Mr. Nick Henderson:

My understanding is that as far as we know the second instance body will not have an advisory board. The inspector of the board of procedure has that advisory board. We refer to and rely on the submission of the human rights commission on the second instance inspectorate. It has significant concerns, to the degree that it would have to consider whether it will participate in the mechanism. In our submission we noted there was no NGO on the advisory board. This goes to the point on our experience as organisations. It would be healthy for the board to have the participation of an organisation and a representative with lived experience. There are also issues with the relationship with other monitoring bodies. We also recommend the Bill should align with the inspection of places of detention Bill. While on first view the chief inspector is apparently one of the critical safeguards for human rights within the pacts, the devil is in the detail. It is very important that we scrutinise the detail and ensure it is soundly managed and has sufficient independence. A key part of this is the advisory board. This would need to be closely scrutinised.