It is evident from the above case that the strip search conducted therein could not reasonably be considered as necessary and proportional. Nothing in the actions of the prison staff indicates that there was any suspicion that the convict possessed any illegal item or he had breached the law in any way. The strip search was not aimed at a more detailed inspection of the respective part of the body. The minutes show that the staff member did the same (up and down movements with metal detector from the waist down to the knees) before strip search and afterwards. Stemming from the above-mentioned, the Public Defender found that the request for bodily search did serve a legitimate aim. Special consideration is given to the fact that there were six persons in the cell without any legitimate ground. In such conditions, intrusion into the intimate sphere of a prisoner may additionally amount to inhuman and degrading treatment. The European Court of Human Rights found in several cases that strip searches amounted to inhuman treatment since no compelling reasons have been adduced to find that this measure was necessary and justified by security reasons. In addition, whilst strip searches may be necessary on occasions to ensure prison security or prevent disorder in prisons, they must be conducted in an appropriate manner.89 In terms of ensuring security at a penitentiary establishment, it should also be taken into consideration that security encompasses many other elements such as personal screening of an remand/convicted person and periodic and spontaneous inspections of the premises of an establishment and buildings and constructions located there.90 Therefore, security considerations may not always be the basis only for strip searches. It should also be taken into account that in those cases, where a prisoner is under control of the personnel, the high degree of the control from the administration should be borne in mind. This concerns e.g., transfer of an inmate to a courtroom or a hospital. During full body searches, every reasonable effort should be made to minimise embarrassment and ensure respect for the dignity of a person. The CPT emphasises that prisoners who are searched should not normally be required to remove all their clothes at the same time.91 These searches must be conducted in private, in a separate room, away from the eyes of inmates and others. There must be adequate conditions of hygiene and cleanliness.92 It is important to clean and sterilise the place before each search. 89 90 91 92 Iwańczuk v. Poland, application no. 25196/94, judgment of the European Court of Human Rights of 15 November 2001; El Shennawy v. France, application no. 51246/08, judgment of the European Court of Human Rights of 20 January 2011; Valašinas  v. Lithuania, application no. 44558/98, judgment of the European Court of Human Rights of 24 July 2011. Statutes of the Penitentiary Establishments. Council of Europe, European Committee for the Prevention of Torture, Report to the Czech Government on the visit to Czech Republic carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 1-10 April 2014, para. 85, published on 31 March 2015, available in English at: http://hudoc.cpt.coe.int/eng#{“fulltext”:[“squat”],”CPTSectionID”:[“p-cze-20140401-en-30”]} [Last visited on 10.02.2017]. Association for Prevention of Torture (APT), Detention Focus – Body Searches, available in English at: http:// www.apt.ch/detention-focus/en/detention_issues/6/ [Last visited on: 10.02.2017]. NATIONAL PREVENTIVE MECHANISM (NPM), 2016 55