NIHRC Consultation Response: Submission to Committee for Health on the Adult Protection Bill
Last Updated: Wednesday, 1 October 2025
Date produced: September 2025
Below is a summary of the Northern Ireland Human Rights Commission's (NIHRC) recommendations and messages.
You can also download the full document through the links provided.
Summary recommendations/messages
The NI Human Rights Commission recommends that:
- the Committee brings forward an amendment to clause 1 of the Bill to include a reference to the human rights obligations of those exercising functions provided for in the Bill.
- adequate resources are allocated to ensure that people with powers and duties under the Bill are trained so that they understand the human rights implications of their work and operate consistently within a human rights-based approach.
- Part 2 of the Bill sets out minimum procedural standards for serious case reviews, including requirements for independence, timeliness, public scrutiny, and involvement of the next-of-kin, in accordance with Article 2 of the ECHR.
- the Committee amend Part 4 of the Bill to include an explicit reference to the European Convention on Human Rights and the EU General Data Protection Regulation in relation to the development and monitoring of regulations for the installation and use of CCTV systems in prescribed premises. This should include a requirement that a human rights impact assessment and analysis of compliance with Windsor Framework Article 2 be conducted before determining whether a CCTV system is installed.
- the Committee amend Clause 44 of the Bill to require that the regulations relating to the installation and use of CCTV in prescribed premises contain procedures for regular monitoring and review. This should take account of the relevant data protection standards laid out in EU General Data Protection Regulation and include periodic reassessment of the necessity and proportionality of surveillance measures, and the continued evaluation of the impact of CCTV on residents, staff and visitors.
- Clauses 45-47 of the Bill require RQIA to consider the necessity and proportionality of CCTV systems when exercising its monitoring and enforcement functions under Part 4.
Open the PDF version here.

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