Mr. Se?n Beatty:

I thank Deputy Pringle for that question. We refer to Article 4 of OPCAT, which defines "places of detention" as any place where persons are or may be deprived of their liberty. In interpreting that, I will quote a short piece that is material to this from the subcommittee on the prevention of torture. In its annual report of 2013 it stated: "the term “places of detention”, as found in article 4 of the Optional Protocol, should be given a broad interpretation, to include, inter alia, civil and military prisons, police stations, pretrial detention centres, psychiatric institutions and mental health centres, migrant detention centres, juvenile detention centres and social care institutions". It goes on to say: "Therefore, an interpretation of “places of detention” that is limited to such traditional places of deprivation of liberty as prisons would be overly restrictive and, in the view of the Subcommittee, clearly contrary to the Optional Protocol." It is crucial, therefore, that the committee considers those non-traditional places of detention and considers whether, factually, liberty is being deprived. As currently constructed. the general scheme of the Bill is clearly contrary to OPCAT.