21 In connection with the CCB members’ suggestion to hold meetings outside the Office of the Commissioner for Fundamental Rights as well, the Deputy Head of the Department pointed out that this issue is regulated by the CCB’s Rules of Procedure. These provisions of the Rules of Procedure, challenged by the members of the CCB, can be explained by the fact that, pursuant to the prevailing legal regulations, the Commissioner for Fundamental Rights shall have the powers and competences of the NPM.70 The staff members71 of the Department, as well as the external experts72 participating in the visits, perform their tasks upon the NPM’s authorization. The NPM may enter the premises of a place of detention only for the purpose specified in the relevant legal regulation. 73 Without legal authorization, no place of detention specified in Article 4 of the OPCAT can be compelled to provide a venue for the CCB’s meetings and let the members enter its premises. However, holding a meeting in a place of detention would not mean that the participants could inquire into the treatment of its patients. The representative of the MDAC indicated that they would be happy to provide a venue for an external meeting of the CCB in their new office. The representative of the Menedék Association would support an external meeting if it resulted in increased publicity and positive social return. Regarding the CCB members’ request to present his draft reports to them, the Commissioner for Fundamental Rights reminded the members that, pursuant to the prevailing legal regulations, it is the exclusive competence of the NPM to make recommendations. Prior to their approval and publication, the draft reports are working materials that he may not and will not discuss with the members of the body. The participants accepted and acknowledged the answers given to the questions formulated by the CCB members selected as a result of a call for application formulated during the March 22, 2017, visit of the SPT’s delegation. Concluding the meeting, the Head of the Department pointed out that the three-year mandate of the CCB would expire on November 19, 2017. The Deputy Head of the Department encouraged the members to think over their experiences gained during the last three years. The NPM would welcome any idea aimed at increasing the efficiency of future cooperation. She also noted that the Commissioner for Fundamental Rights is not legally obliged to establish the CCB, it was a gesture towards civil society organizations that had actively lobbied for Hungary’s joining the OPCAT and supported the CFR’s candidature for performing the tasks of the National Preventive Mechanism. The Commissioner for Fundamental Rights confirmed that, upon the expiry of the current CCB, he intended to set up a new one. He was to publish the call for application soon, and he would have evaluated the application by the end of 2017. The new body would operate under the same rules as the current one. He thanked the participants for their contribution to the performance of the tasks of the NPM and indicated that he would be happy to cooperate with the current members in the future as well. The main topic of the November 7 meeting of the CCB was the evaluation of the CCB’s activities during the previous three years. 74 The Commissioner for Fundamental Rights, due to his official engagements, could not participate in the meeting. Miklós Garamvári, Secretary General of the Office of the Commissioner for Fundamental Rights (hereinafter the “Secretary General”), welcomed the members of the Civil Consultative Body. In his personal opinion, the operation of the Civil Consultative Body was successful, correct, constructive, and professional. A significant part of the locations inspected by the NPM was selected based on the Civil Consultative Body’s suggestions. Over See Section 2(6) of the Ombudsman Act See Section 39/D(1) of the Ombudsman Act 72 See Section 39/D(3) of the Ombudsman Act 73 See Section 39/B(1) of the Ombudsman Act 74 The documents of the November 7 meeting are filed in the Office of the Commissioner for Fundamental Rights under number AJB185/2018. 70 71