During the 2018 visit, the NPM told us they were still finding only limited evidence of their recommendations being implemented. The NPM itself was developing its capacity[36] and reach. In 2018, the NPM inspected institutions of confinement throughout Greece, trying to ascertain the conditions in all areas that fell within its sphere of competence. That year, the NPM undertook fourteen visits to pre-removal centres and police stations where foreign nationals were detained in each one of Greece’s thirteen administrative regions. By organizing at least one visit per year to each detention site, the NPM is now gradually consolidating its mandate as an external monitoring body of detention conditions nationally (Fili and Bosworth, forthcoming 2019). However, NPM staff continue to have responsibility for other work undertaken by the Ombudsman, including complaints, monitoring of removals of thirdcountry nationals, and investigating allegations of arbitrary behaviour of law enforcement officials[37]. While complaints work help them to choose which establishments to visit on the basis of risk, at a final training event with the NPM, staff were concerned about the lack of time to manage the complaints and preventive monitoring work together. Staff were also keen to have more general training and guidance on monitoring. The NPM had not yet published any individual visit reports, but their annual reports contained information on all the sites they had visited in 2016 and 201[38]. During a meeting with the Ombudsman, he was clear-sighted about current challenges and keen to find ways to improve the NPM’s capability and capacity. [36] Concerning financial support, it was only in mid-2017 that the NPM was granted a subsidy by the Ministry of Administrative Reform, notwithstanding the fact that support had been envisaged since 2014 in the law that ratified OPCAT. In other words, since 2014 and until mid-2017, the work of the NPM was carried out with resources redistributed from the Authority’s scarce budget. It should also be noted that, even though additional funding for the NPM mandate has been granted since 2017, this is done on an annual basis and only after the submission of a request by the Ombudsman. As a consequence, funding is normally made available sometime in the course of the fiscal year (i.e. not from January 1st). As a result, the strategic planning and priority-setting of the Mechanism, although designed for a period of 3 years since 2017, can only be confirmed on an annual basis, as it depends on the availability of the financial resources requested. [37] As far as the appropriate staffing is concerned, it should be noted that the granting of the NPM mandate to the Greek Ombudsman was not accompanied by a provision to recruit additional staff to work on a full-time basis. Hence, the Greek Ombudsman set up a working group (the “OPCAT team”) under the responsibility of the Deputy Ombudsman for Human Rights (currently Prof. George Nikolopoulos) composed of 1 administrator and 15 special investigators of the Greek Ombudsman’s office, who have also parallel duties in different departments of the Independent Authority as those of Human Rights, Social Protection, Children’s Rights, Equal Treatment and Public Administration. These staff continue to bear responsibility for additional - yet related - tasks as part of the Ombudsman office as well as their monitoring duties under OPCAT; as a result, they are also responsible for receiving and responding to complaints (Ombudsman’s general mandate), monitoring of procedures for the removal of third-country nationals (art.23 § 6 L. 3907/11 and Joint Ministerial Decree 4000/4/57 − ia/24-10-2014), and investigating the arbitrary behaviour of law enforcement officials (Law 4443/2016, Part D, entry into force 9.6.2017) (Fili and Bosworth, forthcoming 2019). [38]The Ombudsman’s annual reports contained sections on the NPM’s work (https://www.synigoros.gr/resources/annual_report_2017_site.pdf) and a 2018 report on the ‘Return of Third Country Nationals’ had also been published (https://www.synigoros.gr/resources/docs/english-final.pdf). 20

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