the penitentiary establishments do not have medical insurance. The working conditions of on-duty doctors and nurses, paramedics, psychologists, and social workers are quite hard. The establishments’ personnel are not provided with transportation and food; they do not benefit from advice as to how to avert professional burnout. The Public Defender welcomes the implementation of the certified compulsory retraining module for the penitentiary personnel. However, it can be concluded, based on the study of the programmes, that the methodology of the module is general and needs further improvement. 3.2. SITUATION IN PENITENTIARY ESTABLISHMENTS IN TERMS OF PREVENTION OF TORTURE AND ILL-TREATMENT It is essential for the prevention of torture and ill-treatment that the state appropriately responds to the incidents of alleged ill-treatment in penitentiary establishments and alleged ill-treatment by law-enforcement officers, so that perpetrators do not act with impunity. In the Parliamentary Reports of 2013, 2014 and 2015, the Public Defender proposed to the Parliament of Georgia to establish an independent investigative body to ensure effective investigation of incidents of deprivation of life, torture, inhuman and degrading treatment allegedly committed by law-enforcement bodies, as well as on the premises of penitentiary establishments. This recommendation has yet to be fulfilled. The position of the Public Defender, therefore, remains the same; there is a standing problem in Georgian legislation and practice of institutional independence in investigating alleged crimes committed by law-enforcement officers as well as alleged crimes committed in penitentiary establishments. Under Article 17.2 of the Constitution of Georgia, no one shall be subjected to torture, inhuman, cruel or degrading treatment and punishment. Under Article 7 of the International Covenant on Civil and Political Rights, no one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. Under Article 10 of the International Covenant on Civil and Political Rights, all persons deprived of their liberty shall be treated with humanity and with respect for the inherent dignity of the human person. The United Nations Human Rights Committee ‘believes that here the Covenant expresses a norm of general international law not subject to derogation.’23 International human rights law pays special attention as to how the rights of those deprived of their liberty are protected in respective establishments. The state must take all adequate measures to ensure that the suffering inherent in punishment is not exceeded.24 23 24 General Comment no. 29, States of Emergency (Article 4), CCPR/C/21/Rev.1/Add.11, 31, August 2001, para. 13.a). Kudla v. Poland, application no. 30210/96, judgment of the Grand Chamber of the European Court of Human Rights of 26 October 2000, para. 94; see also, Valašinas v. Lithuania, application no. 44558/98, judgment of the European Court of Human Rights of 24 July 200,  para. 102. NATIONAL PREVENTIVE MECHANISM (NPM), 2016 23