CAT/OP/GBR/CNPMRO/1 inspections at prisons and immigration removal centres during the COVID-19 pandemic.11 HMI Prisons held two separate consultation meetings with NGOs, during which the SV methodologies (which were still in development) were discussed and extensive feedback was provided. HMI Prisons considered this feedback and amended the finalised SV methodologies accordingly. Following this consultation, HMI Prisons informed the NGOs who participated of the substantive changes that were made.to the methodologies in light of their comments. In addition, HMI Prisons’ publicly consult on any revised versions of their Expectations (the independent criteria which HMI Prisons inspect places of detention against and which are underpinned by human rights treaties and standards). These public consultations are open to submissions from civil society. All submissions received are considered by HMI Prisons and the finalised Expectations are amended accordingly. Section F. Methodology Paragraph 82 – The Subcommittee recommends the NPM to reinforce the preventive focus and to integrate human rights-based approach in its monitoring work, in order to contribute to systemic changes for the protection of persons from torture and ill-treatment. 29. The NPM understands that in order to ensure a preventive focus it must work to a wide-ranging set of standards when visiting and assessing places of detention to improve the treatment of and conditions for persons deprived of their liberty. That is the primary focus of all NPM members. As noted in paragraph 80 and 81 of the SPT’s report, the NPM’s wideranging set of standards must ensure that the existing national standards set by governments are improved. OPCAT is clear that an NPM must consider the standards or “norms” of the United Nations when carrying out visits to places of detention. In the NPM’s 10th annual report, it provides a ‘Spotlight on Prevention’ which reflects guidance on preventive monitoring developed by the SPT and the Association for Prevention of Torture.12 30. In order to reinforce the preventive focus and ensure a human rights-based approach is fully integrated into its monitoring work, the NPM will be carrying out a thematic project on the prevention of torture and ill-treatment in the near future. The NPM will begin this project in early 2021 and will provide the SPT with updates on the project’s focus. Although the substantive work is yet to begin in earnest, the project will look to incorporate the following: • Human rights guidance and authoritative written materials on prevention from human rights bodies, such as the SPT, relevant stakeholders and experts; • Examples from across the NPM on existing preventive practices to illuminate members’ understanding of a preventive approach to monitoring and inspecting places of detention; • Information and feedback from stakeholders, including experts by experience; • The project will result in advisory guidance and training materials produced by the Secretariat for NPM members on preventive monitoring. Paragraph 103 – While noting that harmonising a great variety of methodologies across 21 bodies of the NPM would be difficult to achieve, even in a long term, the Subcommittee recommends that the NPM strive to ensure that all its members incorporate the requirements of the OPCAT into their working methods. Paragraph 104 – The Subcommittee also recommends that the NPM conduct a lessons learned exercise to take stalk of the existing methodology, and continue adjusting and reviewing the working methods and practices of NPM members as it endeavours to harmonize the methodology and to fulfil its mandate in the most efficient manner. 31. While acknowledging the variety of settings NPM members operate in, the NPM recognises the importance of all NPM members’ different working methods being designed 11 12 More information regarding HMI Prisons’ SV methodology is available here: https://www.justiceinspectorates.gov.uk/hmiprisons/about-hmi-prisons/covid-19/scrutiny-visits/. UK NPM, 10th Annual Report 2019-20, https://s3-eu-west-2.amazonaws.com/npm-prod-storage19n0nag2nk8xk/uploads/2020/03/NPM-Annual-Report-201819-WEB.pdf. 7