With regard to the wider treatment of detainees and the protection of their rights, the Commissioner’s basic recommendations for the said area is the creation of an area where private meetings can be held between lawyers and detainees, the keeping of detailed records and the provision of food, where necessary. In addition to the above, the Commissioner suggested that members of the Police transferring detainees from and to places of detention, as well as those serving in waiting areas in Courts or other places should receive specialised training on the relevant issues. The NPM’s Report was submitted to the Minister of Justice and Public Order and the Chief of Police in order to take their own actions, requesting them to inform the Commissioner of the progress of implementation of the recommendations and related works in the area within 2 months. At the same time, the Report was forwarded to the Chief Registrar of the District Court of Nicosia and to the Director of the Department of Public Works for their information and any actions they wish to take. Today, all improvement works have already been completed on the basis of the aforementioned recommendations, a fact which led to the improvement of the conditions of detention, thus ensuring respect of the rights of detainees. C. CONSULTATION PAPER ON THE IMPLEMENTATION OF ALTERNATIVE MEASURES TO DETENTION DURING DEPORTATION PROCEDURES The Commissioner, through unannounced visits, as well as through the recommendations submitted thereby as NPM, is called upon to act proactively on ill-treatment to places of detention by minimising the factors and conditions which tend to violate the rights of detainees. Arbitrary detention, that is detention that is not based on the law or that is disproportionally imposed, constitutes a violation of the fundamental right 21