self-injuries, etc.). By being transparent, such a detention record increases not only the security of the individuals in custody, but (for instance in case of illness or injuries to the inmates) also contributes towards the legal certainty of the responsible officers. The fact that the specific design of detention is not set out in a separate set of rules leads at the same time to a situation in which some areas do not meet the standards which are called for by the CPT and which the Federal Agency also applies as a standard. The Federal Agency points out that, in accordance with the CPT standards, persons who are deprived of their liberty have three essential rights from the beginning of their apprehension about which they must be informed, both orally and in writing, in a manner which is understandable to them: The right to consult an attorney, to consult a doctor and to inform relatives.18 The Federal Agency proposes to examine and, where appropriate, ensure that the information is provided in the form stipulated by law, and in particular also at the earliest point in time, that is at the time of apprehension. code, it has been ordered that a detention record is to be kept – initially for Dresden customs investigation office. The customs administration as a whole is to be obliged to keep detention records, even before the detention code is created. There is said to be no legal uncertainty regarding the time and extent of the information given to a person who is detained in the customs administration. The regulations regarding the information obligations were announced via a decree, as well as in the individual service regulations of the customs administration (Service Regulations on Financial Control of Illegal Employment [Dienstvorschrift Finanzkontrolle Schwarzarbeit – DV FKS], Service Regulations for Mobile Control Groups of the Customs Administration [Dienstvorschrift für Mobile Kontrollgruppen der Zollverwaltung – KontrollDV], Service Regulations for Criminal and Administrative Fines Procedure [Dienstvorschrift für das Straf- und Bußgeldverfahren – StraBuDV]) and included in the workflow sheets for the investigation standard. The necessary information was included in forms containing translation aids in the national Intranet of the customs administration. The information from the customs investigation office was said to be provided as a matter of principle at the beginning of a questioning. Should there be problems in communication, it was said to be possible in exceptional cases for the information not to be provided until an interpreter had arrived, if no information sheet was availa- 18 cf. CPT Standards, Standards No. 36 and 40 (for police custody, however, the CPT stated in its report to the Greek Government on the visit to Greece from 23 September to 5 October 2001, in which customs units were also visited, that the standards stipulated for police detention apply equally to other agencies, such as customs authorities, to the extent that they exercise law enforcement powers involving the possibility of depriving persons of their liberty (CPT/Inf (2002) 31, No. 10). 37

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