20. a. That the Reviewers undertake a comprehensive review of New Zealand’s intelligence and security legislation for consistency with international human rights law and norms. b. That the Reviewers consider ways in which the clarity, accessibility and structure of New Zealand’s intelligence and security legislation can be improved. c. The Commission recommends that the Reviewers consider the implications that inclusion of the right to privacy in the New Zealand Bill of Rights Act would have for intelligence and security law, policy and operations. d. That the Reviewers investigate the implications of consolidating the NZ legislative framework into a unified structure. e. That the Reviewers investigate the implications of developing a statutory Code of Practice for ensuring human rights compliance by intelligence and security agencies. f. The Commission recommends that the Reviewers consider statutory mechanisms (such as a statutory Code of Practice) for requiring human rights training for intelligence and security officials. g. That that the Reviewers investigate current and potential measures which enable oversight mechanisms to assess intelligence and security practices against New Zealand’s domestic and international human rights obligations. h. That the Reviewers investigate the implications of consolidating current oversight roles and functions into an independent centralised judicial entity such as an Intelligence and Security Commission. The Commission’s position is set out in more detail below under the following sections, based on the terms of reference of the Review:  Part A: Concerning the adequacy of the current legislative framework to protect NZ’s current and future national security, while protecting individual rights.  Part B: Concerning the current oversight arrangements and whether these provide sufficient safeguards at an operational, judicial and political level to ensure that NZSIS and GCSB act lawfully and maintain public confidence. Page 82 of 93 Human Rights Commission submission to the Human Rights Committee in relation to New Zealand’s 6th periodic review under the ICCPR