82 Human Rights in Counter-Terrorism Investigations Strip searches, in particular, might undermine detainees’ privacy and dignity, especially where they involve undressing in front of others, and even more so where detainees have to place themselves in embarrassing positions. Such treatment, however, is not in itself illegal: strip-searches, and even body cavity searches, may be necessary on occasion to ensure the security of detention facilities – including the detainee’s own safety – or to prevent disorder or crime. Such measures may be permitted only where absolutely necessary in the light of the special circumstances and where there are serious reasons to suspect that a prisoner is hiding a prohibited object or substance in the searched part of the body. However, while these searches may be necessary, they must also be conducted in an appropriate manner so that the detainee’s suffering or humiliation does not go beyond the inevitable element of suffering or humiliation connected with this form of legitimate treatment. The greater the invasion of the privacy of a detainee being strip-searched, the greater the caution required. In the present case, the frequency and circumstances of the searches varied from one prison to another. Due to this unjustified and arbitrary frequency of the searches and the feeling of inferiority and anxiety these measures have entailed, such treatment amounts to cruel, inhuman or degrading treatment or punishment. * This case study is taken from the facts in Frérot v. France, and the analysis of the question on the findings of the ECtHR in that case.81 3.4 Safeguards for Suspects in Detention81 As mentioned in section 3.1, detaining a terrorism suspect can be necessary on the basis of reasonable suspicion that he or she has committed a terrorism-related offence or is about to commit one, or for the purposes of deportation or extradition. It is a legal step towards bringing someone to trial. Terrorism suspects detained in police custody have not yet faced a trial and should, therefore, enjoy the presumption of innocence. Because detention happens in facilities to which the public generally has restricted access, it enhances the risk of a number of human rights violations. 81 ECtHR, Frérot v. France, Application No. 70204/01, 12 September 2007, <http://hudoc.echr. coe.int/sites/eng/pages/search.aspx?i=001–81008>.