8 3. ACCOUNTABILITY 3.1 Under international human rights law and international principles on the use of force, States are under an obligation to ensure that law enforcement officials are held accountable for their actions, including any decision to use force. As law enforcement officials are required to protect the public, in certain circumstances States are also obliged to hold them accountable for omissions. 30 To ensure effective accountability, law enforcement agencies shall establish sufficiently independent and effective internal accountability mechanisms, and States should consider the establishment of an adequately resourced external oversight body, in the absence of which an ombudsman or national human rights institution should fulfil this external oversight function.31 3.2 Effective accountability for law enforcement officials involves many different actors: government representatives, parliament, the judiciary, civil society actors and independent oversight bodies, including national human rights institutions or ombudspersons’ offices. Primarily, however, it concerns the police and other law enforcement agencies themselves.32 Members of the Government and other political authorities should promote a culture of accountability for law enforcement and must be held responsible if they encourage or enable unlawful behaviour. States’ domestic law must comply with international law in regulating and controlling the actions of private security companies operating on or from their territory. See for example European Court of Human Rights, Tagayeva v. Russia, Judgment (First Section), 13 April 2017; “Police officers jailed over Bijan Ebrahimi murder case”, The Guardian, 9 February 2016. 31 African Commission on Human and Peoples’ Rights, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, Banjul, 2017, para. 8.1. 32 UNODC, Handbook on Police Accountability, Oversight and Integrity, Criminal Justice Handbook Series, Vienna, July 2011. 30