CAT/OP/POL/RONPM/1 to function effectively owing to the low number of staff members and the disproportionately large workload. An effective system of regular visits to all the places of deprivation of liberty in Poland cannot function properly with such a limited number of staff, especially taking into consideration the number of places of deprivation of liberty in the country. 24. The Subcommittee reiterates that the mechanism must be provided with a budget sufficient for accomplishing all of its mandated tasks, in addition to granting it the institutional autonomy to use its resources. This funding should be provided through a separate line in the national annual budget referring specifically to the mechanism. 8 This funding must be at a level that allows the mechanism to carry out its visiting programme, engage outside experts as and when appropriate, increase its human resources and regularly participate in training, in accordance with its own workplan. 25. Recalling the requirements of article 18 (1) and (2) of the Optional Protocol, the Subcommittee recommends that the national preventive mechanism ensure that its staff have the diversity of background, capabilities and professional knowledge necessary to enable the mechanism to properly fulfil its mandate. 9 This should include relevant legal and health-care expertise, also giving due consideration to gender parity. 26. The Subcommittee recommends that the mechanism evaluate its financial needs in order to more effectively fulfil its mandate under the Optional Protocol and that it submit proposals to the governmental authorities concerning its needs for additional financial and human resources. 27. In order to ensure its functional and operational independence, the mechanism is encouraged to pursue a constructive dialogue with the relevant State authorities with the aim of identifying the additional needs required to properly fulfil its mandate in accordance with the provisions of the Optional Protocol. 3. Mandate and visibility 28. According to the information received by the Subcommittee, the mechanism did not visit all types of places of deprivation of liberty as prescribed by the Optional Protocol. In this connection, the Subcommittee emphasizes that pursuant to article 4 of the Optional Protocol, the State must enable and ensure visits to any place under its jurisdiction and control where persons are or may be deprived of their liberty. Therefore, any place in which a person is or may be deprived of liberty – in the sense of the inability to exercise freedom of movement – should fall within the scope of the mechanism. 29. In determining what constitutes detention and a place of deprivation of liberty, the Subcommittee recommends developing an expansive approach that maximizes the preventive impact of the mechanism. 10 In addition, the mechanism needs to have the legal authority and practical capacity to access any place where the mechanism has information that people are or may be deprived of liberty, in accordance with articles 4, 19 and 20 of the Optional Protocol. 30. The Subcommittee notes that during its first 10 years of operation, the mechanism has been focused primarily on detention-monitoring activities, having carried out around 1,000 monitoring visits. Hence, the mechanism has mainly been perceived as a visiting body and not as a preventive one. The Subcommittee emphasizes that the activities of the mechanism should not be limited only to visiting places of deprivation of liberty. Among other functions, the mechanism needs to have a legal competence to submit proposals and observations concerning relevant draft legislation and to undertake other preventive activities. In this connection, the Subcommittee welcomes the social campaign called “State free of torture”, which was launched by the mechanism in September 2018. 31. The Subcommittee recommends that the mechanism focus not only on visiting places of deprivation of liberty but also on other preventive activities, such as commenting on draft legislation, awareness-raising and training activities, in accordance with article 19 of the Optional Protocol and paragraph 9 of the analytical 8 9 10 6 CAT/C/57/4, annex, paras. 11–21. CAT/OP/12/5, para. 20. CAT/C/57/4, annex, paras. 1–3.