Report on the Performance of the Activities of the National Preventive Mechanism for 2019 reasonable grounds for suspicion of the accused regarding the deed that is the focus of the charges. In case a private lawsuit was not properly written, for instance if the personal information of the accused were lacking, it would be returned to the private plaintiff to correct it within the legal deadline, after which there would be no obstacles to him submitting a request to the police, based on a court injunction, to cede the necessary personal information. In that case, the police could take appropriate action, in line with the APTA and the Ordinance on Conduct of Police Officers, appreciating the circumstance that the court conducted a review of the existence of aspects defined by the CPA, that is, that it is likely that the accused did violate the private plaintiff's rights. Any other manner of proceeding would fail to guarantee that, after receiving information about another person from the police, the potential private plaintiff would actually initiate court proceedings at all. This alone makes such an action by the police legally questionable, because the inexistence of a protective mechanism allows for the other person's information to be abused. The answer by the Director General of the Police, that the option of handing the personal information to the party requesting them is considered on a case-by-case basis, depending on the type of the incident, involved persons, type of the body which requested the information, the reasons for their handing over etc., indicates that the police is acting arbitrarily and unevenly, based on an arbitral interpretation of the APTA, while ignoring the CPA. For this reason, we warned the police that when handing over personal data, it needs to act in an unarbitrary fashion, in a way that will not result in citizens being treated differently, in view of the fact that doing otherwise undermines legal security and the principle of equality before law, and threatens the rule of law. ECtHR case-law also sets the general demand that the way relevant bodies interpret and implement national law must be "free from arbitrariness", and that it is precisely arbitrariness that is a frequent reason for the ECtHR (see Van Kück v Germany, 2003) to deviate from the general rule of non-interference in the interpretation and application of the national law of the parties' states. 1.2.2. VISITS TO POLICE STATIONS AND POLICE DETENTION UNITS During 2019, the NPM visited 23 police stations and four police detention units in the following County Police Administrations (CPA): Šibenik-Knin, Dubrovnik-Neretva, Koprivnica-Križevci and Varaždin. The visits to the Šibenik-Knin and Dubrovnik-Neretva CPAs were follow up in order to establish whether the warnings and recommendations issued beforehand were being implemented. Regular visits Accommodation conditions In regular visits to 12 police stations, we established that there is partial compliance with CPT standards. The majority are spacious enough, have daily and artificial light, ventilation and heating, and contain wooden benches, rubberized mattresses and blankets. However, some do not have an alert system, and surveillance cameras only cover part of the overall space in which persons deprived of their liberty move, increasing the risk of untimely reaction during any incidents that occur while a 17