VI. PROTECTION OF PERSONS DETAINED AT ACCOMMODATION CENTRES WITH THE MINISTRY OF THE INTERIOR In 2020, the NPM inspected thirteen premises for accommodation of detainees in the structures of the Ministry of the Interior, including structures of the Sofia Directorate of the Interior. In view of the mass protests in the country, the NPM received Critical findings The state of the system of 24-hour complaints and signals from citizens detention at police departments and non-governmental organisations remains unsatisfactory in 2020. with information about serious The long-standing problems related violations of the rights of protesters to overcrowdedness, poor housing detained by the police in Sofia on and living conditions, lack of 10.07.2020 and 02.09.2020. There sanitary units, no access to ventilation and natural light, access are indications that with respect to to legal aid are still top of mind. detainees at 2 District Department – Sofia Directorate of the Interior there Main recommendations: was failure to respect a fundamental guarantee of protection – ensuring Develop a specific policy to overcome the access to a lawyer, including in cases problem with overcrowdedness, lack of access to ventilation and natural light at when lawyers engaged by relatives MoI detention centres; of the detainees appeared at the police and demanded to see their Improve the awareness of detainees clients. It is noted that the conditions about their rights; at the detention premises were unsatisfactory and they were Ensure access to legal aid for detainees; overcrowded. There are also claims Improve the provisions for the need for that the police authorities detained medical help when unresponsive persons people who had not disturbed the are detained (temporarily lacking legal public order. The media published a capacity) within the meaning of Article 21, series of images of violence and para 1 of Instruction No. 1821z-78 of 2015 unauthorised use of force against on the procedure for detention, equipping premises for detainees and the order in protesters and reporters. In addition, them at the Ministry of the Interior. media publications show police officers carrying brass knuckles and wearing stickers on their uniforms in English reading “One hit. One kill. My decision. No remorse.” The use of brass knuckles by police officers is inadmissible as per the requirement of Article 85 of the Ministry of the Interior Act which makes an exhaustive list of all auxiliary means and the cases in which they are absolutely necessary. 19