ADVISORY ACTIVITIES • GENERAL INTERVENTIONS According to Article 14(2) of the Act on the Commissioner for Human Rights, the Commissioner may send a general intervention letter to an agency, organization or institution whose activity has been found to have infringed the liberties or rights of an individual and a citizen. In 2020, the CHR, acting as the National Mechanism for the Prevention of Torture, sent 12 general intervention letters. Excessive use of handcuffs on detainees by police officers who use them as a form of prevention17 The National Mechanism for the Prevention of Torture, while visiting places where people are deprived of their liberty, has noted a disturbing practice of excessive use of handcuffs on detainees by police officers. This applies both to escorting detainees and to interrogations or preliminary questioning at police stations. The Commissioner for Human Rights pointed out that public authorities may take such measures with regard to citizens only in cases provided for by law, and if necessary for ensuring the state security or the public order, protecting the environment, health, public morals or the freedoms and rights of people. Both the Act on the use of coercive measures and firearms18, and the Act on the Police19 empower police officers to use direct coercion measures, including handcuffs. However, when using such measures, three basic principles have to be observed: subsidiarity, proportionality and minimal harm. According to these principles, the use of direct coercion has to be preceded by the use of other methods aimed at the intended behaviour of persons who do not obey the law although they have been called to do so by relevant services. Those principles also aim at preventing standard and routine use of direct coercion measures. If the use of such measures is necessary, it should be adjusted to the circumstances and the people concerned. In the Commissioner’s opinion, direct coercion measures should therefore be applied only to the extent necessary to achieve the purpose for which they are used. The findings of the representatives of the National Mechanism for the Prevention of Torture made during the monitoring visits to police detention facilities indicate, however, that the abovementioned principles are not observed. For example, the analysis of post-visit reports from juvenile educational centres, drawn up by representatives of the NMPT in the last two years only, leads to the conclusion that juveniles are handcuffed while being escorted to such facilities by police officers. The NMPT's findings indicate that the use of handcuffs by police officers on juveniles is mainly justified by 17 General intervention letter of the CHR to the Minister of the Interior and Administration, of 20 January 2020, no. KMP.570.29.2019. 18 The Act of 24 May 2013 (Journal of Laws 2019, item 2418). 19 The Act of 6 April 1990 (Journal of Laws 2020, item 360). 20