proportionate to a legitimate purpose in each individual case, requiring the application of alternative measures prior to any use of detention. However, such alternative measures remain underused and underexplored in the immigration context. A wide range of community-based alternatives to detention exist, such as partnerships with NGOs to provide specialized assistance, information, legal provision and case management, that make the use of immigration-related detention unnecessary. These models have achieved high levels of compliance with immigration procedures, while ensuring the rights, dignity and wellbeing of migrants. The CDCJ should further emphasize States’ obligation to give priority consideration to the application of alternative measures to detention before resorting to any administrative immigration-related detention. This could be achieved, for example, by making more explicit reference to, and aligning approaches with, the current work of the CDDH-MIG to elaborate an Analysis of the Legal and Practical Aspects of Effective Alternatives to Detention in the Context of Migration, as well as by drawing upon the expertise of national, regional, and international experts on the effective implementation of alternatives to immigration detention, such as the International Detention Coalition (IDC), or the European Alternatives to Detention Network. 5. Strengthen safeguards regarding access to and monitoring of places of immigration detention Regular access to and monitoring of places of immigration detention by independent bodies is a critical safeguard against arbitrary detention and illtreatment. Risks of human rights violations, including torture or ill-treatment increase when the conditions and treatment of persons held in immigration detention are not regularly and independently monitored. Depending on their mandate and purpose of monitoring, various institutions at national, regional and international levels may carry out immigration detention monitoring. With a mandate established under the UN Optional Protocol to the Convention against Torture, National Preventive Mechanisms are in a unique position to monitor places of immigration detention and prevent human rights violations. In addition to recognizing the importance of monitoring bodies’ unrestricted access to all places of immigration detention, the draft instrument should also strengthen the guarantees of confidential and free communication with migrants as well as protection against the risk of reprisals suffered by migrants or any other person who engaged with monitors. The CDCJ should take steps to strengthen these protections by reference to, among other things, the guidance provided by UNHCR, the Association for the Prevention of Torture, and the International Detention Coalition on monitoring places of immigration detention. Signed by: 1. aditus foundation 2. AITIMA 3. Amnesty International 4. Association For Legal Intervention 5. Association for the Prevention of Torture (APT) 4