-40 that entail isolation (or de-facto isolation) and serious restrictions to their rights. The ECtHR does not consider these special regimes as contrary to Article 3 ECHR per se, but evaluates the conditions of detainees on a caseby-case basis. Even if it states that these kinds of security-driven regimes should be used only exceptionally with all safeguards and precautions, that mitigating measures should be in place and alternatives to isolation should be found, the ECtHR still justifies harsh isolation when the detainee is linked to organised crime, terrorism, and mafia-type organisations.124 Upon judging these cases, the ECtHR thoroughly checks whether the State has made an evaluation of the specific personal circumstances of the inmate (including the effects of the regime on mental health), and whether it has balanced “the degree of the applicant’s relative isolation on the one hand, and the degree of compensating measures on the other”. Among the others, the analysis of compensating measures includes the activities that the isolated inmate is allowed to carry out, the visits s/he can receive, and the level of interaction with staff members.125 On the side of procedural safeguards, detainees should have an effective remedy at their disposal (ECtHR126). They should be able to appeal against their placement in solitary confinement, there should be a mechanism of review of the measure, and the penitentiary system should aim at their placement in progressively less restrictive custody (SPT127). In several cases that ended up in front of the ECtHR, there was no way to complain against the measure. In others, only one magistrate in the country examined the appeals, with the result that sometimes this was done once the measure was over (explaining why the ECtHR found in several instances that Italy had infringed the ECHR.128). As these special regimes involve the use of solitary confinement, their imposition, continuation, and termination 124. European Court of Human Rights, Case of Horych v. Poland, §94. European Court of Human Rights, Case of Ramirez Sanchez v. France, §146. 125. European Court of Human Rights, Case of Fjotolf HANSEN v Norway, Application no. 48852/17, 29 May 2018, §§148-152. 126. European Court of Human Rights, Case of Messina v. Italy (No. 2), Application no. 25498/94, September 2000. 127. Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, Report on the visit of the Subcommittee on Prevention of Torture and other cruel, inhuman or degrading treatment or punishment to Maldives, CAT/OP/MDV/1, 26 February 2009, §§197-198. 128. European Court of Human Rights, Case of Messina v. Italy (No. 2).