Inside Police Custody 2 for use in police interviews, introduced in 2018, requires the information on rights to be provided before details of the interview can be entered. However, lawyers expressed concern that this does not prevent interviewing officers from reading out the rights quickly, or only partially and, in the absence of electronic recording, it is difficult, if not impossible, to assess in retrospect whether the information was appropriately provided in a comprehensible manner. This is of particular concern because some officers were found to seek to deter the exercise of procedural rights, for example, by saying to suspects ‘You don’t need a lawyer’, or ‘I’m assuming that you want to provide testimony’. 3.2.7 Hungary The revised criminal procedure code provides that suspects must be informed about their procedural rights ‘when their participation in criminal proceedings commences’. The code also provides that suspects or accused persons who are arrested or detained must be promptly provided with information about their rights in writing, in simple and accessible language. However, since the provisions prescribing the written notification of rights are contained in regulations governing places of detention (such as the Penitentiary Code), detainees are usually only served with the letter of rights after they have been questioned as a suspect and have been transferred to a place of detention; although a new investigation decree gives the police a discretionary power to serve the letter of rights at the time of the first encounter with the authorities, and at the latest when the first procedural act commences. The electronic interrogation protocol includes all of the rights required by the Directive, but this is only relevant in an interrogation, and provides no guarantee that that the information requirements have been fully complied with. There are two standard letters of rights (one for use in police detention facilities and the other in penitentiaries), but the version in use at the time that the research was conducted did not include all of the rights required by the Directive, and was both lengthy and expressed in complex language. Previous research has demonstrated that the letter of rights cannot be understood by a large proportion of the relevant population. A revised letter of rights has since been introduced, but it was not possible to check whether the problems of incompleteness and lack of comprehensibility have been rectified. The law states that if a suspect is unable to read or write, or if the letter of rights is not available in a language that they understand, they must be given the information orally in the presence of two witnesses. It further provides that suspects who are detained must be allowed to keep it in their possession. 3.2.8 Italy The law provides that suspects must be informed of their rights at the time of the arrest or at the time of the first police interview. Where a person under investigation is not arrested, they must be notified of their rights at the conclusion of the preliminary investigation (which is clearly not in compliance with Article 3 of the Directive). The letter of rights, which the law provides must be in a ‘clear and accurate form’, must be provided to persons who are detained. If the letter of rights is not available in a language that the suspect understands, the suspect may be orally informed of their rights, followed up by a written notice in the relevant language when available. A model letter of rights has been issued in Italian and five other languages (although more may be available at local level), and the rights specified in it are in accordance with the requirements of the Directive. There is no provision regarding suspects who are blind or who 35