administration at the Klagenfurt correctional institution. This problem was already described in the NPM’s reports to the National Council and the Federal Council in 2013 and 2014. The NPM advocated systematic recording and evaluation of complaints in light of the major inequalities in punishments for administrative offenses (see NPM Report 2014, p. 101 et seq.). The Federal Ministry of Justice reiterated that there is still no technical means of implementing the “complaint register” module in the integrated prison administration. A “complaint book” similar to the appeals book cannot be reasonably maintained because complaints can be raised in the most diverse manner (internally and externally). However, for the NPM, the importance of complaint management as a source of information regarding deficiencies and opportunities for improvement is still undisputed. It is positive that, since the end of 2014, petitions for administrative review and legal appeals at the Klagenfurt correctional institution which cannot be remedied within the institution’s own purview are provisionally being recorded in an index in the form of an Excel file. The Federal Ministry implementation of a correctional institution 2015. All incoming management, which number. First aid of Justice also gave its assurance that the complaint register at the Vienna-Simmering has been accomplished at the beginning of complaints are now forwarded to the registers the complaint with a consecutive With respect to the implementation of an appropriate module in the integrated prison administration, the Federal Ministry of Justice states that the available resources of the prison administration and the ITprovider for Federal Departments in Austria will likely be needed until the summer of 2015 for the nationwide expansion of the integrated prison administration module for administrative penalty proceedings. Consequently, the IT experts will not be available to analyse and plan the “complaint register” module until mid-2015 at the earliest. Analysis and planning of “complaint register” by mid-2015 at earliest The Federal Ministry of Justice was unable to estimate the scope of the project and the necessary implementation period. However, the Ministry predicted that it will not be possible to place the “complaint register” module into operation in the integrated prison administration at the beginning of 2016. The NPM emphasises that an effective complaint procedure is a basic precaution against mistreatment in prisons. In accordance with the CPT standard, prisoners should have channels for pursuing complaints. These channels should be open to them inside and outside of the prison system [CPT/Inf/E (2002) 1 – Rev. 2010, p. 19]. The NPM reiterates that implementation of the “complaint register” module in the integrated prison administration must be pursued with the utmost vigour.  The systematic recording of complaints in a register is a prerequisite for the correctional 117

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