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Appendix 4: continued

Healthcare (see Chapter D.8 in Volume II)

RecommendationReport Reference in this Report
82All health care staff should be trained in the recognition and treatment of victims of torture. (para 5.44, p48)Report on a Full  Announced Inspection of  Brook House Immigration Removal Centre, 1519 March 2010, HM Chief Inspector of Prisons, July 2010
83Mechanisms need to be established for improving the working relationship with external stakeholders in order to make use of experiences, suggestions and actions that will promote the mental welfare of detainees. (recommendation 11, para 4.13)Review of Mental Health  Issues in Immigration  Removal Centres, Dr David Lawlor, Dr Mannie Sher and Dr Milena Stateva, 9 February 2015 
84I note that DSO [Detention Services Order] 03/2013 on food and fluid refusal is currently the subject of internal review within the Home Office. I recommend that the review consider alternatives to treatment within a prison or IRC in light of my discussion of this issue. (recommendation 24, p194)Review into the Welfare  in Detention of  Vulnerable Persons, Stephen Shaw, Cm 9186, January 2016The 2016 Shaw report
85The Home Office and NHS England should conduct a clinical assessment of the level
and nature of mental health
concerns in the immigration
detention estate.
(recommendation 55, p180)
Review into the Welfare
in Detention of
Vulnerable Persons,
Stephen Shaw, Cm 9186,
January 2016
The 2016 Shaw report
86I recommend that talking therapies become an intrinsic
part of healthcare provision in
immigration detention.
(recommendation 57, p181)
Review into the Welfare
in Detention of
Vulnerable Persons,
Stephen Shaw, Cm 9186,
January 2016
The 2016 Shaw report
87A health needs assessment should be carried out and a centre health and well-being strategy should be developed. (para 2.40, p36)Report on an  Unannounced Inspection  of Brook House  Immigration Removal  Centre, 31 October– 11 November 2016, HM Chief Inspector of Prisons, March 2017The 2016 HMIP inspection report
88Problems with recruitment and retention across the IRC workforce must be addressed in order to prevent staff shortages negatively affecting the health and wellbeing of detained individuals. (recommendation 3, p60)Locked Up, Locked Out:  Health and Human Rights in Immigration  Detention, British Medical Association, September 2017 
89Doctors should never be involved in disciplinary or non- therapeutic activities within IRCs. (recommendation 5, p61)Locked Up, Locked Out:  Health and Human Rights in Immigration  Detention, British Medical Association, September 2017 
90A best practice forum should be established across IRC healthcare providers. (recommendation 16, p56)Assessment of  Government Progress in  Implementing the Report on the Welfare in  Detention of Vulnerable  Persons, Stephen Shaw, July 2018The 2018 Shaw follow-up report
91Healthcare and G4S management should ensure that nurses involved in control and restraint understand their role and responsibilities. This should be as part of their induction and refreshed yearly. (recommendation 43, p38)Independent  Investigation into  Concerns about Brook  House Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
92To G4S Health Services Ltd: … Staff recruitment and retention to be kept as a priority. (p5)Annual Report of the  Independent Monitoring  Board at Brook House  IRC for Reporting Year  2018, Brook House Independent Monitoring Board, June 2019
93There should be regular training for all Home Office and healthcare staff on early indicators of mental health conditions and the circumstances in which capacity assessments should be triggered. This should be linked to safeguarding training … (para 9, p19)Detention of People with  Mental Disorders in  Immigration Removal  Centres (IRCs), Royal College of Psychiatrists, April 2021
94Review the purpose and use of the Part C process, including clarifying and confirming the roles and responsibilities of Home Office staff and suppliers and the value of enabling Part Cs to be attached to electronic healthcare records. (para 4.6.i, p12)Second Annual  Inspection of ‘Adults at  Risk in Immigration  Detention’, July 2020– March 2021, Independent Chief Inspector of Borders and Immigration, October 2021

Staffing and culture (see Chapter D.9 in Volume II)

RecommendationReportReference in this Report
95I recommend that GSL [Global Solutions Ltd (predecessor to G4S at Brook House)] reviews its staff training in respect of handling and defusing confrontation. (recommendation 38, p385)Report of the Inquiry into the Disturbance and Fire  at Yarl’s Wood Removal  Centre, Stephen Shaw, Prisons and Probation Ombudsman, November 2004
96I recommend that GSL reviews its management training to emphasise the need for managers to be visible, accessible and responsive. (p293)Report of the Inquiry into the Disturbance and Fire  at Yarl’s Wood Removal  Centre, Stephen Shaw, Prisons and Probation Ombudsman, November 2004 
97I recommend that GSL reorganises its ITC [Initial Training Course] to ensure that race relations training informs the whole of the course. (recommendation 7, p107)Inquiry into Allegations  of Racism and  Mistreatment of  Detainees at Oakington  Immigration Reception  Centre and While Under  Escort, Stephen Shaw, Prisons and Probation Ombudsman, July 2005The 2005 Shaw report
98I recommend that GSL
develops a training package for
newly promoted managers
which should cover amongst
other things leadership, giving positive and negative feedback,
and effective supervision of
staff. (recommendation 15,
p108)
Inquiry into Allegations
of Racism and
Mistreatment of
Detainees at Oakington
Immigration Reception
Centre and While Under
Escort, Stephen Shaw,
Prisons and Probation
Ombudsman, July 2005
99Alongside the contractors, I
recommend IND considers
establishing a zero-tolerance
campaign across the detention
estate, with appropriate
posters and literature, to
remind staff of the expected
standards of conduct.
(recommendation 20, p108)
Inquiry into Allegations
of Racism and
Mistreatment of
Detainees at Oakington
Immigration Reception
Centre and While Under
Escort, Stephen Shaw,
Prisons and Probation
Ombudsman, July 2005
The 2005 Shaw report
100Detainee custody officers should be supported to develop positive relationships with detainees in their care, and all new and inexperienced staff should have mentors as part of a formal mentoring scheme. (para 10.6, p75)Report on a Full  Announced Inspection of  Brook House Immigration Removal Centre, 15–19  March 2010, HM Chief Inspector of Prisons, July 2010
101The Home Office should ensure that the behaviour management elements of the NOMS [National Offender Management Service] training are consistent with the initial training for DCOs. [Detention Custody Officers] (p60)Report of the  Independent Advisory  Panel on Non-Compliance Management, Independent Advisory Panel on Non-Compliance Management, March 2014
102Managers at Yarl’s Wood should put in place a programme of organisational development work involving all staff, to develop a clearer and better shared understanding of the centre’s mission, role and purpose, and the cultures and arrangements, including staffing arrangements, that will ensure the appropriate care of Yarl’s Wood’s residents. Such a programme should allow staff to share their insights and engage them in devising plans for how the centre will be managed in the best interests of residents and staff. (recommendation 5, p72)Independent  Investigation into  Concerns about Yarl’s  Wood Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), January 2016
103Managers undertaking the current review of staffing should rectify the problems
with management capacity.
(recommendation 10, p111)
Independent
Investigation into
Concerns about Yarl’s
Wood Immigration
Removal Centre, Ms Kate
Lampard and Mr Ed
Marsden (Verita),
January 2016
104The new governance structure
should redefine lines of
responsibility for all managers
and include … stronger
appraisal and supervision arrangements so that the work of all staff members is
rigorously supervised,
particularly those in middle management positions (i.e.
those currently in DOM
[Detention Operations
Manager], RSM [Residential
Service Manager] and Team Leader positions) and that these staff members benefit
from relevant ongoing training and continued professional
development in childcare, behavioural management and
supervision.
(recommendation 4, p27)
Medway Improvement
Board: Final Report of
the Board’s Advice to
Secretary of State for
Justice, Dr Gary Holden,
Bernard Allen, Sharon
Gray and Emily Thomas,
Medway Improvement
Board, 30 March 2016
105Mental health awareness training should be mandatory
for all new IRC staff as part of their induction and all staff should have mandatory annual
update training. (p5)
Immigration Removal
Centres in England: A
Mental Health Needs
Analysis, Dr Graham
Durcan, Jessica Stubbs
and Dr Jed Boardman,
Centre for Mental Health,
January 2017
106We recommend that public sector employers should identify employees at higher risk of stress or trauma and produce a national framework which coordinates support for these employees and establishes clear accountability for their mental health.
(para 20, p10)
Thriving at Work: The  Stevenson / Farmer  Review of Mental Health  and Employers, Dennis Stevenson and Paul Farmer, October 2017
107Advanced mental health training for staff who interact with vulnerable detainees. (p5; repeated in 2018 and 2019)Annual Report of the Independent Monitoring Board at Brook House
IRC for Reporting Year  2017, Brook House Independent Monitoring Board, May 2018
The 2017 IMB report
108Require increase in staffing levels in future contracts to ensure greater presence of operational staff and managers on detainee wings. (p5)Annual Report of the Independent Monitoring Board at Brook House
IRC for Reporting Year  2017, Brook House Independent Monitoring Board, May 2018
The 2017 IMB report
109Staff recruitment and retention to be kept as a priority. (p5)Annual Report of the Independent Monitoring Board at Brook House
IRC for Reporting Year  2017, Brook House Independent Monitoring Board, May 2018
The 2017 IMB report
110I recommend that IRC staff who have regular contact with detainees should receive mandatory safer detention training on an annual basis. (recommendation 36, p98)Assessment of Government Progress in Implementing the Report                            on the Welfare in Detention of Vulnerable
Persons, Stephen Shaw, July 2018
The 2018 Shaw follow-up report
111The SMT should be more present in the centre and should consider how they can better engage with staff. (recommendation 1, p77)Independent  Investigation into  Concerns about Brook  House Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
112The SMT must ensure that DCMs [Detention Custody Managers] are given adequate training to fulfil the tasks and responsibilities of their role. (recommendation 2, p86)Independent  Investigation into  Concerns about Brook  House Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
113G4S managers should undertake a comprehensive review of matters affecting staff retention at Brook House including remuneration, shift patterns and working hours and G4S needs to develop plans to address the matters arising from such a review. (recommendation 7, p38)Independent  Investigation into  Concerns about Brook  House Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
114The SMT should ensure that staff dealing regularly with detainees with mental health problems or with drugs or other substance misuse issues receive specialist training. (recommendation 15, p37)Independent  Investigation into  Concerns about Brook  House Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
115The safeguarding team should survey staff at Brook House regularly to ascertain their experience of and perspective on violence and bullying and its causes. (recommendation 48, p36)Independent
Investigation Concerns about Brook House Immigration
Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018
  The 2018 Verita report

Complaints and whistleblowing (see Chapter D.10 in Volume II)

RecommendationReportReference in this Report
116I recommend that the whistleblowing policy be ‘talked up’ during initial training and further endorsed during subsequent training. (recommendation 13, p107)Inquiry into Allegations  of Racism and  Mistreatment of  Detainees at Oakington  Immigration Reception  Centre and While Under  Escort, Stephen Shaw, Prisons and Probation Ombudsman, July 2005The 2005
Shaw report
117Managers should undertake a
review of present local policies and arrangements for
whistleblowing and reporting matters of concern. They should devise policies and
arrangements that are easily understood by staff, command
the confidence of staff and encourage and support them to
report colleagues whose
behaviours are inappropriate or
below standard.
(recommendation 8, p28)
Independent
Investigation into
Concerns about Yarl’s
Wood Immigration
Removal Centre, Ms Kate
Lampard and Mr Ed
Marsden (Verita),
January 2016
118Policy for whistle-blowing and acting on information received from whistle-blowers needs to be redeveloped in both YJB [Youth Justice Board] and within the STC [Secure Training Centre] and it must ensure that whistle-blowers feel supported and listened to. (recommendation 10, p43)Medway Improvement  Board: Final Report of  the Board’s Advice to  Secretary of State for  Justice, Dr Gary Holden, Bernard Allen, Sharon Gray and Emily Thomas, Medway Improvement Board, 30 March 2016 
119All whistle-blowing communication must be made available to the Governing Board on a monthly basis. (recommendation 11, p43)Medway Improvement  Board: Final Report of  the Board’s Advice to  Secretary of State for  Justice, Dr Gary Holden, Bernard Allen, Sharon Gray and Emily Thomas, Medway Improvement Board, 30 March 2016 
120The SMT and G4S managers should review the policy and arrangements for raising concerns and their own handling of such matters to ensure that they encourage and support staff to report wrongdoing or misconduct or inappropriate behaviour by colleagues and managers. (recommendation 51, p227)Independent Investigation into Concerns about Brook House Immigration Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
121The SMT should ensure that a single log is kept of all allegations or instances of misconduct by staff and the actions taken in respect of them. (recommendation 52, p228)Independent  Investigation into  Concerns about Brook  House Immigration  Removal Centre, Ms Kate Lampard and Mr Ed Marsden (Verita), October 2018The 2018 Verita report
122The Home Office must take immediate steps to ensure that all IRCs have robust and effective whistleblowing procedures in place which IRC staff and detainees can use with complete confidence, knowing that they will be fully protected. IRC managers should ensure that both staff and detainees are regularly made aware of the whistleblowing procedures, providing clear written and verbal explanations of what the policy is for, with user friendly whistleblowing toolkits and publicity made available across the IRC. Staff and detainees should also be given explicit reassurance that they would be supported if they raised concerns about any wrongdoing or misconduct they witnessed. Failure to do so may result in further abuses across the immigration detention estate. (para 256, p82)Immigration Detention: Fourteenth Report of Session 2017-19, House of Commons Home Affairs Committee, HC 913, 21 March 2019 The Home Affairs Select Committee 2019 report
123Managers should investigate and address the reasons for detainees’ low confidence in the complaints system (para S48, p54)Report on an Unannounced Inspection of Brook House Immigration Removal Centre, 20 May-7 June 2019, HM Chief Inspector of Prisons, September 2019 The 2019 HMIP inspection report
124The Home Secretary should comission an urgent review of BICS [Borders, Immigration and Citizenship System] complaints procedure. Options could include establishing an Independent Case Examiner as a mechanism for immigration and nationality applicants to have their complaints reviewed independently of the department.
(recommendation 20, p147)
Windrush Lessons Learned Review, Wendy Williams, March 2020

Inspection and monitoring (see Chapter D.11 in Volume II)

RecommendationReportReference in this Report
125There should be a system of independent oversight of independent oversight for the operation of detention officers (DCOs) and immigration escorts. (p4)Outsourcing Abuse: The Use and Misuse of State- Sanctioned Force During the Detention and
Removal of Asylum  Seekers, Birnberg Peirce & Partners, Medical Justice and the National Coalition of Anti- Deportation Campaign, July 2008
126Independent Monitoring Boards should … work transparently and engage with visitors and groups. (p5)Outsourcing Abuse: The Use and Misuse of State- Sanctioned Force During the Detention and
Removal of Asylum  Seekers, Birnberg Peirce & Partners, Medical Justice and the National Coalition of Anti- Deportation Campaign, July 2008
127I recommend that the Home Office consider if the inspection arrangements for IRCs can ensure the involvement of the ICI [Independent Chief Inspector of Borders and Immigration]. (recommendation 43, p196)Review into the Welfare in Detention of Vulnerable Persons, Stephen Shaw, Cm 9186, January 2016The 2016 Shaw report
128The Home Office should review with the Ministry of Justice the resource allocated to each IM [Independent Monitoring Board] in the immigration detention estate. (recommendation 39, p126)

Monitoring Board] in the immigration detention estate. (recommendation 39, p126)
Assessment of Government Progress in Implementing the Report on the Welfare in Detention of Vulnerable Persons, Stephen Shaw, July 2018The 2018 Shaw follow-up report
129The Subcommittee recommends that the authorities of the United Kingdom review the statutes of the Independent Monitoring Boards and the lay observers to ensure their full independence and to prevent actual or potential conflicts of interest in their roles within the national preventive mechanism. (para 41)Visit to the United Kingdom of Great Britain and Northern Ireland Undertaken from 9 to 18 September 2019: Recommendations and Observations Addressed to the State Party, Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, 26 February 2020
130The Subcommittee recommends that NPM [National Preventive Mechanism] of UK take steps to enhance its cooperation and channels of communication with CSOs [civil society organisations], for example through an annual forum or other avenues, and strive to maintain a proactive dialogue with the civil society. Regarding concerns expressed by the NPM, the Subcommittee recommends that the NPM
involve NGOs [non-governmental organisations] in its work in a transparent manner and strictly from the perspective of prevention of torture. (para 77, p12)
Visit to the United Kingdom of Great Britain and Northern Ireland Undertaken from 9 to 18 September 2019: Recommendations and Observations Addressed to the National Preventive Mechanism,
Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, 26 February 2020
131Despite the inherited complex nature of the NPM, the SPT
[Subcommittee on Prevention of Torture and Other Cruel,
Inhuman or Degrading Treatment or Punishment]
recommends that the NPM take proactive steps aiming at
transforming itself into a more cohesive preventive body.
(para 109, p16)
Visit to the United Kingdom of Great Britain and Northern Ireland Undertaken from 9 to 18 September 2019: Recommendations and Observations Addressed to the National Preventive Mechanism,
Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, 26 February 2020
132The Home Secretary should introduce a Migrants’ Commissioner responsible for speaking up for migrants and those affected by the system directly or indirectly. The commissioner would have a responsibility to engage with migrants and communities, and be an advocate for individuals as a means of identifying any systemic concerns and working with the government and the Independent Chief Inspector of Borders and Immigration to address them. (recommendation 9, p142)Windrush Lessons  Learned Review, Wendy Williams, March 2020
133The Home Office should establish a central repository for collating, sharing and overseeing responses and activity resulting from external and internal reports and recommendations, and adverse case decisions. This will make sure lessons and improvements are disseminated across the organisation and inform policy- making and operational practice. (recommendation 16, p145)Windrush Lessons  Learned Review, Wendy Williams, March 2020
134It recommends that the authorities of the United Kingdom take such steps as may be necessary to ensure that the NPM [National Preventive Mechanism] is fully in compliance with OPCAT [Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment] requirements, notably the requirement for statutory recognition of the NPM. (para 8, p12)Report to the United  Kingdom Government on  the Visit to the United  Kingdom Carried Out by  the European Committee  for the Prevention of  Torture and Inhuman or  Degrading Treatment or  Punishment (CPT) from  13 to 23 May 2019,
European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment, 30 April
2020
135Senior civil servants in the Home Office must promote a genuine learning culture that actively seeks to act on the evidence of system failures. (recommendation 28, p43)Beyond Belief: How the  Home Office Fails  Survivors of Torture at  the Asylum Interview, Freedom From Torture, 16 June 2020

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