareness raising and training activities, in accordance with article 19 of the Optional Protocol and article 9 of the NPM assessment tool. 36. To properly fulfil its mandate under the Optional Protocol in various areas and keeping in mind its preventive role the NPM is advised to critically analyse its activities against relevant international guiding acts. Such an exercise can be done by using 13 Subcommittee’s NPM assessment tool and its matrix. Having clear overview of areas that are insufficiently covered, the NPM can (together with its partners) make wellgrounded working plan for immediate implementation and future development. 37. Following the visits, the members of the visiting delegation prepare partial reports that are summarised by the head of visiting delegation. Visit reports are subsequently submitted to the respective authorities, as well as to the head of the place of detention concerned, the addressees of the recommendations, and the members of the CCB as well as to the Hungarian member of the European Committee for the Prevention of Torture. Then the visits reports are made publicly available in Hungarian. Some of them are also translated into English, depending on the availability of funds. 38. The Office of the Commissioner for Fundamental Rights publishes its annual reports and the reports on the inspections conducted by the NPM on Commissioner’s website. However, the Subcommittee was informed that the drafting and publication of the NPM reports could take very long time due to the wish to aim for high quality and the comprehensiveness of the reports. In this regard the Subcommittee underlines that extended delays in drafting and publication of the reports can have a negative impact on the timely follow-up to the visit report recommendations and eventually overall conditions of people in detention. 39. While the Subcommittee notes that reports of visits are prepared and submitted to the authorities, it also notes that there is no clear policy concerning the systematic followup and dialogue procedure. 40. Further to making the annual report public, pursuant to article 23 of the Optional Protocol, the Subcommittee recommends that it should be discussed publicly in parliament and widely publicized. The annual report of the NPM should be distinct from the annual report of the Office of the Commissioner for Fundamental. 41. The Subcommittee further recommends that the NPM enters into a continuous dialogue with the relevant State and other authorities as well as with other addressees 13 http://www.ohchr.org/Documents/HRBodies/OPCAT/CAT-OP-1-Rev-1_en.pdf 7