Other contacts and activities 3.1 Contacts with Federal Authorities a.  Federal Department of Justice and Police (FDJP) As part of its efforts to assure the functional independence of the NCPT, the Commission held talks with representatives of the Federal Office of Justice (FOJ) regarding its position under administrative law. In connection therewith, it also discussed the findings set forth in a legal opinion commissioned for the purpose of clarifying the notion of functional independence.22 In the course of a regular inspection visit to the Zurich Prison and in relation to a prominent individual case, the Commission examined the detention regime of persons placed in pre-deportation detention and requested the FOJ to clarify issues concerning the detention regime. The Commission noted that orders for pre-deportation detention are issued under § 128, para. 2, of the Zurich Ordinance on Criminal Justice (Zürcher Justizvollzugsverordnung [JVV]), based on the provisions governing pre-trial and security detention. Based on art. 20, para. 1 of the Federal Ordinance on International Mutual Legal Assistance in Criminal Matters (Verordnung über internationale Rechtshilfe in Strafsachen, IRSV), it recommended that the Federal Office of Justice – as the competent authority – establish clear procedures for the enforcement of such orders, taking into consideration both the detention purpose and the principle of proportionality; the Commission further recalled that enforcement procedures may restrict the fundamental rights of the persons concerned only to the extent required for achieving the detention purpose or for preserving security and order in the detention facility. b. Federal Department of Foreign Affairs (FDFA) The Commission attended a national consultation meeting for the Universal Periodic Review of Switzerland with representatives of all relevant human rights organisations. With regard to the UPR proceedings, the Commission prepared a position paper, addressed Cf. sect 4, p. 22. 22 24 Activity Report NCPT 2017