or 3 of the ECHR.220 On the other hand, the principles are intended to protect against violation of these fundamental rights by providing for an investigative framework that is effective and capable of bringing offenders to justice.221 32. The minimum requirement is that a member state must ensure arrangements are in place to comply with the five principles in the event that Article 2 or 3 of the ECHR is engaged. In furtherance of this aim the CPT has strongly encouraged the creation of a fully-fledged independent investigative body.222 33. More broadly, the five principles also serve as helpful guidelines for the handling of all complaints. The existence of an independent police complaints body (IPCB) with comprehensive responsibilities for oversight of the entire police complaints system will reinforce the independence principle. Practices are suggested in this Opinion in support of a human rights compliant police complaints system which will allow for appropriate and proportionate responses to all complaints. 34. Primary legislation should provide for the operation of an IPCB with general responsibilities for oversight of the police complaints system and express responsibility for investigating Article 2 and 3 complaints in accordance with the ECHR independence principle. Arrangements in the form of, for instance, secondary legislation, regulations, statutory guidance and protocols, will be required to enable the police and IPCB to work together in partnership and ensure that all complaints are handled fairly, independently and effectively. 35. The institutional design of IPCBs established in a number of jurisdictions in Europe in recent years has taken the form of specialised ombudsman institutions or, alternatively, standing commission structures. The appointment of a Police Ombudsman or a Police Complaints Commission, comprising a number of commissioners co-ordinated by a Chairman, are each capable of overseeing a fair, independent and effective complaints system. The United Nations Principles relating to the status and functioning of national institutions for protection and promotion of human rights (Paris Principles) are also relevant in gauging the independence and functioning of IPCBs. Naturally, the constitutional arrangements and policing systems, along with historical, political and cultural influences, prevailing in each member state will play a major part in determining the institutional arrangements for an IPCB. 220. See, for example, Salman v. Turkey (Application no. 21986/93), Judgment 27 June 2000, § 123. 221. See, for example, Nachova v. Bulgaria (Application nos. 43577/98 and 43579/98), Judgment 6 July 2005, § 110. 222. The CPT Standards, Chapter IX., § 38. Effective investigation of ill-treatment – Guidelines ► Page 90