Part II: Tools for an effective follow-up and implementation Similarly, in the Netherlands the IVENJ can request the inspected institution to develop an action plan for the implementation of their recommendations, although it was noted that the Prison Service usually takes the initiative on developing action plans themselves. Those NPMs consulted considered that action plans can be an extremely useful tool, setting out concrete measures and a clear time frame, sometimes negotiated between the NPM and the institution that is required to implement recommendations.160 These provide an additional set of criteria or indicators against which implementation can be measured. Additionally, the process of developing action plans can in itself be a device to encourage implementation and establish constructive dialogue with the relevant authorities and individuals. 1.4 Meetings and personal exchanges with the authorities The SPT expressly recommends that the dialogue should also involve oral exchange, for example through regular meetings, round-tables or working groups, etc. This is acknowledged by all consulted NPMs that confirmed the need for a regular personal contact to build trust, explain the findings in more detail and encourage the implementation of recommendations. Several NPMs stated that they experienced deadlocks in the dialogue with the authorities that could be resolved through personal meetings. It was argued that authorities are more likely to make concessions in a confidential meeting than in writing. Some NPMs hold only irregular and informal meetings with the supervisory authorities when the need arises, mostly where access to the relevant authorities is easy to obtain. Others have made good use of institutionalised fora for regular exchange. The process followed depends on the national context, access to and relationship with the supervisory authorities and may be particularly complicated in federal states. In any case specific attention must be directed towards keeping meetings effective and resource-efficient as well as to ensure that close interactions do not endanger the NPM’s perception as an independent actor. In line with the SPT recommendation that a dialogue should ’involve both written and oral exchanges’ most NPMs hold meetings with the supervisory authorities in between the visits in some form, often rather sporadic and irregularly. At the same time, all consulted NPMs have underlined the importance of an oral dialogue to explain the findings and recommendations and avoid misunderstandings and more generally build a trustful and cooperative relationship increasing the willingness to implement the NPM’ recommendations. œœ Irregular and ad hoc meetings Many NPMs only hold irregular meetings with the supervisory authorities, not following any specific procedures and organised on an ad hoc basis according to specific needs. While this may in part also be due to limited resources, some NPMs, particularly in smaller countries, have commented that a regular, formalised rather than cause-related exchange would be unnecessary and even ineffective where there is an uncomplicated and easy access to the authorities. The Cypriot NPM holds meetings with the directors of the visited institutions and mid-level government representatives (e.g. head of departments), although these do not systematically follow the submission of each report, but rather if specific problems arise, if certain issues need to be clarified or if recommendations are not implemented. In Malta, direct meetings are only held in urgent cases. In Luxembourg the NPM built up trust with authorities in a series of meetings, including at the ministerial level. Furthermore, the NPM is available via phone 24 hours and has established that in cases of emergency, such as deaths in custody, the authorities call NPM staff immediately, with the NPM staff being at the spot within 30 minutes. In Bulgaria, 160 See e.g. the practice of the RQIA in the UK which reviews draft actions plans and can request revisions to be made if they consider the action plan does not address the issues sufficiently. - 55 -