New Zealand Human Rights Commission Submission to the CAT in relation to NZ’s 6th periodic review and secure facilities. Key Issues:  Lack of resources to undertake OPCAT work for some NPMs;  Lack of specific expertise in some areas; and  A number of places where people are deprived of their liberty are not currently monitored by the OPCAT mechanism. Recommended actions: The Commission recommends that:  funding levels should be increased without delay to cover the actual costs of OPCAT work of NPMs, where the appropriation for OPCAT work is less than the actual costs of that work, and to enable NPMs to carry out more site visits and to establish a coordinated mechanism to engage the services of experts to assist with those visits; and  the Government commit to reviewing the scope of the OPCAT mandate in New Zealand with a view to identifying ways to address the gaps in monitoring all places where people are deprived of their liberty. Any increase in scope would need to be properly funded. 55. An overarching challenge that some NPMs have struggled with, is the resources available for OPCAT monitoring. Since ratification of the OPCAT, NPMs have received very limited additional resourcing to carry out their OPCAT functions. To manage within the funding available, NPMs have smaller visit teams and undertake visits with less frequency than they would like (or believe is envisioned by the OPCAT. 56. The Children’s Commissioner, for example, has received no funding for taking on its NPM role, which it has funded from other work streams. The funds allocated to the IPCA cover 34 percent of their respective OPCAT costs, and in the past they have also covered the difference, but more recently have reduced their NPM activities to 22