It should be noted that a prison administration is obliged to inform the convicted person that the Multidisciplinary Group has started evaluation of his/her danger risk. The convicted person has the right to view documents about himself/herself forwarded to the Multidisciplinary Group, if he/she so requests in writing. The convicted person may not view information indicated in Article 8(2) of this order. The person has the right to submit any additional documents, at any stage of proceedings, which he/she thinks will facilitate to making a decision he/she considers favorable to him/her. The Public Defender welcomes this initiative and considers the introduction of a prisoner risk evaluation and periodic review system a clearly positive step. We also welcome the fact that the ministerial order formally establishes the right of convicted prisoners to appeal the decisions of the Multidisciplinary Group on determining the prisoner risk and/or decisions of the Penitentiary Department Chairperson on prisoner transfer. It has been for years that the Public Defender has been recommending in many of its recommendations to allow the prisoners to appeal against their transfer decisions.55 Despite the progress, the Public Defender believes a number of provisions of the draft ministerial order are vague and legally deficient. Annex 2 of the draft order, which lists prisoner danger risk assessment criteria, raises concern in this respect. The Public Defender deems these criteria are vague and insufficient leaving plenty of room for their versatile interpretation and incorrect application in practice. The criteria listed in Annex 2 make the impression that, in evaluating the prisoner danger risks, consideration will only be given to the severity of the punishment. In addition, the proposed draft order contains provisions allowing for unjustified procrastination of the danger risk assessment exercise. The Public Defender believes that convicted prisoners must be explained in advance their rights in the process of their danger risk determination. Convicted prisoners should also be informed, in advance, about the danger assessment criteria. It is then necessary to document the assessment procedure by drawing up relevant minutes, which should be signed by the prisoner. This would raise the protection of prisoner right to a whole new level establishing a higher protection standard. In its proposal, the Public Defender also paid attention to issues such as the need for including physicians in the primary data processing groups and the Multidisciplinary Group. The Public Defender recommended introducing the possibility of moving prisoners from one penitentiary institution to another at their own request. In its proposal, the Public Defender identified also some other issues concerning the draft ministerial order, which he thought were problematic. The proposal has been submitted on 20 March this year and it is therefore unknown at this stage whether the Public Defender’s propositions have been taken into account. 55 Public Defender’s 2013 Report to the Parliament, p. 63 NATIONAL PREVENTIVE MECHANISM OF GEORGIA 41