OSCE ODIHR Comments on the draft Law on the Protector of Human Rights and Freedoms of Montenegro T. To rename the title of Chapter III to cover not only the Protector’s jurisdiction and powers, but also his/her responsibilities; [par 45] U. To delete the requirement of victim’s consent for the initiation of proceedings on the Protector’s own initiative from the wording of Article 21 par 4 and amend Article 38 par 2 to permit the Protector to investigate anonymous complaints upon his/her own initiative; [pars 48-49] V. To enhance Article 13 to ensure that confidential information is kept in a secure place and that all personal information on individuals be kept under the strictest confidence; [par 51] W. To review Article 32 and revise it or merge it with Article 13; [par. 54] X. To amend Article 21 par 2 so that all individuals, not only citizens, may initiate proceedings before the Protector; [par. 55] Y. To amend Article 33 as follows: 1. Expand Article 33 par 4 by including therein the requirement that representatives of complainants shall submit signed authorization letters from the persons whom they are representing; [par 56] and 2. Enhance Article 33 par 6 so that persons deprived of their liberty may seek regular visits of the Protector and communicate with him/her using all possible forms of communication. [par 57] Z. To amend Article 34 so that complainants shall only name the respondent authority in their complaints if these are known to them; [par 58] AA. To include in Article 40 the requirement that complainants and respondent authorities shall be notified without delay; [par 59] BB. To enhance the obligation of authorities to cooperate with the Protector under Articles 41 and 42 by including therein the duty to meet the Protector upon his/her request and without delay; []par 60] CC. To review Article 60 and indicate which type of procedure would precede the imposition of fines under this provision, and which body would be competent to impose such fines; [par 62] DD. To differentiate in Article 44 between individual complaints and cases indicating a pattern of human rights violations; [par 63] EE. To specify the recipients of the Protector’s opinions in Article 46 and require all opinions to be published, while taking into account existing confidentiality requirements; [par 65] FF. To include the following in Article 50: 1. Information on results of the Protector’s interventions and achievements; [par 66] 2. The obligation of the Protector to present the annual report to the Parliament and of the Parliament to discuss it during a special session. [par 67] GG. To include in Article 54 the requirement that neither the government nor any budgeting association may change, modify or affect the budget proposed by the Protector; [par 70] HH. To include in Chapter III the duties of the Protector related to records and statistics of discrimination cases under the Law on Prohibition of Discrimination; [par 76] 6