There are various safeguards within the clause that help to protect against arbitrary and excessive interferences. There is a requirement of reasonable suspicion that, although low, does place a limit on when the powers can be exercised. The powers are only to be used once per entry, when an irregular migrant is encountered,113 such that the checks cannot be excessive in number. Searches of a person cannot require the removal of anything other 107 Clause 20(3) 108 Clause 20(9) 109 Clause 21(6) 110 Clause 22 111 R (HM) v Secretary of State for the Home Department [2022] EWHC 695 (Admin) 112 Naumenko v Latvia, Application No. 50805/14, 23 June 2022, para 50; Gillan and Quinton v UK, Application No. 4158/05, 12 January 2010; Beghal v UK, Application No. 4755/16, 28 February 2019; R (Roberts) v Metropolitan Police Commissioner [2015] UKSC 79 113 Clause 20(2) 31 than outer clothing. Any item seized will have to be returned when it is no longer necessary for an authorised officer or the Secretary of State to retain it, subject to the duty to pass on items seized. These are likely to amount to adequate safeguards against arbitrary interference.