the goals of surveillance. They only indicate that the prisoner was transferred to the cell equipped with the system of visual surveillance, due to re-grouping of prisoners. However, the necessity of applying this measure was not substantiated. Besides, according to these requests, the Safety Unit takes into account personal qualities of the prisoner when requesting surveillance, but it is not specified which qualities are relevant. In some cases, the Safety Unit requests transfer of the prisoner to the cell of the medical unit and introduction of surveillance. The Safety Unit indicates in its requests that the chief doctor requests transfer of the prisoner to the medical unit. However, it was found out as a result of examination that in such cases, the chief doctor requests such transfers only for the purpose of medical supervision and not for visual surveillance. In some cases, the surveillance is based on the ground that is not envisaged by Article 54 (1) of the Imprisonment Code. For example, the mentioned provision does not list surveillance for the purpose of prevention. Accordingly, such surveillance does not serve a legitimate purpose envisaged by Article 54 (1) of the Imprisonment Code and therefore, it is unlawful. It is true that the mentioned provision of the Imprisonment Code allows the possibility of surveillance ‘in order to avoid crime or other offence’. However, the reference to ‘the goal of securing observance of internal regulations’ leaves room for broad interpretation and accordingly, some arbitrariness. It is not clear which requirements of internal regulations need to be secured through surveillance and what is an appropriate nature of action. It is also not explained why it is argued as if there are no alternatives for securing observance of internal regulations when there are other means, including procedure for disciplinary responsibility, for achieving the same goal. It is worth noting that in penitentiary establishment no. 3, all cells for solitary confinement, safe rooms and all cells in the medical unit are equipped with cameras. Therefore, whenever the need for transferring prisoners to these cells arises, they are inevitably subject to the electronic surveillance. Accordingly, when making decisions about surveillance, necessity and proportionality of this measure are not assessed in all cases. Its automatic use is due to the lack of solitary cells and cells in the medical unit that are not be equipped with the system of surveillance. It is worth noting that the surveillance is terminated not when there is no longer any need for such a measure, but when there is no longer any need for keeping the person in the indicated cells (e.g. when there is no need for medical supervision or the term for solitary confinement as a disciplinary measure has expired). The requests filed by the Safety Unit of the establishment N3 that form the basis for the orders of the director of the establishment about electronic surveillance of prisoners placed in the solitary cell for disciplinary offences are basically identical. The Safety Unit of the Establishment indicates that the surveillance is reasonable for securing prisoner’s safety or for health reasons. It is not specified what may threaten the health of the patient. 44 NATIONAL PREVENTIVE MECHANISM (NPM), 2015