Report on the Performance of the Activities of the National Preventive Mechanism for 2019 vulnerable groups, is inadequate, so we recommended that specific identification procedures are guaranteed, as well as additional training for professional staff. Moreover, at the police stations we were denied access to data from the MoI Information System on the proceedings towards irregular migrants, and sometimes even to the cases themselves. Withholding of information to the Ombudswoman In performing the mandate of the NPM, the Ombudswoman is authorised under articles 4, 19 and 20 of OPCAT and Art. 3 and 5 of the ANPM to make unannounced visits to places where there are, or may be, persons deprived of their liberty, and to freely access any data on their treatment, that is, the treatment of anyone in any kind of detention, custody, or being held under surveillance and unable to leave of their own volition. This leaves no doubt that this also pertains to visits to PS/BPS, and access to data on the treatment of irregular migrants held there. However, since June 2018, the MoI has denied direct access to cases and data on the treatment of irregular migrants. Thus, as for instance during NPM visits to border police stations, we were denied access to the MoI Information System, while where individual cases were concerned, the head of the Police Administration's illegal migrations service explained to us that as the officer in charge of the cases was on holiday, "all the cases are locked in the cabinet", and neither the assistant to the police commander nor the head of the illegal migration department were authorised to retrieve them. He also pointed out that we would have received the individual cases had we announced our visit, even though Art. 5 of the ANPM and Art. 20 of OPCAT explicitly authorised NPM members to make 30 unannounced visits to bodies or institutions. On the other hand, the cooperation with reception centres during NPM visits was good, and access to cases and premises was provided, which highlights the inconsistency of MoI practice. Data have also been withheld during investigative proceedings, although under Art. 24 of the Ombudsman Act, the Ombudswoman is authorised to request any necessary information, data, explanations, acts and other documentation from any state body, which must fulfil such requests. Such investigative proceedings By arbitrarily and unevenly interpreting the legal framework regulating the mandate of the Ombudswoman and the NPM, police officers overstep their authority and make it impossible to efficiently fulfil the functions of the NPM and examine the treatment of irregular migrants. were conducted at the border police station, after a report by the Border Violence Monitoring Network (BVMN) alleging that migrants, and even members of vulnerable groups, were held in a basement room at the station, where they had no access to a toilet, water or food, and that their right to seek asylum had been denied. Among them was an underage individual who stated that he had been held there for more than an hour, beaten with fists and bats, and tazered. At the BPS, the head of the PA's Illegal migration service did not allow us to inspect all the requested data, stressing at first that he could not, and then that he would not hand them, but would only allow us to inspect those

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