224 NPMs strongly argue that persons in such facilities or situations can effectively be in a state of detention, which means these places should be subject to preventive monitoring under OPCAT.126 The Commission would welcome the Committee’s guidance on these issues. F Transgender people in detention 225 The Commission has previously raised concerns that transgender prison inmates are particularly vulnerable to abuse and/or sexual assault. Partly this was because they were housed according to their biological sex unless they had completed gender reassignment surgery. 226 In late 2014 the Department of Corrections broadened the criteria used to determine the gender identity of a prisoner and to ensure appropriate assignment to a prison that matches that gender. In October 2015 Corrections reported that there were up to 20 transgender people in NZ prisons.127 The majority of these were, and continue to be, trans women.128 227 However, despite these policy changes issues still remain. These include abuse of wrongly placed (predominately female) prisoners; using solitary confinement as a way of protective segregation; lack of or slow response to, applications for transfer after/during transition; lack of access to health and rehabilitation services and abuse under search and detention policies that do not recognise their gender identity. 228 The Commission has been informed that there remains a lack of understanding of the new policy/procedures (by Corrections personnel and trans people), and few suitably trained Corrections staff to ensure effective implementation. 229 The Commission recommends that the Committee urges the Government to commit to:   reviewing – in collaboration with the trans community – the current policy and practices; and ensuring all Corrections staff are appropriately trained and supported in the implementation of these policies. 126 See also CRPD General comment No.1, p.10. This does not include transgender people that are in immigration detention centers 128 Corrections' deputy national commissioner Rachel Leota in a statement to Radio New Zealand (October 7) 127 Page 60 of 93 Human Rights Commission submission to the Human Rights Committee in relation to New Zealand’s 6th periodic review under the ICCPR