Part I: Basis for an effective follow-up and themes. It is important that all recommendations are recorded, therefore not only should formal written recommendations be entered in databases but also any verbal recommendations. For example, the Danish NPM has established the procedure of registering in the Ombudsman’s statistics system any verbal recommendations, suggestions, etc. made during monitoring visits, as well as subsequently on the telephone following the visit, which are not reflected in the subsequent written report. Many NPMs do not have such a database or are only beginning to create one.111 For some, therefore what information there is on implementation is only documented, for example, through the visit report or annual report. In the UK, some bodies in the NPM have developed databases to capture recommendations as an aid to follow-up. For example, HMIP has developed a ‘recommendations database’, among other databases, that holds a whole range of information that feeds into all inspections. As well as supporting visits, the information contained in this database is also useful in other contexts such as when submitting information to a parliamentary inquiry. Likewise, the Regulation and Quality Improvement Authority (RQIA), holds an ‘Inspection Activity Monitoring System’, which captures and records recommendations. The Office of the Children’s Commissioner has developed a ‘recommendations log’ which is a record of any written response to a recommendation and which is updated regularly, and has also developed an ‘impact log’ which takes this a step further to look at the impact any recommendations may have had.112 In the UK it has been recognised that ‘creating a database of recommendations that can be searched by theme could enable more sharing of good practice and strengthen consistent across the 20 NPM bodies.’113 Similarly, in Cyprus the NPM follow-up visits are carried out based on the findings of the previous visit and on complaints received. An internal database system records information on the implementation of recommendations. The database system is the same as that used for handling individual complaints, namely that the recommendation is recorded and if it has been implemented a note is made, otherwise the recommendation is ‘flagged up’ in order to follow-up at a later stage. In Estonia, the NPM has an internal digital document management system that does not include a specific list of recommendations, but recommendations and findings can be found by searching by ‘key words’. Included in this document management system is information on whether the recommendation has been: implemented, not implemented, or partially implemented, including information on what action has and has not been taken in relation to a recommendation. Furthermore, the Estonian NPM has a general document register on its website, where all its documents that are not classified and thus public are listed.114 A database does not have to be complex. In Bulgaria, the NPM produces a table of recommendations and when an answer is received this is also noted. This information is then used during follow-up visits as part of the tool to check whether the recommendation has been implemented. Within this process it was noted that prioritising recommendations at the outset helps the process of follow-up by providing a focus. The table of recommendations has been developed as an internal tool but in the last annual report the table was published as an appendix. The decision to publish the table was to encourage compliance and transparency. In the Netherlands the Prison Service has developed its own database of recommendations of the IVENJ, to help the Prison Service itself to follow-up on the recommendations. The findings from our research suggest that, provided the appropriate attention is paid to confidentiality and protection against reprisals, other authorities or institutions also consider putting in place similar databases to systematically record recommendations from NPMs as a way to assist in follow-up. E.g. Austria. UK, NPM, Making Recommendations (2014) para 11. 113 See UK NPM and HRIC, ‘The UK NPM at Five Years’ 5. 114 According to the Estonian Public Information Act, para 11, the document register is a digital database which is maintained by a state or local government agency or a legal person in public law in order to register documents received by the agency and prepared in the agency and to ensure access thereto. This general document register is available in Estonian here <http://adr. rik.ee/okk/> for the Estonian Public Information Act see <https://www.riigiteataja.ee/en/eli/522122014002/consolide>. 111 112 - 43 -