Report into Tinsley House, Section 3: Summary of recommendations

hm-inspector-of-prisonstinsley-houseThe following is a list of both repeated and further recommendations included in this report. The reference numbers in brackets refer to the paragraph location in the main report.

Main recommendations (from the previous report)
To the centre manager
3.1 If children are to remain at Tinsley House, their detention should be exceptional and only for a few days. (2.1)
3.2 If single women are to remain at Tinsley House, their distinct needs should be systematically identified and met. (2.2)
3.3 If children are to remain at Tinsley House, a qualified teacher should be employed to provide structured and planned education to meet the needs of school-age children. (2.7)
3.4 The centre should provide a welfare officer or team to help detainees prepare for their discharge. (2.8)
Recommendations To the chief executive, UKBA
3.5 Detainees should not be subjected to frequent, unexplained and disorienting transfers around the detention estate. (2.11)
3.6 Reviews of detention should be issued in good time, in a language the detainee can understand, and should reflect balanced consideration of all factors relevant to continuing detention. (2.13)
3.7 On-site staff should regularly review case files and flag up concerns to case holders. (2.14)
3.8 UKBA case owners should consider and respond promptly and fully to detainee applications for temporary release. (2.15)
3.9 Detainees should have sufficient time to confer with representatives before hearings that use the video link facility. (2.16)
3.10 In consultation with the centre, UKBA should ensure that all detainees receive a copy of the bail summary in due time before the hearing, and the on-site immigration team should monitor the receipt of bail summaries. (2.18)
3.11 Detainees who clearly demonstrate a health need should have a care plan. The nurse on duty should see the patient each shift and, if necessary, update the care plan. (2.21)
3.12 The practice of taking additional detainees as reserves to the airport as part of charter flight removals should cease. (2.38)

Recommendations To the chief executive, UKBA and centre manager
3.13 Records on individual children should state the cumulative period of detention. (2.22)
3.14 Accurate records should be maintained of the average and cumulative length of stay of each child held at Tinsley House. (2.23)
3.15 The central log of rule 35 notifications and caseworker responses should include a copy of the notifications and responses. (2.25)
3.16 Use of separation for more than 24 hours should be authorised, with reasons recorded, by UKBA’s representative. (2.27)
3.17 The centre should be notified of the outcome of complaints dealt with by UKBA for inclusion in its overall monitoring and analysis of complaints and issues of concern to detainees. (2.28)

Recommendations To the escorting contractor

3.18 Escorts should use a professional interpreting service to respond to detainees’ queries and concerns and to explain, in a language they understand, what is happening to them during transfer and removal. They should not provide false assurances to detainees being transferred or removed. (2.30)
3.19 Escort vehicles should be clean. (2.32)
3.20 All escorting staff should wear name badges and introduce themselves to detainees.(2.39)
Recommendations To the centre manager
Arrival in detention

3.21 The first night risk assessment form should be revised to include a more comprehensive list of questions and details of other sources – such as the escort record and prison file – to make an assessment of risk. It should be re-issued with guidelines for staff to ensure that it provides an adequate assessment of risk. (2.41)
3.22 The reception area should be refurbished. (2.48)
3.23 The first night risk assessment interview should take place in private. (2.49)
3.24 A copy of the information booklet should be provided to every detainee in their own language, and the English and translated versions should be checked for comprehensibility. (2.50)
3.25 Telephone interpreting should be used where necessary to complete the reception procedures, first night risk assessment and induction talk. (2.51)
3.26 Induction should provide all detainees with the information they require to access all the centre’s services. (2.52)
3.27 Induction information should be explained to detainees who do not speak English fluently in their own language through telephone or face to face interpreting. (2.53)
Environment and relationships
3.28 Residential units should be properly ventilated, and detainee living areas should receive priority for the installation of air conditioning units. (2.54)
3.29 The worn carpets and chairs in the association areas should be replaced. (2.55)
3.30 Single women should have adequate accommodation, and access to their own dining and association facilities. (2.56)
3.31 Detainees should have access to hot water to enable them to make a hot drink at any time. (2.58)
3.32 Smokers should be restricted to a properly maintained discrete external area, which does not intrude on non-smokers and is not visible to children. (2.59)
3.33 Discussions at the consultative committee should be more in depth, and issues raised should be followed up between meetings. (2.60)
3.34 More use should be made of the professional interpreting services or, when appropriate, detainee or staff interpreters, to communicate with detainees who do not speak English. (2.62)
3.35 A care officer scheme should be implemented. (2.63)
3.36 History sheets should be used to record and develop knowledge and understanding of detainees. (2.64)
3.37 The centre should use a system other than public address to contact individual detainees, such as contacting them by their mobile phone. (2.69)
3.38 The public address speakers should be removed from family sleeping areas. (2.70)
3.39 In consultation with custody and other staff, senior G4S and UKBA managers should address concerns about the deterioration of positive staff-detainee relationships. (2.71)
3.40 In consultation with the Legal Services Commission, the centre should seek ways of improving access to specialist legal advice and representation for detainees. (2.72)
3.41 The legal and immigration reference materials in the library should be kept up to date, and those held on the computer should be accessible during library opening times. (2.74)
3.42 Refugee and Migrant Justice legal advice sessions should be available to detainees on an appointments basis and in a private area. (2.78)
3.43 The free legal advice phone lines should be properly maintained to ensure they offer an effective service at all times. (2.79)

Duty of care
3.44 Regular surveys should take place to monitor detainees’ perceptions of bullying and, in particular, establish the concerns of single women. (2.80)
3.45 Detainees should be actively encouraged to attend the safer detention meetings, which should always discuss bullying in the centre. (2.82)
3.46 All staff should attend refresher training on potential bullying, and the establishment should maintain records on participation. (2.84)
3.47 There should be effective multi-agency input into reviews and care plans for managing detainees at risk of self-harm, including UKBA staff when appropriate. (2.85)
3.48 Care plans should be prepared with input from the detainee, using interpreters if required. Actions identified in care plans should be assigned to an individual to ensure accountability. (2.87)
3.49 Records of observations should describe interaction between staff and the detainee, and observations should not be predictable. (2.88)
3.50 Detainees should be able to access the care suite more easily, and its role should be advertised. (2.90)
3.51 Peer interpreters should only be used in assessment, care in detention and teamwork (ACDT) reviews to support detainees, not to replace professional interpreters. (2.91)
3.52 All healthcare staff should complete the full training for ACDT, and a copy of the training record should be maintained. (2.93)
3.53 The data gathered in relation to self-harm should be analysed to identify any significant patterns and trends. The results of this analysis should be used to carry out any necessary preventative work. (2.97)
3.54 Whenever separation or strip clothing are used to manage the risk of selfharm, the reasons should be clearly recorded. (2.99)
3.55 The quality of written contributions to ACDT documentation should be consistently high. (2.101)
3.56 Healthcare staff should be actively involved in the ACDT process and attend reviews. (2.105)
3.57 All staff should be trained in child protection by specialist staff, and accurate records maintained. (2.107)
3.58 There should be 24-hour cover by trained childcare workers. (2.108)
3.59 Social workers who have been involved in assessments or child protection referrals of individual children should attend the relevant weekly welfare telephone conferences and other meetings in the centre concerning any aspect of care planning. (2.109)
3.60 Children held beyond seven days should have a care plan based on a comprehensive  independent welfare assessment, which should be subject to weekly review and inform decisions about continued detention. (2.110)
3.61 There should be minutes of the weekly welfare conferences to record relevant information and action points to inform individual care plans.  (2.111)
3.62 There should be a protocol or service level agreement with the Local Safeguarding Children Board setting out the arrangements for joint working on child protection and welfare assessments. (2.112)
3.63 The facilities, conditions and specialist staffing arrangements for the treatment of children in the centre should be improved immediately, failing which children should not be held at the centre. (2.120)
3.64 Force should only be used on children where there is a serious risk of harm to themselves or others. UKBA should communicate this through the estate urgently, and publish it in the relevant agency code of practice. (2.121)
3.65 A comprehensive diversity strategy should be produced, accompanied by an action plan and overseen by a diversity committee. (2.122)
3.66 All racist incident complaints should be promptly investigated, and conclusions and outcomes should be clearly recorded on the racist incident log. (2.124)
3.67 Outcome letters should be sent promptly to detainees and copies kept on file. (2.125)
3.68 All staff should receive annual diversity refresher training, and this should be recorded. (2.127)
3.69 The race equality officer should have enough time to fulfil his duties and his role should be promoted in the centre. (2.128)
3.70 Race relations meetings should provide strategic oversight and direction on race issues. They should consider racist incidents, nationality and ethnic monitoring in detail, and provide a means of monitoring and promoting race equality. (2.129)
3.71 Staff should be encouraged to use the telephone interpreting service, particularly to communicate with vulnerable detainees. (2.130)
3.72 There should be regular meetings with detainees who speak little English, using professional interpreters, to ensure good communication and identify unmet needs. (2.131)
3.73 Ethnic and nationality monitoring of detainees should be developed to examine and identify any problems. (2.132)
3.74 There should be positive promotion of diversity throughout the centre. (2.133)
3.75 The multi-faith facilities for detainees should be improved. (2.135)
3.76 There should be greater use of professional interpretation services to cater for the religious needs of detainees who speak little or no English. (2.136)

Health services
3.77 Health services should establish formal links with the provider and commissioning sections of the primary care trust to promote quality assurance of services and ensure the health needs of detainees are met. (2.140)
3.78 Health needs assessment work should include independent external input and review. (2.141)
3.79 The health needs assessment should be extended to cover child detainees’ mental health needs. (2.143)
3.80 A healthcare action plan based on up to date health needs assessment should be agreed and updated annually. (2.144)
3.81 Healthcare staff should make every effort to attend multidisciplinary meetings, especially those concerning child protection and ACDT. If necessary, cover from Brook House should be used to facilitate attendance. (2.146)
3.82 Accommodation for the healthcare team should be expanded so that patient confidentiality can be preserved during consultations and administration of medicines, and to enable doctor- and nurse-led clinics to take place simultaneously. (2.147)
3.83 The clinic should be refurbished as soon as possible, and it should include hand-washing facilities that meet infection control guidelines. (2.149)
3.84 The health provider should negotiate with the PCT to provide experienced health professionals, such as health visitors, to visit the centre regularly to ensure that the health and welfare needs of children are met. (2.152)
3.85 A minuted meeting of the health team should take place regularly to promote communication, develop consistent policy and practice, and to improve quality of care for detainees. (2.153)
3.86 All health staff should receive in-depth training on recognition and treatment of patients who have experienced torture and violence. (2.154)
3.87 An annual staff learning and development plan should be agreed that is based on the health needs of detainees, the aims and objectives of the service, and the personal professional development needs of staff. (2.155)
3.88 Health staff should be offered external supervision. (2.156)
3.89 The healthcare department should introduce monitoring systems to ensure that detainees have equal access to services irrespective of age, gender, language, national origin etc. (2.157)
3.90 Professional interpretation should be used routinely for interpreting patients’ health needs. Family members or friends should only provide support and this should be noted in the detainee’s clinical record. (2.159)
3.91 There should be a consistent, multidisciplinary approach to assess and report on the extent to which a person’s physical or mental health is or could be adversely affected by detention. (2.161)
3.92 Prescribing trends should be regularly reviewed to ensure appropriate evidence-based prescribing. (2.162)
3.93 Patients should have access to the advice of a pharmacist. (2.164)
3.94 Prescribed medicines should not be issued from stock. (2.165)
3.95 Administrative support should be provided at Tinsley House to release qualified nurses for professional duties in the care of detainees. (2.172)
3.96 Clinical audit should be introduced and reviewed regularly. (2.173)
Substance use
3.97 The need for a more explicit strategy for the management of illicit drugs and problem alcohol use should be considered at least annually. (2.174)
3.98 Detainees’ cooperation or failure to cooperate with removal should not be considered as part of the recruitment to paid work roles. (2.6)
3.99 Detainees should be able to complete accredited qualifications started at other establishments. (2.176)
3.100 The centre should provide a wider range of structured learning opportunities to suit the needs of longer stay and English-speaking detainees.(2.178)
3.101 There should be improved promotion of sports and gym activities to make better use of available capacity. (2.179)
3.102 The centre should identify and effectively promote appropriate gym and sporting activities to women detainees. (2.180)
3.103 Access to fresh air and exercise for children should be improved, including direct access to the  outside area from the family suite. (2.181)
3.104 The outdoor area set aside for children should be screened from the adult exercise areas.(2.182)
3.105 There should be more books and activity materials for older children. (2.183)
3.106 There should be thorough and effective arrangements to assure and improve the quality of activities. (2.191)
3.107 The promotion of classes in English for speakers of other languages (ESOL) and arts and crafts should be improved, especially to non-English speaking detainees. (2.192)
3.108 The library should be managed by appropriately trained staff, and there should be systems for managing and renewing the stock of books and other materials. (2.193)
3.109 Detainees should have ready access to up-to-date legal reference materials. (2.194)
3.110 Patterns of attendance at the gym and take-up of sporting activity should be monitored and the outcomes used to improve provision. (2.195)
3.111 Supervision of detainees participating in gym and sporting activities should ensure their health and safety. (2.196)
3.112 There should be sufficient staff with specialist training and qualifications in childcare at all times. (2.197)

Rules and management of the centre

3.113 Staff should be encouraged to complete security information reports (SIRs) when appropriate. (2.198)
3.114 A member of the senior management team should monitor all SIRs, and record appropriate actions. (2.199)
3.115 Information from SIRs should be analysed and trends or patterns identified. Objectives should be set from this analysis where necessary. (2.200)
3.116 All detainee security files should be analysed as soon as possible, and action taken promptly where evidence of specific risk is found. (2.202)
3.117 The centre should reassess the rewards scheme and decide whether to continue it. If it is to continue, it should have an up-to-date written policy and be reviewed regularly. (2.205)
3.118 Separation rooms should have furniture in them, which should only be removed or replaced by cardboard furniture following documented risk assessment. (2.208)
3.119 Senior managers should commission and consider action in response to analysis of trends or patterns in use of rule 40 and 42. (2.210)
3.120 Written reasons for separation should be given to detainees in a language they understand. (2.211)
3.121 Security information relating to Tinsley House should be collated, analysed and reported separately from Brook House. (2.218)
3.122 Complaint forms in English and the most common languages should be available for detainees to collect freely and discreetly at all times. (2.219)
3.123 Complaints should be monitored and analysed to identify and respond to patterns and trends. (2.220)
3.124 Complaints from Tinsley House should be handled, recorded and monitored separately from those from Brook House. (2.221)

3.125 Pictorial menus and the menu cycle should be available to detainees before they reach the hotplate so that those with limited English are able to understand what is available. (2.222)
3.126 A pictorial version of the shop price list should be available and it should indicate whether or not items on sale are halal. (2.225)
3.127 The range of hair and skin products suitable for detainees from black and minority ethnic groups should be increased following consultation with them. (2.226)
3.128 Detainees should be consulted on the menu. (2.229)
3.129 The centre should supply condiments and seasoning in the dining area. (2.230)
3.130 A food comments book should be available in the dining area, and its purpose should be advertised in a range of relevant languages. (2.231)

Preparation for release
3.131 Detainees should be offered training in the use of the internet and email. (2.10)
3.132 The centre manager should meet with representatives from the Gatwick Detainees Welfare Group to assess how they can help to improve welfare provision for detainees. (2.233)
3.133 Visitors should be able to purchase or bring in more substantial food. (2.236)
3.134 The centre should have a sufficient stock of mobile phones to loan to detainees. (2.238)
3.135 Detainees transferred into further detention should be given written reasons for the decision and information about the centre to which they are being transferred. (2.239)
3.136 The centre should have a stock of outdoor clothing for detainees being released or removed. (2.241)
3.137 The notice requesting visitors to contact staff if they have any concerns about detainees should be displayed in the languages used by detainees and should supply a phone number. (2.249)
3.138 The centre should develop, publish and implement a policy on the needs and services available to detainees on removal or release, and this should be based on a needs analysis. (2.250)