39 Selected topics from 2019 In addition, we also made comments to the specific proposal. For instance, the Parliamentary Ombudsman emphasised the following problematic elements in the proposal: › the existing provision on the prohibition against isolation used as punishment, treatment or as a corrective measure is to be removed › the prohibition against coercion used as ­ unishment, treatment or as a corrective p measure is to be limited to ‘physical’ coercion, even if improper psychological pressure and threats can cause equally serious harm › the regulations on the use of coercion in situations of acute danger refer to ambiguous rules based on the principle of necessity that is not included in the child welfare legislation › the draft legislation proposal contains no minimum requirement for the use of isolation in situations of acute danger › the legal limits for restricting children’s freedom of movement inside and outside an institution are not clearly defined, including what constitutes illegal isolation A so-called “isolation room” at a child welfare institution visited by the NPM. The room was taken out of use after our visit. Important guidelines for detainees in need of medical help In September, we made a consultation submission on the Directorate of Health's proposal for national guidelines for medical personnel relating to health services for detainees in police custody.3 Several of the recommendations made by the National Preventive Mechanism (NPM) after visits to police custody facilities, are reflected in the draft guidelines. The draft emphasises that doctors must not be involved in decisions concerning placing a person in custody. The submission also proposes measures to ensure that the duty of confidentiality is maintained when medical assistance is given to detainees, by ensuring that police personnel who escort the detainee are not present during examinations and treatment situations, for instance in the accident and emergency unit. 3 The Parliamentary Ombudsman’s consultation submission on guidelines for medical services for detainees in police custody, 29 August 2019. Read the whole consultation submission here: https://www.sivilombudsmannen.no/wp-content/uploads/2019/09/ Sivilombudsmannens-h%C3%B8ringsuttalelse-om-veileder-om-helsetjenester-til-arrestanter-i-politiarrest.pdf

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