72. Still, to define what should be understood as “torture” in light of the provisions of Article 5(2) of the American Convention, according to the Court’s case law, an act constitutes torture when the ill-treatment: (a) is intentional; (b) causes severe physical or mental suffering, and (c) is committed with a specific purpose or objective.58 73. In addition, the Court has indicated that the violation of an individual’s right to physical and mental integrity has different levels that range from torture to other types of abuse or cruel, inhuman or degrading treatment, the physical and mental consequences of which vary in intensity according to factors that are endogenous and exogenous to the individual (such as, duration of the treatment, age, sex, health, context, and vulnerability), which must be analyzed in each specific situation.59 74. Regarding the use of force by the security forces, this Court has indicated that this must respect criteria of legitimate reasons, need, appropriateness and proportionality.60 Furthermore, the Court has indicated that any use of force that is not strictly necessary owing to the behavior of the person detained constitutes an attack on human dignity, in violation of Article 5 of the American Convention.61 75. In this case, Mr. Fleury was subjected to the following acts (supra paras. 34 and 36): (a) he was threatened at the time of his arrest; (b) he was taken by the throat by one of the policemen to force him to get into the truck in which he would be taken away detained, even though he was not resisting in any way; (c) at the time of his arrest he was hit in the face with a gun and hit on the head, ill-treatment that continued during the ride to the police station, and (d) during his detention he was obliged to clean the excrement in the cell in which he was detained with his bare hands as a form of humiliation, and received, approximately 64 blows to his head and the rest of his body, by kicks and using objects, and 15 severe simultaneous blows on both sides of the head (“kalot marassa”). As a result of this ill-treatment, Mr. Fleury suffered bruising mainly on his back and leg and other bruises on his whole body. In addition, his left arm and leg were fractured and he suffered a perforated eardrum as a result of the beatings. 76. As indicated, these acts took place in a context of public insecurity and the institutional shortcomings of the Haitian National Police, which was found to be involved in Guidelines on human rights and the fight against terrorism adopted by the Committee of Ministers of the Council of Europe, Guideline IV. 57 Article 3 common to the four Geneva Conventions; Geneva Convention relative to the Treatment of Prisoners of War (Convention III), Arts. 49, 52, 87, 89 and 97; Geneva Convention relative to the Protection of Civilians in Time of War (Convention IV), Arts. 40, 51, 95, 96, 100 and 119; Protocol Additional to the Geneva Conventions of 12 August 1949 and relating to the Protection of Victims of International Armed Conflicts (Protocol I), Art 75(2)(ii), and Protocol Additional to the Geneva Conventions of 12 August 1949 and relating to the Protection of Victims of Non-International Armed Conflicts (Protocol II), Article 4(2)(a). 58 Cf. Case of Bueno Alves v. Argentina. Merits, reparations and costs. Judgment of May 11, 2007. Series C No. 164, para. 79, and Case of Fernández Ortega et al. v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of August 30, 2010. Series C No. 215, para. 120. 59 Cf. Case of Loayza Tamayo v. Peru, supra note 23, paras. 57 and 58, and Case of Torres Millacura et al. v. Argentina, supra note 17, para. 86. 60 Cf. Case of Montero Aranguren et al. (Retén de Catia) v. Venezuela. Merits, reparations and costs. Judgment of July 5, 2006. Series C No. 150, paras. 67 to 69, and Case of Zambrano Vélez et al. v. Ecuador. Merits, reparations and costs. Judgment of July 4, 2007. Series C No. 166, paras. 83 to 85. 61 Cf. Case of Loayza Tamayo v. Peru, supra note 23, para. 57 and Case of Cabrera García and Montiel Flores v. Mexico, supra note 45, para. 133. 21