Independence of National Preventive Mechanisms (NPMs) law”55, but is nevertheless subject to various norms and directives that are binding on the central Federal Administration.56 In financial matters it is subject – like all other units of the Federal Administration – to the provisions of federal legislation on human resources and budgeting. Personnel costs must thus be approved by the competent department, which is also responsible for the classification of staff positions and for all hiring and employer decisions. The NCPT staff is employed under the same rules as apply to all Federal Administration personnel.57 Because it is attached to the General Secretariat of the FDJP, the NCPT is able to avail itself of existing administrative, financial, linguistic and human resource services, for which the Commission does not at present have its own budget. The administrative attachment to the FDJP makes it possible for the NCPT, by leveraging existing synergies, to maintain a lean structure, which, given the limited financial resources available to the Commission, is doubtless an efficient solution in terms of business management. 4.3 Assessment in the light of the OPCAT The legal opinion commissioned by the NCPT focused, in particular, on the issue of the administrative realisation of functional independence and examined, specifically, the question of whether the model applied to the NCPT, under which it is an organisationally independent administrative unit without legal personality conforms adequately to the prescriptions of international law. RVOV Art. 7a, para. 1 (b) und RVOV Art. 2 55 Directive of 1 January 2018 on Translation Services in the FDJP [Weisungen über das Übersetzungswesen im EJPD vom 1. Januar 2018] , under which the NCPT is required to use the translation services of the FDJP for the translation of its reports into the official languages; the relevant ordinances, directives and guidelines on archiving services; the FDJP regulations on internal audits; the FDJP Directive on Implementation of Data Protection and Information Security [Weisung des EJPD über die Umsetzung des Datenschutzes und der Informationssicherheit (DSIS-Weisung EJPD)] of 1 October 2017; and the directives and guidelines on the EJPD information technology systems. 56 Ordinance of 3 July 2001 on Federal Personnel [Bundespersonalverordnung (BPV)], (SR 172.220.111.3) Art. 1, para.1 (b) and Art. 2, para. 4. 57 Activity Report NCPT 2017 39