AVID’s AGM - Thirty Years of Bearing Witness

 

In January of this year, we were joined by the Chair of the Brook House Inquiry, Kate Eves, at our Annual General Meeting (AGM). We invited her to present the findings from the report alongside Anna Pincus, Director of Gatwick Detainees Welfare Group (GDWG) – one of AVID’s members who visit in Brook House Immigration Removal Centre (IRC) - in a discussion on the role of visitors in bearing witness to the harms of detention and what next after the revelations of the Brook House Inquiry.

In this blogpost, which follows the publication of the governments response to the Inquiry on 19th March, we share what we learnt at our AGM and reflect on the importance of keeping the findings from the Brook House Inquiry in the spotlight.

Prior to our AGM, Kate Eves suggested that she could bring copies of the inquiries report to the event. We readily agreed although we had not anticipated the weight of three volumes, the first two of which are more than three hundred pages. This is in marked contrast to the government response which could fit on no more than ten pages of A4. Ms Eves could not take us through the extensive evidence which was heard during the course of the inquiry (for which they received over 100,000 pages of written evidence) but provided a background to the Inquiry, key findings and what we could expect next.

The backdrop to the inquiry was a High Court Judgement in 2019 which ruled that a public inquiry was necessary under the ECHR Article 3 (prohibition of torture) investigative duty. At our AGM, we heard that the terms of reference set a clear requirement to reach conclusions on credible evidence of Article 3 mistreatment including identifying responsibility for that mistreatment (as a statutory inquiry it did not however have the power to determine civil or criminal liability). The Chair found evidence of 19 instances in which there was credible evidence of acts or omissions that were capable of amounting to mistreatment contrary to Article 3 during the period April-August 2017 in Brook House IRC.

Despite this clear remit of the inquiry, it is notable that the government response to the inquiry does not make reference to this finding, in their introduction or elsewhere. The response also appears to fall short of recognising that – as was made clear by the Chairs Statement and report –  mistreatment was not a result of a small minority of people but resulted from entrenched systemic issues and a toxic culture:

“We expect the highest standards from all contracted service provider staff… the government has been clear from the outset that the sort of behaviour on display from some of those staff was totally unacceptable” (Government response, Introduction, 2.)

On speaking at our AGM, Kate Eves emphasised that all of her 33 recommendations need to be implemented to avoid potential recurrence of the mistreatment seen at Brook House. She had called on the Home Office and other recipients to respond to these recommendations within six months of the publication of the report. The recommendations include (not for the first time) a 28-day time limit on the use of detention; an immediate stop to the use of dangerous restraining techniques; a review of Rule 35 so that all three parts are followed, operate effectively and are properly resourced; and an urgent independent review into the use of force on detained people with mental ill health.

The government response does not address all of the recommendations separately and instead gives a summary of the changes made across ten themes in the Brook House Inquiry report. We have listed the 33 recommendations as they appear in the report at the bottom of this blogpost for ease of reference.

In response to the recommendation that there should be a 28-day time limit:

“the government does not accept the recommendation that it should set a time limit on detention. A time limit would significantly impair the ability to remove those who have breached immigration laws and refused to leave the UK voluntarily. The Illegal Migration Act makes it clear that immigration detention must only be used for a period of time that is reasonably necessary, in the opinion of the Secretary of State, for the relevant immigration function to be carried out.” (6.3.2.)

The detailed recommendations from the Brook House Inquiry Report on the use of force – including an end to dangerous restraining techniques and an urgent review of force being used on people with mental ill health - are addressed over three paragraphs in the governments response starting with:

“it may be deemed necessary to use reasonable force to affect a removal from the UK and ensure security, order and safety is maintained whilst detained.” (6.6.1.)

The response follows that it has been communicated to all IRC contracted staff that handcuffing behind backs whilst seated is not permitted (this was already not permitted in 2017 when staff were found to be regularly using the technique nonetheless) and a commitment to a new Detention Service Order (DSO) on the use of force alongside an overhaul of assurance processes.

In response to the recommendations on safeguards, we are told that the Home Office is currently undertaking a review of the Adults at Risk Policy and of Rule 34 and 35.

As we heard from our second speaker at our AGM, Anna Pincus, this is urgently needed. GDWG are amongst other AVID members who are seeing continued failures in the application of Rule 35 with a lack of Rule 35 (1) and Rule 35 (2) reports being completed, delays in receiving appointments and further delays processing applications. The failures to safeguard people in detention has had devastating consequences. On 9th November 2023 a man tragically died in hospital after hanging himself in Brook House. This was the first death by suicide in Gatwick IRCs – Anna told us – in their near 30 years of supporting people detained in these centres. Further, and despite being told in the government response that a 9-hour maximum on night lock-ins has been instated, lock-in times during the day have been increased by an hour in the daytime in Brook House IRC.

Overall, the government response does not instil hope that there is willingness from the government to listen to the findings and recommendations from the Brook House Inquiry. However, as Kate Eves reminded us in her talk, the inquiry findings remain in the public domain, including video and testimonial evidence. It is our responsibility to ensure that this evidence and, vitally, the bravery of people who gave evidence, is not forgotten. This has been the endeavour of GDWG’s Walking Inquiry which listened to a broad range of witnesses (visitors, people with experience of detention and others) to answer vital questions - What is it like to be detained? How are people detained and what are the systems and structures of detention? Why are people who have experienced detention not heard? – in a process of healing which resulted in a parliamentary event, exhibition and a powerful collection of art, poetry, letters and testimonies.

We cannot put it better than Anna who, at the end of her talk, left us with:

“We are convinced that all visitor groups working more closely and combining our monitoring and evidence gathering will be a strength in the future. Our visitors are human rights monitors, but more than that they are human rights beacons. They see and describe but they also enact and demonstrate a better way and shine a hopeful light.”

 

Thank you to Paul Hamlyn Foundation who hosted us at their offices for the event.

 

Brook House Recommendations as they appear in the Brook House Inquiry Report Volume II

The Contract to run Brook House

Recommendation 1: Robust monitoring of contract performance.

The Home Office must actively and robustly monitor the performance of the Brook House contract, including satisfying itself that any self-reported information is accurate. This may include engagement with monitoring bodies and appropriate stakeholders. Penalties must be attached to inadequate self-reporting.

Recommendation 2: Contractual term requiring compliance with the overriding purpose of Rule 3 of the Detention Centre Rules 2001.

The Home Office must ensure that each contract for the management of an immigration removal centre must expressly require compliance with the overriding purpose of Rule 3, which is to provide “the secure but humane accommodation of detained persons in a relaxed regime with as much freedom of movement and association as possible, consistent with maintaining a safe and secure environment, and to encourage and assist detained persons to make the most productive use of their time, whilst respecting in particular their dignity and the right to individual expression”. The provisions and operation of each contract must be consistent with and uphold the requirements of the Detention Centre Rules 2001, the Adults at Risk in Immigration Detention policy and the safeguards contained in detention services orders (including those concerning the use of force).

The physical design and environment

Recommendation 3: Limit on cell sharing.

The Home Office must ensure that a maximum of two detained people are accommodated in each cell at Brook House.

Recommendation 4: Ensuring computer and internet access.

The Home Office and its contractors must ensure reasonable access to computers and the internet. Contractors must comply in full with Detention Services Order 04/2016: Detainee Access to the Internet, in particular:

• Computers and the internet provided for detained people’s use must be maintained and fixed, if broken, within a reasonable time period, in order to allow detained people to access the internet for a minimum of seven hours per day, seven days per week.
• Websites containing personal internet-based email accounts must not be blocked, since this is not a prohibited category of website.
• Websites facilitating the provision of legal advice and representation must not be blocked, as this is not a prohibited category of website.

Recommendation 5: Undertaking and complying with cell‑sharing risk assessment.

The Home Office must ensure that adequate risk assessment for cell sharing is carried out by contractors in relation to every detained person. This must be done at the outset of detention and then repeated at reasonable intervals (at least every 14 days) or following any relevant change in circumstances. In the event that an immigration removal centre is unable to detain someone in accordance with the outcome of a risk assessment (due to capacity or for other reasons), the Home Office must ensure that the individual does not remain at that centre.

Detained People’s Safety and Experiences

Recommendation 6: Review of the lock‑in regime.

The Home Office, in consultation with the contractor responsible for operating each immigration removal centre, must review the current lock in regime and determine whether the period of time during which detained people are locked in their cells could be reduced. The Inquiry does not consider cost alone to be a sufficient justification for extensive lock-in periods.

Recommendation 7: A time limit on detention.

The government must introduce in legislation a maximum 28-day time limit on any individual’s detention within an immigration removal centre.

Safeguards for vulnerable individuals

Recommendation 8: Mandatory training on Rule 34 and Rule 35 of the Detention Centre Rules 2001.

The Home Office (in collaboration with NHS England as required) must ensure that comprehensive training on Rule 34 and Rule 35 of the Detention Centre Rules 2001 is rolled out urgently across the immigration detention estate. Staff must be subject to refresher training, at least annually. Attendance must be mandatory for all staff working in immigration removal centres and those responsible for managing them, as well as GPs and relevant Home Office staff. Consideration must be given as to whether such training should be subject to an assessment.

Recommendation 9: Review of the operation of Rule 35 of the Detention Centre Rules 2001.

The Home Office must, across the immigration detention estate, assure itself that all three limbs of Rule 35 of the Detention Centre Rules 2001 (reports by a medical practitioner where: (i) it is likely that a detained person’s health would be injuriously affected by continued detention (Rule 35(1)); (ii) it is suspected that a detained person has suicidal intentions (Rule 35(2)); or (iii) there is a concern that a detained person may have been a victim of torture (Rule 35(3))) are being followed, are operating effectively, and are adequately resourced, in recognition of the key safeguarding role that the Rule plays. The Home Office must also regularly audit the use of Rule 35 in order to identify trends, any training needs and required improvements.

Restrictions on detained people

Recommendation 10: Clarification on the use of Rule 40 and Rule 42 of the Detention Centre Rules 2001.

The Home Office must amend, as a matter of urgency, Detention Services Order 02/2017: Removal from Association (Detention Centre Rule 40) and Temporary Confinement (Detention Centre Rule 42) and, if necessary, the Detention Services Operating Standards Manual for Immigration Service Removal Centres, to clarify who can authorise use of Rule 40 and Rule 42 of the Detention Centre Rules 2001, in both urgent and non-urgent circumstances, including providing a definition of the term ‘manager’ in Rule 40(2) and Rule 42(2). In anticipation of the update to Detention Services Order 02/2017, the Home Office must issue an immediate instruction to communicate this clarification to staff and contractors operating immigration detention centres.

Recommendation 11: Review of the use of E Wing at Brook House.

The Home Office and the current operator of Brook House must keep under review the appropriateness of the multi-purpose use of E Wing, particularly in relation to its suitability as a location to detain vulnerable people.

Recommendation 12: Training in relation to Rule 40 and Rule 42 of the Detention Centre Rules 2001.

The Home Office and contractors operating immigration removal centres must provide regular training, at least annually, on the operation of Rule 40 and Rule 42 of the Detention Centre Rules 2001, which must include:

• that Rules 40 and 42 are the only powers under which detained people in immigration removal centres can be removed from association and/or located in temporary confinement;
• who is permitted to authorise use of those Rules and in what circumstances they may be authorised;
• that Rules 40 and 42 cannot be used as a punishment or solely for administrative convenience before a planned removal or transfer; and
• the need to assess any adverse effect that use of Rule 40 or Rule 42 could have on a detained person’s physical or mental health, and to consider any steps that could be taken to mitigate those effects. Attendance must be mandatory for all staff working in immigration removal centres and those responsible for managing them. The training must be subject to an assessment.

Recommendation 13: Audit of use of Rule 40 and Rule 42 of the Detention Centre Rules 2001.

The Home Office must regularly (and at least quarterly) audit the use of Rule 40 and Rule 42 across the immigration detention estate, in order to identify trends, any training needs and required improvements. In addition, HM Inspectorate of Prisons and the National Chair and Management Board of Independent Monitoring Boards must review processes to consider how they fulfil their oversight role in respect of Rule 40 and Rule 42, and report on the monitoring of the use of Rules 40 and 42 going forward.

Use of Force

Recommendation 14: Handcuffing behind backs while seated.

The Home Office and contractors operating immigration removal centres must ensure that all staff are aware that the technique of handcuffing detained people with their hands behind their back while seated is not permitted, given its association with positional asphyxia.

Recommendation 15: A new detention services order about the use of force.

The Home Office must introduce, as a matter of urgency, a new and comprehensive detention services order to address use of force in immigration removal centres. The detention services order must include the following issues:

• the permissible justifications for the use of force within immigration removal centres, based on the key principle that force must not be used unnecessarily and must be used only as a last resort;
• the use of Personal Protective Equipment (PPE), including that it must be subject to a dynamic risk assessment before and during any use of force incident;
• the protection of dignity when force is used on a naked or near-naked detained person;
• the circumstances in which force can be used against a detained person with mental ill health; and
• monitoring, oversight and reporting of use of force by contractors and by the Home Office.

The Home Office must ensure that training about the application of the new detention services order and use of force techniques takes place on a regular (at least annual) basis for all detention staff as well as healthcare staff. Attendance must be mandatory for all staff working in immigration removal centres and those responsible for managing them. The training must be subject to an assessment. In anticipation of a new detention services order on the use of force in immigration detention, the Home Office must issue an immediate instruction to its contractors managing immigration removal centres that force must be used only as a last resort, using approved techniques.

Recommendation 16: Urgent review of use of force on detained people with mental ill health.

The Home Office must urgently commission an independent review (with the power to make recommendations) of use of force on detained people with mental ill health within immigration removal centres. The review must consider:

• how, when and whether to use force on detained people with mental ill health (including the application of pain-inducing techniques);
• the likely effect of the use of force on a detained person’s mental health;
• the use of individual risk assessments for detained people, which could be conducted by personal officers and healthcare professionals; and
• the increased use and prioritisation of de-escalation techniques for those who have mental ill health.

The review must take place in consultation with relevant stakeholders, including detained people’s representative groups and mental ill health experts. The recommendations of the review must be incorporated in the new detention services order regarding the use of force (see Recommendation 15), in respect of which additional, regular (at least annual) training should then be provided.

Recommendation 17: Urgent improvement of use of force reviews.

The Home Office must ensure, as a matter of urgency, that training is delivered on how to conduct an effective use of force incident debrief, ensuring that issues of detained person and staff welfare, as well as training needs, are covered. The training must be mandatory for all immigration removal centre contractor employees who conduct such reviews and those who manage them. The Home Office must also require that use of force incidents be reviewed, at a minimum, at the following levels:

• Within 36 hours of each use of force incident, the Use of Force Coordinator must conduct a thorough incident review, ensuring that all documentation and footage are collated and preserved, and with a view to taking emergency action in instances of unlawful or inappropriate force. On a weekly basis, all use of force incidents must be reviewed (including all necessary paperwork and available video footage) at a formal meeting by the Use of Force Coordinator and a suitable manager in order to review each incident and to identify any issues or further action required.
• On a monthly basis, immigration removal centre contractor senior management must arrange meetings with other stakeholders (including detained people and representatives of non-governmental organisations) to review use of force trends.
• Periodically, the Home Office (or its Professional Standards Unit if the Home Office considers it more appropriate) must review use of force at Brook House and across the immigration detention estate, to identify trends and to direct the implementation of any changes and improvements that are required. This review process must be reflected in the new detention services order regarding the use of force – see Recommendation 15 – in respect of which additional, regular (at least annual) training must then be provided.

Healthcare

Recommendation 18: Urgent guidance in relation to food and fluid refusal.

The Home Office must, as a matter of urgency, update Detention Services Order 03/2017: Care and Management of Detained Individuals Refusing Food and/or Fluid, to ensure that it deals with:

• food and fluid refusal being clearly and directly linked to consideration of the Rule 35 process and whether a detained person is defined as an ‘adult at risk’;
• the consideration by the healthcare provider at each immigration removal centre, upon an incidence of food and fluid refusal occurring, of assessments of mental capacity, of mental state, and under Rule 35, and the conduct of these where indicated, as well as ensuring compliance with the Adults at Risk in Immigration Detention policy and making sure that decisions made in relation to these are recorded;
• the notification to the Home Office of the numbers of detained people refusing food and fluids, and the reasons for such refusal, on a monthly basis (in the same way that incidents of self-harm are notified); and
• the monitoring by the Home Office of the compliance by healthcare providers with Detention Services Order 03/2017 and the numbers of detained people refusing food and fluids, and the reasons for such refusal, in order to identify any patterns of concern and take appropriate action. The Home Office must ensure that mandatory training about the application of the updated detention services order takes place on a regular (at least annual) basis for all detention staff and healthcare staff, as well as those responsible for managing them.

Attendance must be mandatory for all staff working in immigration removal centres and those responsible for managing them. The training must be subject to an assessment. In anticipation of the update to Detention Services Order 03/2017, the Home Office must issue an immediate instruction to communicate this clarification to those operating immigration detention centres.

Recommendation 19: Guidance and training for healthcare staff on the use of force.

The Home Office must ensure that guidance is issued to healthcare staff in immigration removal centres clarifying their role in use of force incidents. It must liaise as necessary with NHS England and any relevant medical regulators. The Home Office must ensure that mandatory training is introduced for healthcare staff, and those responsible for managing them, on their roles and responsibilities in relation to planned and unplanned use of force (liaising with NHS England and any other relevant parties). The training must be subject to an assessment.

Recommendation 20: Updating guidance regarding ‘fit to fly and fit for detention’ letters.

The Home Office must review and update Detention Services Order 01/2016: The Protection, Use and Sharing of Medical Information Relating to People Detained Under Immigration Powers, to ensure that guidance given to GPs working in the immigration detention estate in relation to their duties and responsibilities in writing ‘fit to fly and fit for detention’ letters is clear. It must liaise with NHS England and any relevant medical regulators as necessary. The Home Office must ensure that training about the updated guidance takes place on a regular (at least annual) basis for GPs working in the immigration detention estate and those responsible for managing them. The training must be subject to an assessment. The Home Office must monitor compliance with this updated guidance at least annually.

Recommendation 21: Ensuring effective communication of medical information.

The Home Office must review and update Detention Services Order 04/2020: Mental Vulnerability and Immigration Detention: Non-Clinical Guidance to set out comprehensive guidance for detention and healthcare staff where there are concerns that a detained person is suffering mental ill health or lacks mental capacity. This must include an appropriate system for:

• the routine handover or sharing of relevant information between detention custody staff and healthcare staff (for example, in Security Information Reports and Anti-Bullying Support Plans);
• the identification and follow-up of missed medical appointments;
• the assessment of mental capacity where indicated; and
• mental health assessment where indicated. The Home Office must ensure that training about the updated guidance takes place on a regular (at least annual) basis for detention and healthcare staff, as well as those responsible for managing them. The training must be subject to an assessment.

Recommendation 22: Improving the handling and audit of healthcare complaints.

The Home Office must review and update Detention Services Order 03/2015: Handling of Complaints to ensure that appropriate guidance is given to healthcare providers on the investigation and handling of complaints specific to the provision of healthcare in an immigration detention setting. The Home Office must ensure that training about the updated guidance takes place on a regular (at least annual) basis for staff dealing with healthcare complaints, as well as those responsible for managing them. The training must be subject to an assessment. Healthcare providers in immigration removal centres must ensure that all healthcare complaints are robustly investigated in accordance with the updated guidance. The methodology and outcomes must be clearly communicated, including to the detained person. They must also ensure that appropriate, regular (at least annual) training and guidance is provided to those holding responsibility for the investigation of healthcare complaints.

Staffing and Culture

Recommendation 23: Ongoing assessment of staffing levels.

The Home Office and contractors operating immigration removal centres must ensure that there is ongoing assessment of staffing levels (at least on a quarterly basis), so that the level of staff present within each centre is appropriate for the size and needs of the detained population. The Home Office must also ensure that the detained population does not increase at any immigration centre unless staffing is at an adequate level.

Recommendation 24: Mandatory training for immigration removal centre staff.

The Home Office, in conjunction with contractors, must ensure that all relevant immigration removal centre staff receive mandatory introductory and annual training on: mental health; race and diversity; a trauma-informed approach; their own resilience; drug awareness; and the purpose of immigration removal centres. This training must include the perspectives of, or be conducted in consultation with, detained people. The Home Office must also ensure, in conjunction with contractors, that new joiners must start on probation on completion of introductory training and be adequately supervised for a period of time as necessary to establish their competence to work independently.

Recommendation 25: Improving the visibility of senior managers within centres.

Contractors operating immigration removal centres must ensure that senior managers are regularly present and visible within the immigration removal centre and are accessible to more junior detention staff.

Recommendation 26: Improving the visibility of Home Office staff.

The Home Office must ensure that its staff are regularly present and visible within each immigration removal centre.

Recommendation 27: Developing a healthy culture among staff.

Contractors operating immigration removal centres must develop and implement an action plan to ensure a safe and healthy staff culture in immigration removal centres. The action plan must address:

• the identification of and response to any sign of desensitisation among staff;
• training staff on coping mechanisms and secondary trauma awareness; and
• maintaining an appropriate balance between care and safety or security.

The Home Office must regularly monitor each contractor’s compliance with its action plan.

Complaints and Whistleblowing

Recommendation 28: Action to address barriers to making complaints.

The Home Office and its contractors operating immigration removal centres must take steps to identify and address the barriers to making complaints that are faced by detained people, including a fear of repercussions. This must include training for staff on their role in enabling detained people to overcome these barriers.

Recommendation 29: Improving investigations by the Home Office Professional Standards Unit.

The Home Office must update Detention Services Order 03/2015: Handling of Complaints to clarify that, in investigations carried out by the Professional Standards Unit into allegations of serious misconduct against contractor staff:

• Professional Standards Unit investigators must carry out interviews themselves and not rely on contractors to do so.
• All staff against whom allegations are made must be invited to interview.
• Where there are inconsistencies between any accounts given of events, any evidence relating to those accounts (including footage and documentation) obtained by an investigating officer must be shown to the complainant and to the subject of the complaint prior to reaching a conclusion.
• The Professional Standards Unit must be given information about previous complaints made against alleged perpetrators, including unsubstantiated complaints.
• Previous disciplinary action against alleged perpetrators must be taken into account.
• Investigators must look for evidence that is both supportive and undermining of the complaint.
• Full reports must be sent to complainants (and their solicitors if applicable).
• Investigation reports and/or outcome letters must be sent directly from the Professional Standards Unit to complainants (and their solicitors if applicable).

The Home Office Professional Standards Unit must ensure that training about the updated guidance takes place on a regular (at least annual) basis for staff dealing with investigations, as well as those responsible for managing them. The training must be subject to an assessment. The Professional Standards Unit must also review the training provided to investigators and ensure that investigators receive regular and adequate training, from a variety of perspectives, on issues including:

• the nature of immigration removal centres and issues that may arise;
• obstacles that detained people may face in making complaints;
• interviewing vulnerable witnesses; and
• use of force and assessing reasonableness of force.

Recommendation 30: Improving the independence of the Home Office Professional Standards Unit.

The Home Office must:

• take steps to enhance the independence of the Professional Standards Unit from the Home Office and the perception of this independence; and
• increase the seniority of the Head of the Professional Standards Unit so that they are closer in status to the Heads of the relevant Home Office Immigration Enforcement teams.

Recommendation 31: Improving the process for and response to whistleblowing.

The Home Office must update Detention Services Order 03/2020: Whistleblowing – The Public Interest Disclosure Act 1998 to require contractors that run immigration removal centres to:

• have a whistleblowing policy and procedure that is specific to the immigration detention environment;
• ensure that the whistleblowing mechanism is not limited to a hotline and allows for anonymous reporting of concerns;
• ensure that those who receive whistleblowing concerns have an understanding of immigration removal centres;
• take active steps to encourage staff to use whistleblowing processes, for reasons including those set out at paragraph 10 of Detention Services Order 03/2020; and
• ensure that whistleblowing concerns are investigated thoroughly by someone external to the immigration removal centre, and that the Home Office is informed of the nature of the concern and the investigation carried out.

The Home Office must ensure that training about the updated guidance takes place on a regular (at least annual) basis for staff dealing with whistleblowing, as well as those responsible for managing them. The training must be subject to an assessment.

Inspection and Monitoring

Recommendation 32: Enhancing the role of the Independent Monitoring Boards.

The government must:

• respond to and publish responses to all concerns raised by any Independent Monitoring Board regarding immigration removal centres;
• take steps without further delay to amend the Detention Centre Rules 2001, in so far as they govern Independent Monitoring Boards, in order to accurately reflect their current role; and
• consider whether to put the National Chair and Management Board of the Independent Monitoring Boards on a statutory footing.

Recommendation 33: Improving the investigation and reporting of HM Inspectorate of Prisons and Independent Monitoring Boards.

 HM Inspectorate of Prisons and Independent Monitoring Boards working within immigration removal centres must ensure that they have robust processes for:

• obtaining and reporting on an enhanced range of evidence and intelligence from detained people and those who represent or support them, staff and contractors, including that which is received outside of inspections or visits; and
• reporting on any concerns about the Home Office and contractors.