1. PRISON MANAGEMENT CONTEXT: INFORMAL COMPLAINTS [1.13] The UN Special Rapporteur on torture and others have pointed out that prisoners should be able to make more informal, verbal requests and complaints to prison staff. The opportunity to make representations in this way can mitigate against some of the common barriers to making requests and complaints, including where the procedures are overly bureaucratic or slow. Such informal procedures are also more accessible to particular groups of prisoners, including those who are illiterate or have learning disabilities. 1 In prisons that successfully operate a dynamic security approach to prison management, prisoners are more likely to feel that they can approach prison staff about the problems they face without fear of reprisals, and with the confidence that their requests or complaints will be taken seriously. More serious complaints 160 More serious complaints should be dealt with through formal complaints procedures. Such allegations are likely to be less common but will require more complex, and urgent, investigations and responses. Allegations of torture and other ill‑treatment 161 Special procedures must be applied to deal with allegations of torture and other ill‑treatment in line with the UNCAT and the Manual on the Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (the Istanbul Protocol). 162 Allegations of torture and other ill‑treatment must be dealt with immediately and in accordance with Rule 71. Independent, prompt, impartial and effective investigations must be carried out whenever there are reasonable grounds to believe that an act of torture or other ill‑treatment may have been committed, irrespective of whether a complaint has been received. In those cases, measures should be taken immediately to avoid any contact of the potentially involved persons with witnesses, the victim, or the victim’s family and any involvement of the alleged perpetrator(s) in the investigation. For more information on investigations see Chapter 3, paragraphs 68–101 of this guidance document. Outcome of complaint procedures 163 In all cases, the outcome of the request or complaint, and any follow up action, must be properly communicated to the prisoner who initiated the procedure in an easily understandable format. If families or other representatives initiated the complaint, then they should also be informed of the process and any outcome. 164 Requests and complaints should be recorded in a prisoner’s file in accordance with Rule 8(f). It is also good practice to maintain a centralized register of requests and complaints. In this regard the UNCAT has called for “a centralized register of complaints that includes information on the corresponding investigations, trials and criminal and/or disciplinary penalties imposed”.63 165 As Rule 57(1) makes clear, if a request or complaint is rejected, or in the event of undue delay, the complainant shall be entitled to bring it before a judicial or other authority. 63. Observations of the UN Committee against Torture on the Revision of the United Nations Standard Minimum Rules for the Treatment of Prisoners, 16 December 2013, CAT/C/51/4, para. 53. Guidance document on the Nelson Mandela Rules 37