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D.5 Safeguards for vulnerable individuals


  1. There are a number of provisions that seek, collectively, to provide safeguards for those individuals who may be vulnerable to suffering harm in detention.

1.1 Rule 34 and Rule 35 of the Detention Centre Rules 2001 (the Rules) require a physical and mental examination by a medical practitioner within 24 hours of admission to a detention centre, as well as a report where the health of a detained person is likely to be injuriously affected by continued detention or any conditions of detention, where the medical practitioner suspects that a detained person has suicidal intentions or where there is a concern that a detained person may have been a victim of torture.1

1.2 The Home Office’s statutory Guidance on adults at risk in immigration detention (Adults at Risk policy) specifies the matters to be taken into account in accordance with section 59 of the Immigration Act 2016 when determining the detention of vulnerable people.2

1.3 Detention Services Order 08/2016: Management of Adults at Risk in Immigration Detention (the Adults at Risk DSO) includes mandatory guidance for Home Office staff and suppliers operating in immigration removal centres (IRCs) on the care and management of detained people deemed to be adults at risk while in detention.3

1.4 Detention Services Order 01/2022: Assessment Care in Detention and Teamwork (ACDT) (the ACDT DSO) provides mandatory operational guidance for all Home Office, centre supplier and healthcare staff working in IRCs, to implement “a holistic approach to self harm and suicide prevention within the broader context of decency and safety”.4

  1. The purpose of these safeguards is to consistently identify those who may be vulnerable and at risk of harm:

“The clear presumption is that detention will not be appropriate if a person is considered to be ‘at risk’ … detention will only become appropriate at the point at which immigration control considerations outweigh this presumption. Within this context it will remain appropriate to detain individuals at risk if it is necessary in order to remove them.”5

  1. The safeguards provided by the Rules and policies recognise in this way that vulnerable people should not be detained inappropriately. The safeguards put in place by the Home Office must be implemented properly. Failure to do so is a breach of the legal requirements and will likely cause harm to some detained people.
  2. The healthcare service was and is an NHS-commissioned service on behalf of the Home Office, provided entirely separately from the contract to manage Brook House.
  3. G4S Health Services (UK) Ltd (G4S Health Services) held the contract for the provision of healthcare services in Brook House from September 2014 until 31 August 2021, including during the relevant period (1 April 2017 to 31 August 2017).6 Practice Plus Group (PPG) took over this contract in September 2021.7
  4. GP services in Brook House were provided by Doctor PA Ltd under a subcontract with G4S Health Services in the relevant period and with PPG from 1 September 2021.8


  1. Detention Centre Rules 2001. These provisions are reinforced in the Detention Services Operating Standards Manual for Immigration Service Removal Centres, January 2005, pp38-39[]
  2. Immigration Act 2016: Guidance on Adults at Risk in Immigration Detention, Home Office, August 2016 (first published May 2016 and subsequently updated, most recently in March 2022); see Adults at Risk policy; section 59 of the Immigration Act 2016[]
  3. Detention Services Order 08/2016: Management of Adults at Risk in Immigration Detention (CJS000731), Home Office, February 2017 (updated August 2022[]
  4. Detention Services Order 01/2022: Assessment Care in Detention and Teamwork (ACDT) (INQ000214), Home Office, October 2022, p5[]
  5. CJS007082_004[]
  6. CJS0074040_002 paras 6-11. The contract was initially held by G4S Medical and Forensic Services (UK) Ltd, which changed its name to G4S Health Services (UK) Ltd in October 2016[]
  7. PPG000182[]
  8. CJS0073870; PPG000040. The Inquiry was told that PPG intends to move towards an employed GP model (PPG000169_010 paras 43 and 44[]