inside.72 In the third institution73 the department for persons with mental problems has a room which could be locked from the outside with a key without the possibility of opening it from the inside. The Chancellor is still of the opinion that seclusion of a client of 24-hour special care services in their bedroom or another room adjusted for that purpose is inadmissible. In order to prevent arbitrary restriction of the liberty of service recipients the Chancellor proposed to stop locking clients in their rooms, use seclusion only when all the conditions for seclusion are fulfilled and, should a need for seclusion appear, seclusion should take place only in a specially designated seclusion room. In addition, the Chancellor recommended to analyse which lawful measures can be taken to ensure the safety of a client who may quickly become violent as well as other clients at night and, in order to ensure safety, take measures which, in proportion to the threat, cause least interference with the rights of the clients and also raise the awareness of the staff about the admissibility of restricting the clients’ fundamental right to liberty. 7.4. The number of activity supervisors Insufficient number of activity supervisors in special care homes continued to be a problem during the reporting year. In two special care homes74 only one activity supervisor was on duty at night. During the evening tour of one of the institutions it was found that none of the activity supervisors on duty were constantly present in the department and thus the department had been left unsupervised. In the Chancellor’s opinion, the number of activity supervisors significantly affects the quality of special care services. Inspections carried out during the reporting year give reason for a concern that providers of 24-hour special care services are still unable to ensure the statutory minimum number of activity supervisors. Moreover, the Chancellor is also of the opinion that, for example, in view of the location and arrangement of the rooms of an institution and the distribution of the clients between the departments, the nature and severity of mental problems of the clients, even compliance with the minimum requirements might sometimes not be sufficient. In order to ensure a safe living environment for the recipients of 24-hour special care services and maintain or increase their ability to cope independently, taking account of their condition and skills, the Chancellor proposed to guarantee that at any time the institution has at least the required number of activity supervisors on duty and that service recipients are not left without supervision in any situation. The staff member conducting the tour for the Chancellor’s advisers did not have doubts about the admissibility of locking the door. The staff claimed that the client was preventively locked in their room for their own protection, and explained further that the staff locked service recipients in their rooms for ensuring the clients’ own safety. 73 Narva-Jõesuu Care Home. 74 Erastvere Home of Hoolekandeteenused Ltd and Valkla Home of Hoolekandeteenused Ltd. 72 40