ANNUAL SPECIAL REPORT 2016 9 Furthermore, according to the general competence of Article 103(9) of the Greek Constitution and of Law 3094/2003, the Ombudsman has access to all files, documents, data or archives. To implement this competence of the Ombudsman, a working group was set up in October 2014 on all issues relating to the NPM under the responsibility of the Deputy Ombudsman for Human Rights. The following key areas of activity were defined: ϭϭ Analysis of the scope and extent of its competence, good practices and search for collaborations in the direction of the efficient exercise of its competence. ϭϭ Definition of the methodology of investigation, data collection and processing, and presentation of findings and recommendations. ϭϭ Establishing the criteria for prioritising the selection of the detention facilities to be visited. These serve as the starting-point from which the NPM will carry out its operational planning with regard to monitoring issues relating to detention, starting with the conviction that detention, as the most serious deprivation of liberty, must be used as the exception, when it is unavoidable and when no alternative measures can be imposed. ●