meant by a “preventive visit” – and suggested that specific guidelines and standards be issued. A particularly important factor stressed by the representative of the Chancellor’s office was the need for widespread dissemination of information regarding the Protocol, the protection it offers, and the role of NPMs and the UN Subcommittee. This aspect is not specifically included as a key task of the NPMs under the Protocol, which only requires that NPM reports should be made publicly available by States Parties. After a visit, the Chancellor’s office issues a public report, which is posted on its website, and sends a follow-up letter, booklets with information on its mandate, and texts of the UNCAT, OPCAT and other international agreements to the place of detention. It was also pointed out that the NPMs were well placed to help in preparing the ground for a Subcommittee visit by disseminating information about it on the ground. The Estonian Chancellor of Justice’s office has the right to attend and speak at parliamentary sessions, and is thus able to comment directly on legislation relating to OPCAT issues. It can also provide its interpretation of a law to the Ministry of Justice. 4.4.3 Detention monitoring: some country experiences It was reported with regard to Ukraine that the establishment of the office of Ombudsman and independent surveys conducted by civil society were key factors in the recognition and public perception of torture as a problem that exists in the country. In particular, the office of Ombudsman and human rights protection groups received large numbers of complaints of torture and ill-treatment, including those concerning conditions of detention. This led to a particular focus on the issue by the Interior Ministry. The first attempt to introduce civic monitoring was associated with the adoption of the Interior Ministry Ordinance, 32 which provided a provisional legal framework for a pilot scheme of preventive monitoring in three regions in Ukraine. Mobile Monitoring Groups were established under the Interior Ministry specifically to monitor places of police detention. The scope of the work by the Monitoring Groups was subsequently expanded to incorporate monitoring on a nationwide basis. 33 This direct link to the Interior Ministry was deemed useful in that it facilitated the translation of NPM recommendations into binding commitments. With regard to the independence of the Mobile Monitoring Groups, it was stated that two-thirds of a Group’s membership should be drawn from civil society, with other representatives being full-time Interior Ministry representatives. Notwithstanding Interior Ministry support for the Monitoring Group system, some outstanding issues need to be resolved to ensure it functions effectively. Issues that need to be addressed include insufficient funding in many regions in Ukraine for monitoring activities and regular visits (such funding is provided by the OSCE field operations and NGOs), a limited 32 Ukrainian Interior Ministry Ordinance No. 286 of 17 March 2004 “On Approving the Provisional Regulation on Mobile Groups for Monitoring Observance of the Constitutional Rights and Freedoms of Citizens in the Activities of the Ministry of the Interior.” 33 Ukrainian Interior Ministry Ordinance No. 536 of 8 July 2005 “On the Establishment of Regular Mobile Groups for Monitoring the Observance of the Constitutional Rights and Freedoms of Citizens in the Activities of the Ministry of the Interior.” 39