Part II: Preventing torture: NHRIs in action and standards, and the practices that are found in detention – work which requires an in-depth understanding of what is happening in detention, built on in-depth visits to places of deprivation of liberty. Undertaking the role of NPM therefore requires a change of mindset for the NHRI. The NHRI should take time to reflect on the new mandate and ensure that all staff members have a clear understanding of the preventive approach. 2.2.4 Internal structure When the NHRI is designated as NPM, it is advisable to establish a dedicated unit or department within the NHRI headed by a senior figure to take on this preventive function. This can help the NPM focusing its full attention on preventive work and avoid confusion among the authorities or detainees about the specific mandate of the NPM. While one department of an NHRI may be responsible for the NPM work, designation means that the NHRI as a whole “is” the NPM and not only one department (although some exceptions do exist). While the NPM department should be granted operational autonomy, it should also be integrated into the broader institution, including with a system of regular interaction and cooperation with other departments. Such cooperation may cover: complaints and how they are collected, transferred and investigated; visits to places of detention; thematic issues relevant to the whole institution; training and education; communication; and law reform. Insights from practice: Estonia ratified the Optional Protocol in 2006 and designated its Ombudsperson’s Office (Office of the Chancellor of Justice) as NPM. It started its operations as NPM in 2007, the NPM mandate being implemented by three thematic units. In 2015, a new department - the Inspection Visits Department - was created to carry out the NPM tasks and increase the efficiency of the work. 2.2.5. Handling complaints While undertaking their preventive work – during and beyond visits to places of detention –NPMs will hear allegations of torture and ill-treatment and receive complaints related to treatment, conditions or other situations in detention. Although NPMs should not focus on documenting these cases, they constitute important indicators of systemic problems and a valuable source of information for NPMs’ work. Therefore, it is important that NPMs are able to keep record and systematise all complaints received, to be able to identify patterns and integrate them in the NPMs’ overall strategy. NHRIs that are designated as NPMs should have a clearly defined process in place for the NPM to refer serious cases and the complaints received to the relevant unit within the NHRI (the complaints or investigations unit) and for the complaints unit to share the complaints related to places of detention to the NPM. 2.2.6. Composition In order to conduct effective preventive work, NPMs need to have dedicated staff with expertise from diverse professional backgrounds. Some NHRIs may already have a mix of relevant professional skills and training. However, many NHRIs are predominantly made up of lawyers and lack expertise in certain areas, especially in the medical field. It is therefore key for NPMs to be able to recruit new staff 137