CAT/OP/GBR/CNPMRO/1 to follow the OPCAT framework, as noted in paragraph 103 of the report. The NPM accepts the SPT’s recommendation that it should strive to ensure OPCAT requirements are incorporated into all of the members’ methodologies. The NPM Secretariat intends to analyse and reflect on NPM members’ methodologies as part of the aforementioned thematic project on prevention. The NPM notes the SPT’s comments that harmonising the work of NPM members in line with an international human rights framework requires that members cooperate for the effective discharge of their OPCAT mandate. This includes exchanging relevant information, sharing monitoring approaches and expertise and engaging in crosssector learning. The possibility of legislation for the NPM, as noted above, also raises the possibility, promoted over the last few years by the NPM, that the keys provisions of OPCAT, including the prevention of ill-treatment, will be included in the legislation of every one of its 21 members. 32. In this regard, the NPM would like to draw the SPT’s attention to the NPM’s work to incorporate the requirements of OPCAT and international guidance in the context of monitoring places of detention during COVID-19. COVID-19 restrictions in the community and in places of detention required NPM members to re-visit their methodologies to ensure they continued to exercise their OPCAT mandate whilst also committing to the principle to ‘do no harm’. Guided by the SPT’s advice and international human rights guidance to NPMs on monitoring during COVID-19,13 NPM members developed new approaches to monitoring places of detention. In April 2020 the NPM published a Factsheet to showcase the new working methods of some NPM members.14 NPM members shared their new approaches to monitoring at NPM business meetings and subgroup meetings. 33. In relation to the SPT’s recommendation in paragraph 104, the NPM intends to resume its self-assessment process as part of a ‘lessons learned’ activity. In previous years, the NPM Secretariat circulated a detailed self-assessment to NPM members annually. The NPM Secretariat intends to re-visit the self-assessment questionnaire and modify certain questions to bring the document more in-line with this report’s observations and recommendations on the NPM’s working practices. The self-assessment will include questions to analyse the methodologies used by each NPM member.15 Paragraph 105 – In light of the above, the Subcommittee recommends that the NPM of the UK to: (a) ensure that their working practices are consistent with standards for preventive monitoring; (b) in case of Lay NPM entities, conduct training to ensure consistency in the methodology of volunteers and lay observers from the moment of selection; (c) realize cross-institutions trainings and exchanges across different NPM bodies; (d) establish and use the referral system for individual complaints, which should not be handled by the NPM; and 13 14 15 8 Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, February 2020, Advice of the Subcommittee on Prevention of Torture to the National Preventive Mechanism of the United Kingdom of Great Britain and Northern Ireland regarding compulsory quarantine for Coronavirus, adopted at its 40th session (10 to 14 February 2020), https://s3-eu-west-2.amazonaws.com/npm-prod-storage-19n0nag2nk8xk/uploads/ 2020/02/2020.02.25-Annexed-Advice.pdf-V2.pdf [accessed 27/08/2020]; Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, March 2020, Advice of the Subcommittee on Prevention of Torture to States Parties and National Preventive Mechanisms relating to the Coronavirus Pandemic (adopted on 25th March 2020), https://www.ohchr.org/Documents/HRBodies/OPCAT/AdviceStatePartiesCoronavirusPandemic2020. pdf [accessed 27/08/2020]. UK NPM, April 2020, Factsheet: The UK National Preventive Mechanism – preventing ill-treatment in the context of COVID-19, https://s3-eu-west-2.amazonaws.com/npm-prod-storage19n0nag2nk8xk/uploads/2020/04/WEB-NPM-member-approaches-for-website-.pdf [accessed 27/08/2020]. UK NPM, 2015, Self-assessment of the UK NPM, https://s3-eu-west-2.amazonaws.com/npm-prodstorage-19n0nag2nk8xk/uploads/2015/08/UK-NPM-self-assessment-write-up.pdf.